Submission Number: 560891-00744
Received: 11/1/2012 5:53:19 PM
Commenter: Carl Johnson
Organization: self employed veterinarian
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Dear FTC Members,
I am a self-employed veterinarian who owns a Veterinary practice in Pekin,Illinois and I write to you at the Pet Medications Workshop Project P12-1201 in opposition to the proposed law,"Fairness to Pet Owners Act"(H.R.1406).I object to the bill for the following reasons:
-All of my clients know they can get prescriptions from their veterinarians;constant advertising in all the media inform them.As a practitioner it is a waste of my time and resources to inform and document what all of my clients already know.
-At my practice we have never declined a client's request for a prescription to be filled elsewhere;in fact I consider that to be unethical as does the American Veterinary Medical Assoc.At my practice we always match prices when asked,if it is affordable for me to do so.
-FORCING increased competition will not decrease prices!As cited by the FTC,the law requiring opticians to do so,in my experience has FAILED to reduce prices for me as a lensewear consumer!In my family my wife and 2 children require prescription lensewear.In 20 years I have never noted any decrease in nor any significant differences in prices among any opticians for any eyewear we have purchased.I frequently see glasses advertised at 2 pair for $69.00 yet the national average annual costs are $114.00 for eye exams,$195.00 for glasses and over $400.00 for contact lenses!!In my experiences these national prices are similar to prices I have paid and have more than doubled in the last 10 years,far outpacing rates of inflation!Additionally,I have never been presented with any notice from any optician notifying us of the option of taking the lens prescription elsewhere..clearly,the law is unenforceable!Obviously,this law will NOT reduce prices for the veterinary medicine consumer either!
-This proposal will cost jobs!At my business the loss of income from veterinary medicine sales and the increased cost of receptionist's time to document signatures of notification of "choice" will require me to fire 3 people!I can assure you that BigBox stores will not increase their staffs to compensate for the business they take from me!If they did,I can assure you they will not pay "livable wages" as I do!
-Lastly,and most importantly,the proposed "Fairness to Pet Owners Act" promotes Unfair Business Practices against the Veterinary Profession!I provide veterinary medications at essentially the same prices as my competitors.I offer to write prescriptions AT NO COST to my clients who still wish to purchase these items at my competitors.As it stands now the BIGBOX pharmacies have the overwhelming advantage of attracting consumers with their unlimited,infinite advertising budgets!Why should I as a businessman be FORCED to tell my client"You should go by MY product elsewhere."?!Why should I,in essence,be forced to advertise for Wal-Mart,PetMedExpress,Costco or any of my competitors? How is this fair in a free market economy? In fairness to me,will you require the BigBox stores to inform their veterinary medicine consumers that they can purchase these products at my facility? Where will these required notices end? Will auto insurance companies or grocery stores or any other store soon be required to have customers sign a document at every visit telling them to go purchase their items and services at another store? This proposed law is unfair,unethical and I hope,probably unconstitutional as it does not treat veterinary businesses equally in a free market!!
-My final comment on this proposed regulation is a personal one. I find the name,"Fairness to Pet Owners Act" highly objectionable! I have prided my life as a person,as a professional and as a local elected public official on my honest and FAIR interactions with my clients and everyone with whom I deal!I doubt,highly,the BigBusiness entities and the writers and supporters of this bill,whom these businesses support with financial donations,can say the same!
Thank you for considering my comments.