Submission Number: 560891-00448
Received: 9/14/2012 3:43:46 AM
Commenter: Keith Norberg
Organization: Danada Veterinary Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am an associate veterinarian in a very busy 7 doctor practice, where we strive to provide our clients with the best quality medicine and value for their money. It is my opinion that HR1406 hinders our clients from obtaining this value and places unnecessary burdens and potential liability on veterinarians, while placing veterinary medications in the hand of unqualified individuals.
Value to our clients is not simply monetary. It is also measured by the time we dedicate to them and to their pet's needs. This is the reason that consumer satisfaction in veterinary medicine is consistently higher than our human medicine counterparts. We typically have 20-40 minutes per appointment to perform a complete physical exam, take a thorough history, run diagnostics, provide treatments, and educate our owners.
In comparison, my human MD has an RN take vitals and history. He spends 5 minutes of his own time with me while only performing a partial physical. He sends me to a lab for diagnostics, and either writes me script or sends me to a hospital for treatments. It takes him a week to do what I am expected to do in less than an hour. Of course my MD also has the benefit of insurance subsidies that allow him to charge inflated costs for his services, and therefore allow him to afford all of his support staff while carrying an average 30% profit margin.
In veterinary medicine, our support staff is completely dependent on the profits of the hospital. As HR 1406 adds to our appointment demands with redundancies and unnecessary paper work, we will need additional assistance to perform the duties already required of us. However, our ability to maintain our support staff will be hindered by the lost profits that result from HR1406's intentional redirecting of clients away from in-house pharmaceuticals. Most veterinary hospitals only operate on an approximate 10% profit margin. Approximately 25-33% of our income comes from medication/food sales. As more medication is out-sourced,profits will suffer, hiring of support staff will be hindered, and quality of services would be diluted, leading to a precipitous decline of the industry as a whole.
Secondly, HR1406 places veterinary pharmaceuticals in the hands of professionals with no veterinary training, yet does not release veterinarians from liability in the event that these pharmacies error. Veterinarians are the ONLY medical professionals trained in the use of veterinary medications. We uniquely understand drug interactions, side effects, and contraindications as they relate to species-specific drug use.
As medications become more readily available through non-veterinary sources, consumers will turn to these unqualified advisers for medication related questions. We all ask our pharmacists about side-effects and interactions of our own medications. It is only natural that consumers will ask them similar questions about their pet prescriptions. However, pharmacists are deficient in their training on these matters, and may offer erroneous advice. HR1406 fails to hold pharmacists to any standards regarding pharmaceutical advice and fails to protect veterinarians in the event that such advice results in complications.
In closing, HR1406 could result in dangerous repercussions to consumers and to the industry of veterinary medicine as a whole. As it stands, most veterinarians freely offer scripts to clients that request them, and anyone with a TV or a magazine subscription has knowledge that pet medications are available off-site. (1800 Pet Meds, etc.) HR1406 simply adds to the administrative duties of already busy veterinarians, while essentially pushing clients toward unqualified and/or unsafe sources for their medications. It is essentially the equivalent of forcing an accountant to write his client a note stating they can get tax advice from the car salesman down the street because it might be cheaper (regardless of how poorly qualified the salesman is).