Submission Number: 560891-00304
Received: 9/11/2012 11:28:08 AM
Commenter: Greta Stamberg
Organization: Clarksburg Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I have no serious problem with competition and consumer choice. Those choices need to be safe and regulated properly. I have concerns about online companies following basic prescription laws, my lack of contact with the client, and the source and safety of the products they distribute.
As a practice owner, there is still a financial bottom line that must be met to continue to provide the level of service that my clients expect and deserve. Prescriptions are a source of income for any practice. As one source of income diminishes, another will have to take it's place. In anticipation of the decreased sale of products and prescriptions (which is already occurring at my practice), I have been increasing my service prices. This will continue as my sales decrease. As I have less control over dispensing, I will require more lab work. Ultimately, the client could end up paying more than if products were purchased through me. We are a service industry and that is where our profits should be focused anyway.
While consumers have a choice, it is not my responsibility to tell them what their choices are and automatically offer a written prescription. I will always write one upon request. What other service industry must offer up the competition to a consumer using their services? If there was a requirement for me to provide a written prescription at all times, I would increase my overall service prices even higher to account for the extra time to offer, discuss, and process the prescriptions. I would also refuse to sign prescriptions faxed to me after sending a written one with the client.
Nearly all of the online pharmacies will still fax me a form to authorize any prescription whether I have already written one or not. Now I have to do the same thing twice and cost the practice more time. Any written prescription I have given the client could be filled online and then the actual written prescription could be taken to a local pharmacy and filled a second time when I have not authorized this. I lose control over managing that prescription as soon as it walks out the door.
For me it also starts blurring the lines of responsibility for information on administration, side effects, other concerns. Is my prescription going to be dispensed properly with information about the drug? Is the client going to ask medical advice of the human pharmacist that has no veterinary education? I have overheard this at Costco and the client was given incorrect information and not told to ask their veterinarian. Is the client going to actually purchase the prescription? Human nature is to be lazy and adding another step to successful treatment will automatically decrease client compliance and there will be fewer pets getting the treatment we prescribe. Nearly every week, I have a client who states their pet is on heartworm preventative and I have no record of a prescription. I have to badger them or note it and move on because there are some pharmacies that fill these without a prescription.
Ultimately, I would like to see a federal protocol for filling prescriptions online and more importantly - enforcement of those rules.
My opinion on external pharmacies is that it is a lose-lose for the client. They lose the personal follow-up they would have through their veterinarian. They lose the guarantee of genuine safe products and the opportunity for us to hold a manufacturer or distributor responsible if there is a problem. They lose on compliance. Some of those pets will never get their medication. They lose on a delay in critical treatment in some cases. They lose on overall costs because service costs will be significantly higher. They also lose on time expended to get the prescription. They lose on proper care when I have no proof that a client has purchased the prescription. At the end of the day, the savings will only be perception, not reality and it will bring an increased risk of improper or unsafe medications.