Submission Number: 560891-00558
Received: 9/27/2012 10:15:54 PM
Commenter: Linda Bloomfield
Organization: Livermore Veterinary Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
The evolving situation regarding pet medication is very complex. The most pressing concern that I see is the portability of prescriptions for clients. This issue is one that has no comparision in the human health field. As veterinarians, we are involved in treating many species, all of which have unique drug requirements. Human MD's are only dealing with one species. Human pharmacists are trained to deal with the drugs for that species. They are not trained to advise and understand how medications are used in all the species that we as veterinarians treat. If required to write rxs that will be filled at human pharmacies, there will be of necessity much more training required of those pharmacists. And a weekend course won't cover it. These pharmasists cannot make any changes without clarifying with the veterinarian. One potential side effect will be that much more time will need to be spent by the veterinarian on the phone with the pharmacist ensuring that the right medication is filled. This will need to be compensated for somehow, most likely by higher fees elsewhere in the practice.
Requiring veterinarians to write scripts for every medication, even if filled in house, is a recipe for disaster. The time involved in writing these prescriptions, ensuring that the human medication is appropriate, and in an appropriate dosing/strength is significant. It adds an extreme burden to the practitioner, which will impact their time for patient care. Again, this time will need to be compensated for somehow, and fewer patients will be able to receive care. The significance of this issue cannot be overstated. I firmly believe that the overall costs of veterinary care will increase as a result of these measures.
A parallel has been suggested between veterinary in house pharmacies and the issue of contact lenses that ophthalmologists had. I would suggest that the two issues are not similar at all. Again, we as veterinarians are dealing with more than one species. Also, medications are needed often in a much more timely fashion. While some medications are not time dependent, many more are.
Regulation of drug sources is another very real concern. If I, as a veterinarian are going to be held accountable for potential issues that may arise due to prescribing a medication, I want to know that that medication has been handled and stored properly. Safety and efficacy are essential. Currently, there is concern about the oversite of many of the online/internet sites. How will these safety concerns be addressed? How will they be monitored and regulated to ensure safety?
This issue is so much more complex than many seem to believe.