Submission Number: 560891-00662
Received: 10/20/2012 5:36:42 PM
Commenter: John DeVries
Organization: DeVries Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I own a 2 doctor small animal practice in suburban Chicago area and have been in practice since 1984. The proposed legislation would adversely affect my practice in many ways. My pharmacy generates profits which helps me keep prices more affordable on other procedures. I would not say that it should be this way, but historically this is true in most veterinary clinics. Clients appreciate the convenience of getting their pet's medications at the same time as their visit. However, the current consumer is very savvy and is well aware of online pharmacies, alternative places to purchase their pet's medications, and don't hesitate to ask for a written ("portable") prescription. I gladly provide them with one, although it slows the whole process of checking them out as I manually write out a prescription. We do not have the luxury of sending electronic prescriptions nor printing one on a printer. Having to provide a written prescription for every patient would be onerous, time consuming, and reduce my efficiency and ability to produce enough income to cover a service which is both unnecessary and a waste of my time.
Of greater concern is the current state of online pharmacies- their seemingly flagrant violations of dispensing standards and willingness to accept fines when caught as merely a cost of doing business are truly frightening. Until the regulatory agencies in charge of these pharmacies are given the resources, funding, and authority to pursue violations, I have a real concern for the retailer's ability to safely and accurately dispense medications. The notion that violations of dispensing laws for pets are minor, because, after all, "it's only an animal" that might be affected adversely, is ludicrous, but very real. Dispensing pharmacies know that, in case of fatal errors, they will only be held responsible for the replacement value of an animal, as animals are considered personal property in most states, fueling their irresponsible behavior in filling prescriptions. Currently the bulk of prescriptions being filled by retailers are heartworm and flea and tick products, which provide for a large margin of error if mistakenly dispensed. If, however, drugs with a lesser margin of safety start being routinely dispensed, how many animal deaths will need to happen before retailers clean up their act? Further, if I am unable to require waivers of liability for how prescriptions are filled, what protection is provided me when a retailer makes mistakes in filling a prescription? I, for one, continue to ONLY provide written prescriptions, do not authorize ANY refills or prescriptions over the phone in an effort to provide a clear paper trail should there be an error in a prescription.
In conclusion, the proposed legislation (House Bill 1406) is both onerous for the veterinary practitioner and unnecessary. Further, it does nothing to address the very real concerns about improving the safety, accuracy and performance of what is now a substandard retailer's industry for filling prescriptions.