Submission Number: 560891-00332
Received: 9/11/2012 7:04:00 PM
Commenter: John Duncan
Organization: Apalachicola Bay Animal Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Hello, I am an associate veterinarian, licensed in Florida and Georgia.
I am writing to comment on HR1406 (2011), which to my knowledge would require a veterinarian to 1) write a prescription whether or not he/she will dispense the product; 2) provide a written disclosure notifying clients that they may fill prescriptions at the veterinary clinic or at an off-site pharmacy; and 3) verify a prescription electronically or by other means consistent with applicable State law.
I would like to point out about (1) that it is absurd to write prescriptions for products that have been dispensed in full. Most products dispensed are not to be refilled, but handing a client a prescription plus the dispensed product would confuse them. They may fill the prescription elsewhere despite having already purchased it. They then would not be using it as prescribed.
Additionally, veterinarians cannot be expected to know the inventory of a human pharmacy. Pharmacies often do not carry drugs in the strength we prescribe. By writing scripts in every instance, we would make it appear that the desired drug should be available. Compliance with our recommendations drops when such hurdles are presented to owners, and our customers get frustrated.
As to (2), A written disclosure would likely be ignored just like the HIPAA notices handed out at physicians' offices, but this requirement, if it were a one-time thing for each client, would probably not be onerous.
Finally, (3) is redundant with our code of ethics and, therefore, not verifying a prescription when requested is something that anyone can already complain about at the state level.
Please note that pharmacists are not currently required to attain any training in the pharmacology of drugs in veterinary patients. This legislation or regulation should not be passed or implemented before veterinary training is universal among pharmacists and veterinary continuing education is required.