Submission Number: 560891-00513
Received: 9/14/2012 11:07:14 PM
Commenter: Kelly DeBaene
Organization: Elmhurst Animal Care Center
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Thank you for inviting the veterinary community and the public to voice their opinions and concerns over this matter. My colleagues and I believe passing H.R. 1406 would harm the welfare of our community’s pets in the short term as well as be detrimental to pet owner’s pocketbooks in the long term.
Most veterinary practices have a protocol for writing out, faxing or calling in prescriptions to outside pharmacies at a client’s request or on the rare occasion the medication is not stocked at the clinic. Prescribing a medication and filling it in house is both valuable and convenient to the owner as veterinarians are formally trained in animal pharmacology in school while vet technicians and assistants are, at least, very familiar with common drugs, dosages, side effects and other concerns. Not in an effort to belittle the knowledge and training of pharmacologists, but they simply do not have the formal training in animal medicine, physiology, and pharmacology. To superficially explain the idea behind this concern, consider this: a Border Collie is not a Boxer, and a English Bulldog is certainly not a Siamese cat! Not all pets are created equal and not all human drugs can and should be filled for pets.
What are the reasons for restricting a veterinary practice from requiring liability waivers to be signed by clients asking to have meds filled elsewhere? It is at least a simple reminder to a pet owner that, as veterinarians, we recommend our trusted medical supply companies to fill your pet’s medications and not the online pharmacies in which the production background of such medical products remain mysterious.
Enforcing the requirement of writing out every prescription for every client/pet would not only be monotonous but it would be an immense waste of an animal clinic’s (i.e. small business) manpower and resources. The time spent writing out extra Rx forms and filing such documents could be better spent in the form of client education on preventive care or disease management. This written requirement in the end would cost more for the clinic and of course, ultimately cost more for the owner (who often are already having difficulty paying for bills beyond basic care). What next? Will the CVS Minute Clinic nurse practitioners be administering rabies vaccines to dogs? Please consider the far-reaching implications of this proposed bill.