Submission Number: 560891-00368
Received: 9/12/2012 6:23:00 PM
Commenter: Michael Thomas
Organization: Teegarden Veterinary Clinic, PC
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I have been a practicing veterinarian for 38 years. I started out working as a mixed animal practioner (treating large and small animals). I currently work as a small animal practioner. It is my opinion that HR 1406, the Fairness to Pet Owners Act should be renamed the Unfairness to Pets Act. There are several reasons why I think this.
1. Owner compliance is a huge issue in treating any animal.
A. We make every effort in choosing the best medication in the easiest form to administer to each pet. For example, the antibiotic Doxycycline can be found in a tablet or a capsule formulation. Either formulation may be easier to administer depending on the individual pet and their owner.
B. Most all medications need to be started immediately. Owners may elect to fill the prescription at a pharmacy, but, are too busy to get to the pharmacy for several days to pick it up. We have had owners call our clinic to refill a prescription at our clinic and have failed to pick it up until called several days later and reminded.
2. As a veterinarian, I am aware that cost is a deciding issue in whether or not a pet will receive a needed medication in some cases. The selection of medication that is used in treating a pet may not only depend on what is the best medication, but, what the owner can afford. This may bring to mind the "good, better, best" options that we may see in retail stores. Our costs for different antibiotics, for instance, vary from one order to the next now more than ever in the past. One particular antibiotic may be more expensive than a different antibiotic on one order to supply our pharmacy, and less expensive on the next order. It is impossible to know what each pharmacy is currently charging for each antibiotic that may be an option in treating a particular pet. It would be very easy to write a prescription for an antibiotic, that may not be the "best" choice, but, perceived by us to be less expensive; but, in reality,it may be more expensive than the "best" at a particular pharmacy. The pet owner may take the prescription to a particular pharmacy, and, after finding out how much it will cost to fill the prescription, decide not to fill the prescription and all is hopeless. We will have no way of knowing this happened so that we could explore a more affordable option. In fact, this has actually happended to us.
I have listed some examples of why I think this bill is not in the best interest of the pet and the owner. Probably the summation of all of this can best be said that veterinary medicine has different and many more challenges than in human medicine. In my 38 years of practicing veterinary medicine, I have always put my patients first in the quality of care they receive and tayloring a treatment plan that their owners can afford. Writing a prescription for everything we prescribe would be an implication to our clients that we no longer want to serve their pharmacy needs, and, in many cases, lead to pets getting less than the best option or nothing at all.