Submission Number: 560891-00377
Received: 9/12/2012 11:55:01 PM
Commenter: Ruth Etherton
Organization: Green Trails Animal Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
“Pet Medications Workshop, Project No. P12-1201”
I have grave concerns over the proposed bill H.R. 1406, the Fairness to Pet Owners Act. While this bill would seem to help pet owners have access to the lowest prices for their pets' medications, there are many problems that will arise. My biggest concern is for the safety and well-being of the animals. If veterinarians are required to write prescriptions for every animal that requires medication, there would be less time for patient care. I am blessed to practice where we have 30 minute appointments, but I still find that properly examining my patients and educating my clients takes the full time (in addition to any treatments or lab work that needs to be done). Many of my patients have conditions that need medication started immediately. They should not wait and cause unnecessary discomfort or even worsening of their pet's condition due to the delay. They also need to have a trained individual explain not only what the medication is for, but potential side effects, and also how to properly administer that medication to that individual patient, be it bird, reptile, dog, cat, etc. Sometimes this involves modifying the medication by cutting it into small fragments or compounding it into small doses that are palatable and tolerated by the patient.
In addition, I have concerns that human pharmacists will be unable to properly educate the clients since they do not understand the differences between humans and animal species. They also do not have the time to properly train themselves or the clients when their corporate employers require them to fill hundreds of prescriptions per day to maintain their profit margin, in addition to giving vaccines, etc. These clients will then return to me and expect me or my staff to give them this information for free. I will not have to time or resources to do this. Not only does this bill require me to take precious time to write out prescriptions (which some patients may have 2 or more), I will then be expected to take my time for free to explain what the pharmacist will not be able to do. This in turn will force service fees to go up to compensate me for my time. Fees will have to go up also to compensate for the loss of income, in many practices up to 30% of their income is from prescriptions. If this is lost, then service fees will have to go up, or else the practice will fail financially.
I understand that this bill was proposed to help save money for the consumer and provide them with the opportunity to shop around for the best price, but this is not what is always best for the pet. I have no problem writing a prescription when requested, but being required to write one for every medication will be detrimental to patient care and ultimately increase costs for the client.