Submission Number: 560891-00506
Received: 9/14/2012 6:17:00 PM
Commenter: Jeff Claborn
Organization: Twin Rivers Vet Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I own a 2-doctor mixed – animal Veterinary practice in a town of 21,000 people. Our clientele base is 50% pets and 50% livestock. I am against H.R. 1406 as this bill is unnecessary, unfair and attempts to place non-veterinary trained individuals in a position to provide Veterinary guidance.
This bill is unnecessary as more than 95% of my clients already know that they can obtain a portable pet prescription from our clinic. I have written Veterinary prescriptions to Pet-Med Express, Wal-Mart, Walgreen’s, and other on-line / catalog companies. I have never refused nor charged for a prescription. My office manager has called clients when faxed prescriptions from Pet-Med Express have been sent. She then informs the client of our price. Most of the time our clients tell her they saw the multiple commercials and assumed our medications were much higher in price. If the client still desires a prescription, the conversation is over and the prescription is written. Veterinary clinics have unjustly been shed in a negative light thru this company’s massive commercial campaign that Veterinarians charge twice as much for the same product. Overall our clinic prices are in-line with Pet-Med and many times we are actually cheaper.
This bill is unfair due to the increased time and expense to comply with measures that are redundant. I would be forced to hand-write prescriptions with every patient along with daily checking of Fax and E-mail transmissions for return correspondence. As emergencies occur at the clinic or in the country, time would be lost in serving immediate needs as I am hand-writing prescriptions and discussing purchase options that most of my clients already know from on-line, T.V. and print advertisements they have been exposed to for years. Prescriptions are currently fast and accurate at the clinic without the paper overload. Veterinary Technicians process the prescriptions on our main computer. I do not have this computer connected to the internet to eliminate the risk of viral attack or unauthorized access to medical records.
H.R. 1460 places pharmacists trained in human medicine in an authoritative position to answer client questions regarding pet medications. Veterinarians are uniquely qualified thru training and knowledge in the nuances associated with animals that only communicate in actions and behavior. Only Veterinarians can fully explain to clients’ administration techniques, side-effects and expected results and answer questions as they develop. Clients will turn to Pharmacist with initial questions and receive inaccurate or incomplete information which may further complicate the outcome for a successful treatment.
H.R.1460 in my practice could even affect the cost of Veterinary services charged to our clients. If passed, the unfounded negative advertisements that we endure, implying that owners are being over-charged thru the clinic may escalate. One fear is that some people will take multiple ads as gospel. Large corporate advertising coffers will decrease sales unjustifiable. If this occurs, I will need to raise prices for services which would increase the clients overall cost of Veterinary care or necessary services may be declined at a cost to the animal’s well-being. Price competition is already in effect. The same profit on medication sales will go to mega corporations, yet Veterinary services will need to rise to keep the small business alive.
I am against H.R. 1600, Fairness to Pet Owners Act. Price competition already exists in the pet medication market. Prescriptions are being written for out-of –clinic purchases. Veterinarians are most capable of providing accurate pet medication usage. Increased cost of veterinary medical and surgical services can result without a compensatory change in prescription drug cost for the consumer. This bill would not be in the best interest of pets and owners.