Submission Number: 560891-00400
Received: 9/13/2012 12:52:14 PM
Commenter: Kimberly Maun
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a practicing veterinarian, I am very concerned about the proposed changes in veterinary prescribing legislation. Currently, the majority of veterinary prescriptions are filled on-site from the practices' pharmacies. When applicable, veterinarians do write scripts or call prescriptions in to be filled at outside pharmacies. Veterinarians are the only medical professionals who know the particulars of dosage, safety, and availablity of various medications for animals. Human physicians, nurses, and pharmacists do NOT have this knowledge, nor, certainly, do our clients. Therefore, for the safety of our patients, dispensing veterinary pharmaceuticals is best left in the hands of the veterinarian.
Furthermore, I would estimate that about 70% of veterinary patient visits in a small animal general practice result in the prescription or refill of medication. Requiring a written prescription for every drug prescribed, even if it will be filled on-site is a ridiculous misuse of a doctor's time. It may sound minor, but in the context of a busy practice setting, the time taken to write a script and explain why we are doing so to a client will leave us lacking for time to discuss critical medical information, such as adverse drug reactions or dosing instructions. When clients DO choose to pick up medications at a pharmacy, I am concerned they will not receive that critical information. Pharmacists do NOT have the knowledge of non-human animal drugs, drug interactions, or dosage variations. This compromises the health and safety of our patients.
I also have concerns that the proposed legislation will encourage people to seek prescriptions from online sources. The limited oversight of these sources has proven to be a serious concern in recent years. Once again, veterinarians are simply fighting for control over our patients' medications as a safety issue.
Perhaps the biggest concern is that relegating our patients' medications to an outside source tends to result in a general "loosening" of the control we have as doctors over prescription refills. This means patients can "fall through the cracks" of medical care. Clients could more easily obtain prescription refills without having to talk to a doctor, leading to inappropriate medical care or follow-up, and, of utmost concern, inappropriate use of antimicrobials.
The misuse and overuse of antibiotics in human and veterinary medicine has become issue of major concern in this decade. The emergence of antibiotic-resistant bacterial infections is perhaps one of the most threatening issues in human medicine today. Anything that reduces the medical oversight veterinarians have will contribute to this problem. So you see, this is not just a safety concern for veterinary patients, but for the human population as well.