Submission Number: 560891-00693
Received: 10/25/2012 7:21:28 PM
Commenter: Eric Clough
Organization: Burch Creek 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 oppose the "Fairness to Pet Owners Act" for several reasons.
First, the name of this Act purports that current pet owners are not being treated fairly by veterinarians. Given that large corporations with in-store pharmacies initiated this legislation, the more appropriate name should be "Your Veterinarian Can't Be Trusted and We Want More Pharmacy Revenue Act." I would like to see documentation from at least a handful of veterinary clients stating they weren't given the opportunity to shop elsewhere for medication. A doctor-client relationship involves trust and we as veterinarians cherish the perennial high esteem held by the public in our profession. We don't need the Federal Government casting doubt on our trustworthiness. There has never been an instance in my 20 years of practice when I denied a prescription request because it came from a legitimate outside pharmacy.
Secondly, this legislation is completely unnecessary. People are well aware that they can get their medications from human pharmacies, and on-line pharmacies through their own experience and extensive advertising. It should not incumbent upon veterinarians to supplement big corporations' advertising.
Thirdly, written prescriptions (or written anything for that matter) are a thing of the past and a needless waste of resources. When most responsible and progressive practices are trying to go paperless and "green," this act seems regressive. It would be disruptive to the efficiency of everyday practice for the doctor to have to delay subsequent exams to be writing individual prescriptions, especially when multiple drugs are needed. It is common practice these days for our technicians to use more modern modes of communication like the telephone or fax machine to give prescriptions to pharmacies.
Fourthly, I rarely write prescriptions anymore due to potential fraud, especially when controlled substances are prescribed. People can scan these, edit them on a home computer, and rewrite the prescription anyway they want. If my DEA number is on the prescription, then the fraudster can have up to a Class 2 controlled substance if he wishes.
Fifthly, there is enough governmental regulation not only in my industry, but industries throughout the United States. I concede that some regulation is necessary, such as licensing and monitoring performance, but excessive regulation (like this Act) impedes efficiency, increase costs, and cause unnecessary frustration.
I strongly urge you to disregard this needless regulation.