Submission Number: 560891-00387
Received: 9/12/2012 5:07:00 PM
Commenter: Mary Beth Leininger, DVM
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Regarding Pet Medications Workshop, Project No. P12-1201 I am writing to express my opposition to HB 1406. As a licensed veterinarian for 45 years, and an owner of a private veterinary practice for 30+ years who has cared for thousands of pets, I believe this well-intentioned legislation is both unnecessary and redundant, and may even be unsafe.
It is redundant because State Boards of Pharmacy and Veterinary Medicine already govern prescription writing for health professions; this legislation encroaches on state jurisdiction.
It is unnecessary because the American Veterinary Medical Association (the veterinary profession’s national umbrella organization) has a longstanding policy encouraging veterinarians to write a prescription in lieu of dispensing a pet medication whenever a client so requests. In addition, the AVMA Principles of Veterinary Medical Ethics provides the guideline that “veterinarians should honor a client’s request for a prescription in lieu of dispensing.”
This legislation may be unsafe for pets (the issue which is of primary concern for veterinary practitioners) because it does not address the need for multi-species pharmacologic training by the non-veterinary “pharmacist” filling these prescriptions.
If the intent of this legislation is to truly make pet medications available to pet owners at a modest cost, I feel that my practice experience shows how truly unnecessary it is. In my practice, we regularly wrote prescriptions for pet owners when a pet/patient needed medication that we did not regularly stock, or for human medications that were available at substantially less cost at our neighborhood pharmacy. Of course, we did not charge a prescription fee to the client. Any medication we dispensed was priced at a modest mark-up over our cost (often 25%-35%) plus a $2.50 dispensing fee.