Submission Number: 560891-00660
Received: 10/20/2012 4:35:46 PM
Commenter: Steve Coffin
Organization: Interbay Veterinary Care Center
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
My practice has lowered mark-ups and prices on some medications (flea, heart worm, allergy, etc), but kept other mark-ups at what we consider to be fair, and we fight to keep those prescriptions in-house even if we know them to be more expensive than outside sources. It isn’t so we can gouge our clients, but because it is the business model we know.
Rightly or wrongly, pharmacy sales have always been a significant portion of veterinary hospital revenue. These sales are integral parts of the typical hospital business model - they don't add excess revenue, but rather are a part of a balance that allows us to remain competitive and still pay our bills. To contend with the revenue reductions, hospitals will be forced to raise their remaining fees - we have already experienced this necessity in my practice. And to cover the increased liabilities that result from the treatment of patients we no longer see as often, hospitals will be forced to require increased exam frequency and additional diagnostic test evaluations. These changes will increase the cost of veterinary care, not decrease it.
Secondly, while some people will see lower prescription fees, others will pay substantially more. If and when the law requires veterinarians to provide clients with prescriptions that can be filled elsewhere, in-hospital drug sales will decline significantly. As such, and because all drugs have shelf lives, are typically not returnable when expired, and are often distributed in multi-packs, the cost of medications sold through veterinary hospitals will likely become much higher to cover reduced sales and increased loss.
Additionally, medications that are not used for the care of hospitalized patients may no longer be carried by the hospital, resulting in inconvenience to some clients who would prefer to purchase them there, and level-of-care concerns for patients whose owners don't promptly fill their written prescriptions and initiate treatment (for example: many clients are willing to wait for on-line pharmacy deliveries of antibiotics, heart worm medications, etc, which could be devastating for the patient).
Lastly, veterinary medicine is not a high-profit endeavor. While there are those that are comfortable, typically practice-owning veterinarians (ie; some of the “small business owners” that are currently of such great concern), very few technicians, or assistants earn a living wage in spite of the fact that pet owners increasingly expect these people to be knowledgable enough to provide the services they need and to treat their pets when they become sick. Losing pharmacy income will put additional financial pressure on veterinary hospitals to find and keep good employees, which may have the effect of actually lowering the level of care provided to our patients.
Although there are many reasons why the current legislation and discussion should not become law, I personally believe that most veterinary practices will actually be much healthier, fiscally, when outside drug sales (effectively the result of current legislation) are mandated. Rather than allow the market to change age-old behavior in a slow and methodical manner, a forced change will allow the entire veterinary profession to adjust at once. There will be significantly less concern about restructuring non-pharmacy fees as we will all have to do it at once, and with luck the veterinary hospital business model will become much healthier than it is today. In my practice we welcome the change.