Submission Number: 560891-00597
Received: 10/11/2012 12:47:55 AM
Commenter: Dan Berbert
Organization: Gaithersburg Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
In regard to HR 1406, this would be an onerous and unnecessary piece of legislation. The vast majority of pet owners already are aware that there are catalogue and internet sites that offer pet medications. These sites are routinely advertised on television (with often misleading and false information, such as PetMed Express implying they are cheaper than all veterinarians...maybe their statements should be looked into if the consumer is really to be protected). Our office willingly writes prescriptions for clients who wish to purchase their product elsewhere, while informing them of our price. The added burden to write out a prescription for each and every medication may not seem like much, but with a full appointment book and some pets getting multiple medications in a given visit this will add easily 5 to 6 minutes per appointment, meaning that we either fall behind in our schedule or we make fewer appointments per day. To counter the loss of revenue if fewer appointments are able to be seen due to the increased length of these appointments, no doubt the cost of the office visit will rise negating any small savings made by purchasing medications elsewhere. The pharmacy is an important and necessary area of modest profit for most animal hospitals. If this is removed that profit must be made up elsewhere.
More importantly, for the health of the pet, it is unlikely the third party supplier of these medications will be able to answer questions about the very medications that they are dispensing as well as the veterinarian would be able to. Leave it that if a client requests a written prescription they should be able to get one without a hassle, but please do not mandate that everyone is required to get a written prescription for every medication whether they ask for it or not.
Dr. Dan Berbert