Submission Number: 560891-00480
Received: 9/14/2012 1:49:10 PM
Commenter: Millie Armstrong
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am experiencing a large number of clients purchasing their pets' preventative medications (heartworm and fleas/ticks) at an online pharmacy or a local non-veterinary merchant. I am also spending more time discussing side effects and dosing problems with these folks. They are not getting guidance before purchasing these products and are often getting into trouble with ineffective medication, dosage overdoses, or product used on the wrong species of animal! In this latter case, very serious complications can develop Products that should be beneficial to animals are now becoming a threat to their health. Unsuspecting owners thought they were saving money, but when they realize they have just endangered their pets, they feel horrible. The manufacturers of these products will not support products that are not purchased from licensed veterinarians, so the owners have no technical support to call for help or financial recourse if problems develop. Consumers and patients are upset by this disservice and veterinarians spend a great deal of time handling complaints and complications. This is valuable time taken away from preventing and treating medical and surgical cases.
Time spent in the veterinary practice reviewing prescription requests, authorizing the request, submitting the request, and resubmitting the request when the online pharmacy has “lost the paperwork,’ detracts from patient care.
Current television and online advertising often implies a veterinarian is not needed to obtain medications. This diminishes the value of veterinary medicine and proposes veterinarians are an enemy in the mission for pet health care. This could not be further from the truth; we are the best trained advocates for the health and safety of our patients.
Veterinarians should not be denied the ability to charge a fee or to require a waiver of liability for providing a written prescription to clients. Writing prescriptions require subsequent follow-up work, including phone calls with pharmacists, that take time and it is not unreasonable to charge a fee for that time. The decision to require a waiver should be left to the judgment of the clinic owner and not be dictated by federal law.
There are potential risks associated with portability of prescriptions to retailers external to the veterinary clinic. One risk is a result of the lack of formalized veterinary medical pharmacology training requirements for pharmacists. A second is the potential for delay in treatment should the preferred pharmacy not carry the needed medication or if the client is delayed in picking up the drug from the preferred pharmacy.