Submission Number: 560891-00307
Received: 9/11/2012 2:33:39 PM
Commenter: Patricia Burke
State: Rhode Island
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
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The American Veterinary Medical Association (AVMA)’s code of ethics and public stance has long encouraged veterinarians to ‘write a prescription” when requested.
MY ACCEPTANCE OF BEING WILLING TO PRESCRIBE DOES NOT MEAN I SUPPORT HR 1406 – A TERRIBLE (AND THERE IS NO BETTER WORD –) STUPID BILL, WRITTEN BY SOMEONE WITH NO CONSULTATION WITH A MEDICAL PROFESSIONAL (and I imagine under duress from a constitent) WITH INDEFENSIBLE RIDICULOUS REGULATIONS .
(A) “ whether or not requested by the pet owner, provide to the pet owner a copy of the veterinary prescription and a written disclosure that the pet owner may fill the prescription through the prescriber (if available), or through another pharmacy determined by the pet owner; “ Even if we get past the inanity of writting a RX, then selling the med, and then attepting to grab back the RX - very likely many cleints will get the med at the DVMS and then still have a RX - i.e. double dip to sell, or in the case of controlled drugs, abuse.... That is one reason I am concerned about this law’s emphasis on “written” prescriptions. When I queried the RI Board of Pharmacy , several years ago, I was told being willing to prescribe a drug, does not require giving the client a written script. I would hope any bill passed would have language which allows - EITHER - electronically transmitted prescribing- which is preferred in human medicine, OR a written prescription.
C. Not giving a written prescription, prevents client from filling the RX from illegal, unreputable sources , from double dipping, and -I do not have paper floating around which has my RI license and my DEA number on it. I don’t have to order tamper-proof prescription forms to prevent prescriptions being copied and used fraudulently. This also prevents a prescription being filled –maybe innocently, but illegally--, by another animal hospital. Instead I respond to faxes and or call in Rxs.I find this faster, easier for both the client & myself, errors are reduced. I do not have to make a copy of the RX to file, and I can confirm its being filled by a licensed pharmacy. In addition, I do agree with RIVMA and AVMA’s concerns of the economic impact of the onerous client notification requirements, and the timing of, and emphasis on providing, written prescriptions.
---Client notification of the option of buying the medication elsewhere should come first and could be covered by requiring posted signage “You can request that medications be dispensed thru or by licensed pharmacies in lieu of purchasing here”. Posted signs are good enough to inform about HIPPA in human hospitals, workplace safety, No Smoking and Emergency Exits, etc.
(B) May require payment of fees for an examination and evaluation before providing a veterinary prescription, but only if the prescriber requires immediate payment in the case of an examination that reveals no requirement for an animal drug.
The last part makes no sense ---Veterinarians can only charge for an examination that reveals the patient DOESN’T need an “animal “drug. Meaning-- we cannot charge for examination if they do need an “animal” drug -- i.e. a prescription drug? Veterinarians, as physicians, can legally only prescribe when there is a “current doctor / patient relationship “ and the need is supported by physical, laboratory, radiographic, surgical evidence- which of course we should be able to charge for ! The bill’s definition of “animal drug” is a drug to be used in an animal. Why not just say prescription drugs? That covers drugs only a licensed veterinarian can dispense or prescribe, as well as “human drugs” all of which (with DEA license for controlled drugs) a veterinarian can dispense or prescribe to their patients