In early February, the AVMA met with staff at the Federal Trade Commission's (FTC) Office of Policy Planning to discuss veterinary prescription writing and how H.R. 1406, the Fairness to Pet Owners Act, would impact the profession. The FTC is the executive agency tasked with enforcing provisions in H.R. 1406 should it become law.
The FTC staff was very interested in the practice of veterinary medicine and the logistics of dispensing and prescribing medications for our patients. They were interested in whether there is a typical veterinary pharmacy operation in each veterinary clinic, what percentage of a veterinarian's business is comprised of pharmacy sales, how a veterinary clinic's prescription product pricing compares to non-veterinary retailers, and how pet medications are regulated to ensure quality and safety.
FTC staff was also interested in learning about when pet owners might request a prescription for a medication and how many complaints pet owners have filed when their veterinarian did not provide a written prescription. The standards of a Veterinarian-Client-Patient-Relationship (VCPR) and how it is interpreted in each of the states, extra-label drug use, and the impact of the current economic recession on veterinarians and their practices were all discussed.
AVMA staff expressed concerns that the lack of veterinary pharmacology training amongst pharmacists would impact animal health animal health should a pharmacist give incorrect information or change a prescription based on their knowledge of human medicine. Unscrupulous online pharmacies and unaccredited or unlicensed online pharmacies, and how they could negatively affect animal health and welfare should the prescription be filled improperly or with an unsafe or ineffective product were also discussed.
FTC staff was very interested to hear about the potential logistical and financial burdens placed on veterinarians should this legislation pass. AVMA explained the administrative issues and time it takes to provide a prescription, especially when it is not part of the office visit. In addition, verifying prescriptions and answering any follow-up questions from non-veterinary pharmacies, it was explained, puts an unfair burden on veterinarians who are small business owners.
FTC has been in the process of contacting individual veterinarians, state veterinary medical associations, state veterinary medical boards, drug manufacturers and pharmacy associations. The AVMA appreciates the participation of the veterinary community. While the FTC has not disclosed their next steps, the AVMA will remain engaged and keep our membership informed.
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