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 companiesoffering these prescription services, the trend over the last couple ofyears has included many less-than-traditional players, including internationalpharmacies and even pet stores.

The American Veterinary Medical Association (AVMA) has taken so manyinquiries about veterinarians' rights and responsibilities, it has createda 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 Internetpharmacy as one of the hottest issues now for the government agency to police.

According to Dr. Elizabeth Curry-Galvin, AVMA's assistant director ofscientific activities, she is now aware of at least 100 formal complaintsregarding Internet veterinary pharmacies. While Curry-Galvin noted the associationwill not discuss any one particular pharmacy, she adds that there are verylegitimate, credible pharmacies using the Internet to expedite sales. Butthere are also rogue companies.

Of the complaints AVMA knows have been filed with the appropriate regulatoryagencies, Curry-Galvin says that all have focused on companion animals.

"We all know that food animal practitioners have been dealing withthe situation of rogue suppliers and 'drive-by' drop shipping for quitea few years. We are also hoping they will use this form as a way to combatthese inappropriate activities."

Curry-Galvin says, AVMA's involvement is as a resource to practitioners.

* One role is to guide practitioners on rights and responsibilitiesin providing prescriptions.

* The other area is to instruct DVMs on what to do if theysee rogue activity when prescriptions are filled. AVMA has defined rogueactivity as contrary to regulation and inconsistent with best patient care.

"A common question is 'Someone wants a prescription but the pharmacyis six states away, do I have to be licensed in that state?' The answeris no; your practice of veterinary medicine is contained in the state whereyou or the animal is and your license to practice," Curry-Galvin states.

If a veterinarian has a complaint about an out-of-state pharmacy, thenthey should file complaints to the pharmacy boards in the practitioner'shome state as well as the pharmacy's home state.

The pharmacy's home state is where potential actions against its licensecould be taken if judged egregious. The board in the veterinarian's homestate also issues out-of-state pharmacy licenses, so it could potentiallybe important to file there too.

"A state could say that they do not wish a certain pharmacy to shipinto their state anymore, so that is why it is important for practitionersto send it to both those pharmacy boards," she adds.

DVM on staff

Some pharmacies also have staff veterinarians to authorize prescriptionswhich can be a source of contention. Curry-Galvin says that there is noway a valid veterinarian-client-patient relationship can exist in that situation.

Those complaints should be filed with the boards of veterinary medicinein the appropriate state.

"We want to reprimand the veterinarian who is not looking out forbest patient care and who is not following the federal and state regulationsgoverning prescription drugs," she adds.

Curry-Galvin is encouraging practitioners to document cases contraryto pharmacy laws.

"It is the only way this goes on the radar screen of the regulatoryagencies. The AVMA form says, 'Prescription drugs are regulated by federaland state agencies, including the state to which prescription drugs aresent. Pharmacists are required to have a valid prescription before dispensingprescription drugs. Veterinarians must have a veterinarian-client-patientrelationship to prescribe prescription drugs.' "

AVMA adds that while Internet pharmacies can be a legitimate businessenterprise, the association would like to be kept in the loop about thosepotentially breaking laws. Curry-Galvin adds that AVMA's position will continueto focus on best patient care and a level playing field for veterinarians.

"They have to feel comfortable that the pharmacy getting the scriptwill be doing legitimate things when filling the script, or their name andaccount won't be misused, or they won't be sent some threatening letterbecause they declined a request for a prescription because of medical reasons.

"Regrettably there is a whole lot of ill will going on out therethat is just plain inappropriate," she adds.

Credibility question

Worried about the credibility of a pharmacy?

Curry-Galvin advises you to take two different routes, but adds veterinariansare not obliged to become a police officer for clients wanting to fill prescriptionsvia an Internet pharmacy.

* First, make certain the pharmacy is licensed to operatein the state. The fastest way to ascertain the information is to go to theNational Boards of Pharmacy Web site (www.nabp.org), which has a listingfor all the state boards of pharmacy. Many of the states have Web siteswith search functions and you can find out this information on line. Forother 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 certifiedin the program, it is a way to allay credibility fears, but Curry-Galvinsays she does not believe there are any pharmacies in the program yet carryinganimal drugs.

AVMA's role

AVMA wants to act as a resource for veterinarians in determining whichgovernment agency needs to know when pharmacy laws are circumvented.

"Veterinarians want to make sure they are in compliance and doingthe 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 foundat www.nabp.org).

* FDA Center for Veterinary Medicine, Dr. Andrew Beaulieu,associate director for animal health policy and operations, CVM/FDA, 7519Standish 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. ElizabethCurry-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 foundat www.nabp.org).

* FDA Center for Veterinary Medicine, Dr. Andrew Beaulieu,associate director for animal health policy and operations, CVM/FDA, 7519Standish 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. ElizabethCurry-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 prescribingand client purchases:

* 1. Drug therapy, when medically indicated, shouldbe initiated by the attending veterinarian in the context of a valid veterinary-client-patientrelationship (VCPR).

* 2. Drugs may be dispensed or prescribed. Veterinariansshould honor client requests to prescribe rather than dispense a drug (AVMAPrinicples of Veterinary Medical Ethics). The client has the option of fillinga prescription at any pharmacy.

* 3. Clients might be advised to select an Internetpharmacy certified by the National Boards of Pharmacy whose VIPPS programand its accompanying seal of approval identify to the public those onlinepharmacies that are appropriately licensed and prepared to practice pharmacyvia the Internet.

* 4. Veterinarians asked by pharmacies to approve prescriptionsthey have not initiated should do so only if the prescription is appropriateand 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 shouldbe maintained.

* 7. Prescribing veterinarians should assure that informationregarding the proper use of the prescribed drug and the risks associatedwith its use are communicated to the client, regardless of the drug source.

Use of drugs of foreign origin that lack FDA approval generally isnot permitted.