Internet pharmacies: AVMA tracking complaints
Schaumburg, Ill.-Access to veterinary products via the Internet, from credible and charlatan pharmacies, is a trend that is here to stay.
And it will likely become more prevalent, experts predict.
While officials say it is hard to know exact numbers on the companies offering these prescription services, the trend over the last couple of years has included many less-than-traditional players, including international pharmacies and even pet stores.
The American Veterinary Medical Association (AVMA) has taken so many inquiries about veterinarians' rights and responsibilities, it has created a form to file complaints with the appropriate boards or government agencies, which regulate pharmacies.
In human medicine, the Food and Drug Administration (FDA) cites the Internet pharmacy as one of the hottest issues now for the government agency to police.
According to Dr. Elizabeth Curry-Galvin, AVMA's assistant director of scientific activities, she is now aware of at least 100 formal complaints regarding Internet veterinary pharmacies. While Curry-Galvin noted the association will not discuss any one particular pharmacy, she adds that there are very legitimate, credible pharmacies using the Internet to expedite sales. But there are also rogue companies.
Of the complaints AVMA knows have been filed with the appropriate regulatory agencies, Curry-Galvin says that all have focused on companion animals.
"We all know that food animal practitioners have been dealing with the situation of rogue suppliers and 'drive-by' drop shipping for quite a few years. We are also hoping they will use this form as a way to combat these inappropriate activities."
Curry-Galvin says, AVMA's involvement is as a resource to practitioners.
* One role is to guide practitioners on rights and responsibilities in providing prescriptions.
* The other area is to instruct DVMs on what to do if they see rogue activity when prescriptions are filled. AVMA has defined rogue activity as contrary to regulation and inconsistent with best patient care.
"A common question is 'Someone wants a prescription but the pharmacy is six states away, do I have to be licensed in that state?' The answer is no; your practice of veterinary medicine is contained in the state where you or the animal is and your license to practice," Curry-Galvin states.
If a veterinarian has a complaint about an out-of-state pharmacy, then they should file complaints to the pharmacy boards in the practitioner's home state as well as the pharmacy's home state.
The pharmacy's home state is where potential actions against its license could be taken if judged egregious. The board in the veterinarian's home state also issues out-of-state pharmacy licenses, so it could potentially be important to file there too.
"A state could say that they do not wish a certain pharmacy to ship into their state anymore, so that is why it is important for practitioners to send it to both those pharmacy boards," she adds.
DVM on staff
Some pharmacies also have staff veterinarians to authorize prescriptions which can be a source of contention. Curry-Galvin says that there is no way a valid veterinarian-client-patient relationship can exist in that situation.
Those complaints should be filed with the boards of veterinary medicine in the appropriate state.
"We want to reprimand the veterinarian who is not looking out for best patient care and who is not following the federal and state regulations governing prescription drugs," she adds.
Curry-Galvin is encouraging practitioners to document cases contrary to pharmacy laws.
"It is the only way this goes on the radar screen of the regulatory agencies. The AVMA form says, 'Prescription drugs are regulated by federal and state agencies, including the state to which prescription drugs are sent. Pharmacists are required to have a valid prescription before dispensing prescription drugs. Veterinarians must have a veterinarian-client-patient relationship to prescribe prescription drugs.' "
AVMA adds that while Internet pharmacies can be a legitimate business enterprise, the association would like to be kept in the loop about those potentially breaking laws. Curry-Galvin adds that AVMA's position will continue to focus on best patient care and a level playing field for veterinarians.
"They have to feel comfortable that the pharmacy getting the script will be doing legitimate things when filling the script, or their name and account won't be misused, or they won't be sent some threatening letter because they declined a request for a prescription because of medical reasons.
"Regrettably there is a whole lot of ill will going on out there that is just plain inappropriate," she adds.
Worried about the credibility of a pharmacy?
Curry-Galvin advises you to take two different routes, but adds veterinarians are not obliged to become a police officer for clients wanting to fill prescriptions via an Internet pharmacy.
* First, make certain the pharmacy is licensed to operate in the state. The fastest way to ascertain the information is to go to the National Boards of Pharmacy Web site (www.nabp.org), which has a listing for all the state boards of pharmacy. Many of the states have Web sites with search functions and you can find out this information on line. For other states it may just take a phone call.
* Secondly, NABP runs a program certifying Internet pharmacies. The voluntary program is called Verified Internet Pharmacy Practice Sites (VIPPS), and includes facility inspections. If the pharmacy is certified in the program, it is a way to allay credibility fears, but Curry-Galvin says she does not believe there are any pharmacies in the program yet carrying animal drugs.
AVMA wants to act as a resource for veterinarians in determining which government agency needs to know when pharmacy laws are circumvented.
"Veterinarians want to make sure they are in compliance and doing the right thing for the animal and the client," Curry-Galvin says. "So, we are offering assistance in that regard."
The form provides veterinarians with an outlet to file complaints.
Complaints should be directed to:
* The state's board of pharmacy (addresses can be found at www.nabp.org).
* FDA Center for Veterinary Medicine, Dr. Andrew Beaulieu, associate director for animal health policy and operations, CVM/FDA, 7519 Standish Place, Rockville, MD 20855; FAX: (301) 827-4401, e-mail: Abeaulie@cvm.-fda.gov.
* Forward a copy of the complaint to AVMA, c/o Dr. Elizabeth Curry-Galvin, 1931 N. Meacham Road, Schaumburg, IL 60173; FAX: (847) 925-929; e-mail: Egalvin@avma.org, (800) 248-2862.
The form is available at www.avma.org.
Where to file pharmacy complaints
* The state's board of pharmacy (addresses can be found at www.nabp.org).
* FDA Center for Veterinary Medicine, Dr. Andrew Beaulieu, associate director for animal health policy and operations, CVM/FDA, 7519 Standish Place, Rockville, MD 20855; FAX: (301) 827-4401, e-mail: Abeaulie@cvm.fda.gov.
* Forward a copy of the complaint to AVMA, c/o Dr. Elizabeth Curry-Galvin, 1931 N. Meacham Road, Schaumburg, IL 60173; FAX: (847) 925-929; e-mail: Egalvin@avma.org, (800) 248-2862. The form is available at www.avma.org.
AVMA position on Internet pharmacies
The following recommendations are offered as a guide to prescribing and client purchases:
* 1. Drug therapy, when medically indicated, should be initiated by the attending veterinarian in the context of a valid veterinary-client-patient relationship (VCPR).
* 2. Drugs may be dispensed or prescribed. Veterinarians should honor client requests to prescribe rather than dispense a drug (AVMA Prinicples of Veterinary Medical Ethics). The client has the option of filling a prescription at any pharmacy.
* 3. Clients might be advised to select an Internet pharmacy certified by the National Boards of Pharmacy whose VIPPS program and its accompanying seal of approval identify to the public those online pharmacies that are appropriately licensed and prepared to practice pharmacy via the Internet.
* 4. Veterinarians asked by pharmacies to approve prescriptions they have not initiated should do so only if the prescription is appropriate and valid VCPR exists.
* 5. It is within the veterinarian's (not the pharmacy's) purview to determine the medical criteria whereby a drug is indicated.
* 6. As with any prescription, a written record should be maintained.
* 7. Prescribing veterinarians should assure that information regarding the proper use of the prescribed drug and the risks associated with its use are communicated to the client, regardless of the drug source.
Use of drugs of foreign origin that lack FDA approval generally is not permitted.