Submission Number: 560891-00306
Received: 9/11/2012 1:46:13 PM
Commenter: Melinda Cumming
Organization: Spring Glen Veterinary Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am a business owner and practicing veterinarian with a 3 doctor small animal practice that serves primarily cats and dogs. The primary reason I am writing to you is to shed some light on our day to day business in regards to prescription medications for animals.
We currently offer prescription medications via four avenues: from our stock, through our own on-line pharmacy, by written prescription, and fax requests. We do not charge a fee for our time for written prescriptions or for responding to fax requests (my personal physician will not respond to fax requests for my medications) although it can become burdensome.
If HR1406 requires written prescriptions for all medications, we will be forced to add a fee to cover the cost. We strive to be responsive to our clients and control their costs, and this would add an unnecessary charge and burden to us and to our clients.
When I do script out or call in medications, I am often questioned about medications or dosages by the human pharmacist. We have found changes to medications, doses and frequency of dosing by these pharmacists who are not trained in veterinary medicine. Yes, they are mammals, no a dog is not a person, a cat is not a dog, and a cat is not a person either. It is my training to know these differences and keep them safe.
Diversion of prescription medications is also an issue for us. Without exception manufacturers will not stand behind product that has been purchased and then diverted. It is a buyer beware society but this is a dirty little gray area that for the expediency of lower cost can endanger the health of the animals. If there is a problem, there is no recourse from the manufacturer.
Online Pharmacies - In my experience these range from excellent and dependable sources for less common medications and compounded medications to sources where we warn clients that too good to be true is indeed to good to be true. For the medications we use frequently we are usually able to set our price point at a competitive level. However, we have seen medications from online pharmacies that come with expired dates and unauthorized substitutions.
There is already a robust market place. Further regulation does not seem to be warranted. I am a doctor who serves a population whose care comes from the owner's discretionary income. We are very aware of cost issues for the owner and we have discussions of cost during nearly every office visit. Pet insurance is like car insurance. It is helpful in an emergency but not for ongoing care issues. I do not perceive a current barrier to a client's ability to select from a variety of sources for an animal's medications. We currently accommodate and in many cases encourage owners to use offerings such as the $4.00 specials from Walmart. It has been a long time since pharmaceuticals were a mainstay of our profitability.
Please reconsider legislating an area where the marketplace is working well.
Thank you, Melinda Cumming DVM