Submission Number: 560891-00527
Received: 9/19/2012 1:01:48 PM
Commenter: Austin Neely
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am a veterinarian who has practiced primarily small animal medicine for 5 years. I am against the passage of HR 1406 for the following reasons.
1) The bill is unnecessary and burdensome to veterinarians. Anyone who watches TV, goes on the internet, or reads magazines has already seen multiple advertisements for online pharmacies for many years now. Many local pharmacies in my area actively advertise that they carry pet medications. I already routinely prescribe many medications to local and chain pharmacies. Most of these prescription happen because I recommend that the client acquire those medications from an outside pharmacy, not because they requested it. Also, when I do prescribe medications to an outside pharmacy, I don't write prescriptions on a sheet of paper. They are usually submitted via fax or called in over the phone as written scripts are often misread and the human medical community is moving away from them in favor of other methods.
2) The primary goal of this bill is to force veterinarians to advertise for large chain pharmacies. If a pharmacy wishes to market that they carry presciption medication for animals they are more than able to do so. During the short amount of time that I have with a client to discuss their animal's health and needs, I should not have to use that time to write a prescription, talk about what pharmacies carry pet medications, and then offer the option to fill the medication here. Currently, if a client requests a medication be filled elsewhere we tell them yes and fax a prescription.
3) Most human pharmacists are not adequately trained to fill pet medications. While many of the medications we use are human generic products or equivalents, the dosages and frequencies used in the veterinary world differ greatly. I have dealt with many instances where the pharmacy either misread the prescription and prescribed an obviously wrong dose out of pure ignorance or a wrong prescription was given because a human pharmacist intentionally changed the prescription because that person assumed the written script was incorrect based on the normal dosage for an adult human. Another example of inadequate training would center on different side effects of medication. In the human medical world, I have known people with severe arthritic diseases that were treated with a combination of steroids and NSAID's. Every vet student is taught in school that it is malpractice to prescribe these medications together to animals.
4) Ultimately, the likely result of this bill's passage would be to further hurt small businesses and drive up the overall cost of veterinary healthcare for consumers. Even before this bill was introduced veterinary clinics have had to deal with the loss of income from outside pharmacies. There is obviously nothing wrong with this, but the end result is that as income from pharmaceutical products diminishes the cost of services (examinations, vaccines, surgeries, etc.) increases to make up for the loss. Ultimately pet owners pay more at their visits while veterinary clinics receive less income. The only group that profits from this is large businesses such as Walmart.
In summary I feel that this bill is unnecessary. It is currently being championed by groups such as Walmart as a means to strong-arm veterinarians into sending prescriptions to them to increase their pharmaceutical sales. If they wish to sell pet medications that is their right, but it is not the responsibility of veterinarians to advertise for them nor is it useful for congress to have its time wasted by large corportations attempting to legislate more business for their themselves. If you have any questions please feel free to contact me.
Austin Neely, DVM