Submission Number: 560891-00312
Received: 9/11/2012 3:25:54 PM
Commenter: Sharon Hurley
Organization: Minnesota Veterinary Medical Association
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Federal Trade Commission
Office of the Secretary
Room H-113 (Annex X)
600 Pennsylvania Ave., NW
Washington, DC 20580
Re: Pet Medications Workshop, Project No. P12–1201
Dear Sir or Madam:
I am writing on behalf of the Minnesota Veterinary Medical Association (AVMA), established as a state veterinary association in 1897 to advance the profession of veterinary medicine in Minnesota. We are nearly 2000 members strong with the same mission to improve and advance the profession.
We understand that you have already received extensive comments from the American Veterinary Medical Association (AVMA) as well as other state associations. For the most part, we agree with the comments submitted by the AVMA as well as the other veterinary state associations that have submitted comments.
Briefly, the MVMA wishes to highlight and emphasize some of the points and concerns that we believe need careful consideration by the FTC and legislative leaders:
• The MVMA believes that HR1406 is unnecessary in that Minnesota and other states already have effective regulations, laws, and/or practice guidelines pertaining to veterinary prescriptions writing. It is our belief and ethic that when veterinarians are asked for a written prescription that it is provided to the client. Consequently, making written prescriptions mandatory for veterinarians appears unnecessary and burdensome.
• We also fail to see the need for new laws, regulations, and mandates that may be perceived to be aimed at creating a wedge between the client, patient and veterinarian.
• Through the long-standing Veterinary Client Patient Relationship (VCPR) practice standard, veterinarians have been able to work effectively, confidentially, and knowledgeably with clients and their animals in providing the best treatment as well as offering appropriate therapies for the health and wellbeing of the animal in a timely and, at times, life-saving manner.
• We believe that veterinarians are uniquely trained in veterinary medical pharmacology combined with ongoing medical and pharmacological education they receive from veterinary education institutions, veterinary medical associations, as well as veterinary pharmaceutical industries. This depth of knowledge of animal therapies acquired by veterinarians coupled with a commitment to follow-up animal care we believe is the best model for optimal animal care.
• The expansion of unscrupulous businesses and commercial entities, both physical and virtual, that market and sell animal medications is of concern to the veterinary community. We believe the concern primarily lies in the ability of some animal owners’ to ascertain pharmaceutical vendor and product quality and effectiveness, especially if they are prompted through these new regulations and mandates to enter into a foreign and unfamiliar marketplace with just a written prescription in hand. It would seem to us that a proven and safe marketplace for consumers and animal owners needs to exist before consideration is given to creating these new regulations and laws.
In summary, we fail to see a problem that warrants the type of solution being proposed through HR1406. Veterinarians have and will continue to provide the best care for their animal patients. This includes making sure that their patients receive appropriate therapies whether it be through the veterinary clinic or otherwise. It is also our belief that where concerns or issues have arisen in certain states, that they have been effectively addressed by those individual legislatures and/or state agencies.
Thank you for your consideration.
Sharon Hurley, DVM
Minnesota Veterinary Medical Association
101 Bridgepoint Way, Ste. 100
So. St. Paul, MN 55075