Submission Number: 560891-00421
Received: 9/13/2012 5:44:35 PM
Commenter: Randy Carsch
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
My main concern is that "Pets will die". As a Veterinarian and Veterinary consultant, I am amazed how often clients receive medical advice from unreliable sources like the internet instead of licensed professionals.Unscrupulous, unaccredited or unlicensed online pharmacies could negatively affect animal health and welfare should the prescription be filled improperly or with an unsafe or ineffective product. The worse part would be when the pet is brought to the clinic because of the reaction to a toxin or impurity in the medication, the Veterinarian will not know what is the cause of the illness. Only when pets die across the nation will a link be established to the cause.
As Veterinarian, I am concerned a result of misinformation a mandate like HR 1406 can be used by a client to threaten/ pressure a veterinarian into issuing a prescription despite her / his bona fide veterinary medical judgment the animal is not in need of a legend, veterinary legend or controlled substance (or needs a non-drug treatment) because if she / he does not the client will file a complaint with the FTC asserting violation of the Federal Trade Commission Act; [see, e.g., Section 3, p. 3, line 22 to p. 4, line 6] This forces the veterinarian to choose between facing a federal investigation or breaking their own ethical code and state laws related to the standard of care. The Federal Trade Commission (FTC) is ill-suited and not equipped to know what is, or is not, the permissible practice of veterinary medicine or what a reasonable, ordinary and prudent veterinarian faced with a like circumstance would do.
Does the FTC plan to hire veterinarians to evaluate and investigate complaints?
In veterinary malpractice suits a veterinarian/expert witness is required to evaluate the actions of another practitioner.
Practitioners raise concerns about administrative burdens and the time it takes to provide a prescription, especially when it is not part of the office visit. In a typical practice, the average Veterinarian sees 15 clients per day or 22 patients. This would include all hospitalized patients (surgical,dental and ill pet's) 50% would need a prescription or 11 would need a prescription. If each RX take 1 minute to write and 10% resulted in calls from the 3rd party pharmacy to ask a question or see if a substitution is possible, than in one year, the average doctor would not be able to do patient care for 8 days due to writing prescriptions. That is a ridiculous amount of time to take away from what we as Veterinarians are trained to do and that is treat illness, prevent pain and keep pets well.
Dr. Randy P. Carsch