Submission Number: 560891-00343
Received: 9/12/2012 1:05:13 PM
Commenter: Michael McLaughlin
Organization: Panther Park Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Modifications of the pet medications supply protocols such as suggested in HR1406 (The so-called Fairness to Pet Owners Act) are completely unnecessary and an onerous burden on the practicing veterinarian.
No pet owner who ever requested a written prescription from me has ever been denied for a legitimate medication. To force the vet to write a free prescription for every single medication to be dispensed to every single pet (even when the owner specifically declines the prescription) puts an extreme and unfair burden on the veterinarian's time and expertise. It is illegal to have "pre-written" prescription forms at our practice and each prescription takes several minutes of doctor time in their preparation and staff time in maintaining the necessary document records. A dog that needed heartworm preventive medication, flea treatment medication, and perhaps another medication (or two) for an ear infection would require 3 or 4 separate prescriptions and at least 15 minutes of my time. That time lost could be spent seeing one more patient. Those expenses and losses would have to be shifted to the client in one way or another and result in higher (not lower) health care costs for the pet owner. The only one to benefit from such an arrangement would be the pharmacy at the big box stores and pharmacy chains who let me do all the work, all the research, and all the decision making, while they collect unearned fees.
Many of our most commonly used medications are already priced everyday lower than the regular online pharmacies prices. Each size of our heartworm preventive medications is $5-$10 less than the regular price published at PetMeds (for example).
Changes to the existing system are burdensome and unnecessary and will result in higher overall costs to the pet owner.