Submission Number: 560891-00441
Received: 9/13/2012 11:43:45 PM
Commenter: Scott Anderson
Organization: Association for Veterinary Clinic Success
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I have been involved in veterinary practice management for over twenty-five years. During that time I've witnessed veterinarians and practice personnel working diligently to assist their clients in providing the care that a client's pet deserves. This is often difficult, both for the client and the practitioner. While the cost veterinary care can at times be an impediment to providing all of the care an animal might need, offering medications through a licensed veterinary practice contributes to better care for a patient, and a portion of the small margins on which veterinary practices survive.
Veterinary practices currently script out selected medications, when a viable product is available elsewhere. In regard to patient care, our experience indicates that a client is less diligent in following a medication protocol when a veterinarian and veterinary practice are not involved through each step in the process, including the dispensing of medications.
As in human medicine, veterinary computer systems are capable of producing a variety of information for clients to take with them when medications are dispensed. Along with this is the coaching by veterinarians and registered veterinary technicians to help a client understand the purpose of the medication, anticipated outcomes, and the potential signs of a negative reaction to the medication in an animal. Unlike with humans, signs that a medication is not producing the desired result, or if there is a negative reaction, can be very subtle in animals. By breaking the bond with a veterinarian, through distributing the treatment of an animal, the welfare of the animal is likely to suffer.
As I mentioned earlier, veterinary practices work on very low margins, even though veterinarians and veterinary staff earn less than their counterparts in other professions. Diluting veterinary practice income in any way would have a very detrimental impact on practices throughout the county, and especially for smaller practices.
The principals of our association have consulted with small to large practices throughout the United States. It's our opinion that veterinary practices are not overcharging for medications, especially when you consider that the price charged for a medication includes using the diagnosis of a problem to determine the appropriate medication to address the species, breed, and the characteristics of an individual animal when prescribing a medication to address a medical problem.
My personal fears are two:
1) Excessive "outsourcing" of medication fulfillment might result in inappropriate products or instructions being given to a veterinary client, and I worry about it breaking the link with veterinarians who need to be involved in ongoing patient care.
2) I worry about the state of veterinary business. The dispensing of medications is important to veterinary medicine in that income derived from it helps to support overall patient care. Some veterinary practices will have difficulty in conforming with proposed legislation, and I believe that it will force several of these small businesses out of business. Adjusting fees for services other than medications might help to provide business survival income, but such actions are likely to cause pet owners to defer needed care for their pets.
In closing, the sale of medications is an important element in the care of veterinary patients. The sale of these products cannot be isolated from other elements in patient care, both for the benefit of the patient, client, and the veterinary practice. I believe that consumers are protected through the efforts of various associations, such as AVMA, and governmental agencies. In regard to competition, veterinary businesses are very aware of competition, and they provide a balanced approach in the sale of services and products to insure the care of their patients and the survival of their businesses.
For information about our association, please visit AVCSuccess.com