Submission Number: 560891-00330
Received: 9/12/2012 9:47:40 AM
Commenter: James Davis
Organization: Georgia Poultry Lab
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
TO WHOM IT MAY CONCERN:
I think the new regulations proposed on prescription-writing in Veterinary Practice are both unfair and ridiculous. MD's are not required to do this and Veterinarians should not be either. For decades Veterianarians have stocked prescription drugs in order to serve their clients' needs...and serve them in an immediate way. The clients can purchase the medications needed there, without the inconvenience of having to go to a Pharmacy. If the client asks for a prescription, so that it may be filled at a Pharmacy, that is fine. But, Veterinarians should not be required to do this by the Government.
Having to inform each client of these options and having to electronically verify each prescription is ridiculous. These are ANIMALS we are talking about, not humans. Additionally, most pet owners do not carry health insurance on their pets that require electronic filing of prescriptions to their insurance company for payment (as with human prescriptions).
PLEASE re-consider your stand on this and do not pass this law in its current form.
If you want to do something much more useful to Veterinary clients, you should pass a price-regulation bill, requiring Veterinary Practioners a limit on how much they can mark-up the price on medications. This will be much more beneficial to pet owners, because Veterinary Practioners often mark-up the price on medications to an extremely high level in order to help pay their overhead. This practice should be regulated...not the actual writing and informing procedures that are outlined in this proposed bill.
James F. Davis, D.V.M., MS.
Diplomate, American College of Poultry Veterinarians
(Former Small Animal Practioner for 11 years; licensed in Alabama, Florida, & Georgia)