Submission Number: 560891-00407
Received: 9/13/2012 1:50:13 PM
Commenter: Amy Cousino
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Regarding HR 1406. The requirement to give all clients a written
prescription will put a great burden on small animal veterinarians.
It takes time to write a prescription, more time to explain it to the
client, and it will be costly to the veterinarian, as the small profit from dispensing that medication will be lost. And it will be lost to big corporate pharmacies, human pharmacies among them, and faceless internet pharmacies that just will not back up their medications. Veterinary practices are for-profit, and are some of the most highly regarded professional practices now in existence.
As an experienced veterinarian with over three decades of practice, I have some additional comments. I would say that over 80 percent of the medications I now dispense for my patients are sourced, purchased, and evaluated clinically over many years, for their efficacy (does the drug work?), ease of administration (is the medication in a size or form that is easy to administer to a kitten of 2 lbs, a cat of 9 lbs, or a dog of 60 lbs?), and flavor (dogs and cats have much better sense of smell and tast).
For instance, I dispense an antibiotic for cats that I buy from a small animal specialty pharmacy, and it is in a very tiny 50 mg tablet. The medication also comes in a very large tablet that has 500mg of the drug and is so large that a cat could not swallow it at all. It is formulated for humans so it is not appropriate for a cat.
Could a client save money by buying the 500 mg tablet-yes, but it is impossible to give to their cat. Just to break it into 10 even pieces would not be enough, as any one piece could contain more or less than the required 50mg. As the cat's vet I have devoted my practice to finding just the right medications for cats. A pharmacist at a corporate pharmacy does not know what I do, and is supremely unqualified to choose a medication for a cat. They should stick with people only, because that is what they are trained in.
Recently a client told me that she took a prescription for insulin to a Walgreens pharmacy. She asked for a cheaper insulin and the pharmacist recommended one for her cat. My client hesitated to take the recommendation. Later that week she told me her experience. I told her that if she had given her cat the pharmacists "recommended" substitution for insulin, that her cat could have died. It was the wrong insulin for a cat. My clinical experience with thousands of cats just like hers gives me the professional expertise needed to prescribe just the right insulin for her cat. I was appalled that a Walgreens pharmacist did this. They just don't care, and don't have the professional qualifications or expertise to do this. And I believe it might even be illegal what they did. My prescription as written should have been followed with no question from the pharmacist. The no substitution box was checked (which prevents substituting a generic drug), but where was the protection from an unscrupulous pharmacist "box?" Veterinarians are one of the most if not the most trusted professionals in the United States. Why would you even think that this bill would benefit animals? Most certainly it won't. In fact it would hurt the animals, and in the name of "saving consumers money." Animals suffer enough, don't make them suffer more with this unneeded and destructive bill. If pharmacists want to be veterinarians, let them go to veterinary college to become one. Don't let them or big corporations like Walgreens push this bill through, it is such a bald-faced lie to say that they want to help consumers, all they want is to take the medication dispensing business out of the hands of caring professional veterinarians, just so they can make a bigger profit. It is just not right. Vote NO.