Submission Number: 560891-00385
Received: 9/13/2012 10:19:36 AM
Commenter: Mary Benz
Organization: Randall Oaks Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I believe HR1406 is redundant and will cause undue regulatory and administrative burdens on veterinary practices. It is burdensome and unnecessary to require a written prescription be provided, as well as a written notification that the prescription may be filled elsewhere, regardless of whether or not the client is having the prescription filled by the veterinarian.
? The provision requiring verification of prescriptions, regardless of whether the pharmacy is accredited or licensed, places the veterinarian in both a legal and ethical dilemma. At the same time, it puts consumers at risk.
? HR1406 encroaches on state jurisdiction; state pharmacy and veterinary practice laws already given compliance by veterinarians.
? Clients already have the flexibility to fill a prescription at their veterinary clinic or off-site at a pharmacy of their choice. I am supportive of a client’s right to choose where they have their prescription filled.
? I believe that veterinarians are uniquely trained to provide the best professional guidance and education to pet owners when dispensing prescription products.