I'm Preparing a Submission to ACCC about The Veterinary Industry. - I Need Your Stories

LCraigminns on 23/12/2018 - 06:41
Last edited 23/12/2018 - 16:46 by 1 other user

I've been invited by the ACCC to prepare a formal submission in relation to breaches of Australian Consumer Law within the veterinary industry. I have asked the ACCC for advice on the anti-competitive nature of regulation in this field and been advised that it has no power to act in respect of Government.

In order to support that submission I need your stories.

We all know that vet fees are high. In my view there are several reasons for this.

  1. The Australian Pesticides and Veterinary Medicine Authority (APVMA) administers a piece of legislation that expressly protects monopolies on veterinary medications. https://apvma.gov.au/node/1072

  2. The veterinary industry is dominated by a single large corporation, Greencross/Petbarn, which has a strongly integrated supply chain that includes wholesale and importation entities.

  3. Greencross is a large donor to the RSPCA, which supports its activities and benfits from that support both by direct donations and through the sale of high cost pet insurance products which in turn support the high charges made by vets.

  4. The Australian Veterinary Association (AVA) is also strongly supported by suppliers to the industry, including medicines,pet food, equipment and services, including insurers. In my view this creates a strong incentive for that organisation to advocate for overservicing.

  5. There is no independent oversight of veterinary practise. It is self-regulated.

  6. Individual vets have a strong incentive to advocate for the use of expensive equipment they have leased or purchased.

  7. The RSPCA has become a large corporation in its own right and frequently acts in repugnant ways in pursuit of financial rather than animal welfare interests.

  8. Both the RSPCA and APVMA operate as regulators for animal welfare and both organisations are driven by a cost-recovery model which creates an incentive for punitive enforcement and in some cases to aggressive enforcement action unjustified by the circumstances.

  9. Governments condone the RSPCA's abuse of powers in order to cost-shift compliance activities.

  10. Veterinary schools, in common with some other vocational professional education schools are training students in risk management practises and business models that create an incentive to overservice.

I'd love to have your stories. If there are any journalists who subscribe to this site I'd be happy to provide you with any information you need.

IF you would like to provide information in confidence you can send it to [email protected]. I give you my word that no identifying information will be used without your permission. I may contact you to discuss things if you are agreeable. Please say so if that's the case.

**EDIT

One of the eagle-eyed contributors to this thread has pointed out that pharmacists are empowered to fill veterinary prescriptions. I'd strongly recommend that people ask their vet for a prescription rather than handing over cash for possibly inflated prices. Thanks wordplay.

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Comments

          • p1 ama on 28/12/2018 - 18:21
            +4

            @Craigminns:

            I accept that some people don't agree, but the purpose of posting here is to gather evidence, not debate whether there is a problem or not.

            This is complete contradiction to the things you've said right here on this thread. You've said that you wish to hear "both sides". This necessitates discussing whether there is a problem or not.

            Either way, regardless of whether you wish to debate whether there is a problem or not, you need to establish that there is some sort of a problem before gathering evidence. Evidence is gathered to support a claim.

            I'm still a little nonplussed that vets seem unwilling to contribute in their own defence. A simple cost analysis of a typical practise would help to clarify things.

            You do realise that over 99% of people are NOT vets. So posting in a public forum is unlikely to gather the attention of any vets.

            If you are interested in hearing from vets, why don't you contact some vets directly or speak with many of the bodies that represent vets?

            Further, I'm confused why you expect vets to contribute in their own defence. You actually haven't accused them of anything illegal. Do you personally go around defending everyone who criticises groups to which you belong? Nobody does that.

            At present I'm pretty happy with the way things are going.

            You haven't produced anything despite saying that you wish to make your report public?

          • SydStrand on 28/12/2018 - 23:27
            +4

            @Craigminns:

            I'm still a little nonplussed that vets seem unwilling to contribute in their own defence.

            You do realise this is Ozbargain, not Ozvet, right? The fact that no other vets have responded in an off-topic bargain-hunting forum is not an admission of guilt. It's blind luck I stumbled across this thread, and you still haven't responded. Also, you seem to labour under the delusion that the onus is on random people to 'defend' our profession, when the burden of proof is actually on you and your wild conspiracy theories.

            • Craigminns on 29/12/2018 - 05:16
              -2

              @SydStrand: ah, now I'm a conspiracy theorist. You guys….

              There's no onus on anyone to do anything, but if someone is offering you a chance to set the record straight about your profession, I'd have thought it would be reasonable to do so. After all, the people here are your clients…

              It's up to you.

              • CMH on 29/12/2018 - 09:01
                +2

                @Craigminns: He's offering you a chance to set the record straight, that you're not a conspiracy theorist.

                According to you this is reasonable, so explain away!

                • Craigminns on 29/12/2018 - 09:45
                  -1

                  @CMH: Already been done.

                  Here's a tip you might find useful. A reasoned argument on the facts in relation to linkages between players in an industry may lead to the realisation that those players have common interests that lead them to act against the interests of the consumers of the products of that industry. This is a "conspiracy theory" based on reality.

                  On the other hand, a set of unrelated opinions that leads to wild accusations of misconduct involving unrelated players is a "conspiracy theory" based on fantasy.

                  You work out which this is.

                  • p1 ama on 29/12/2018 - 12:08
                    +2

                    @Craigminns:

                    A reasoned argument on the facts in relation to linkages between players in an industry may lead to the realisation that those players have common interests that lead them to act against the interests of the consumers of the products of that industry.

                    Which vet is breaking the law and which law is that vet breaking?

                  • CMH on 29/12/2018 - 13:35
                    +2

                    @Craigminns:

                    A reasoned argument on the facts in relation to linkages between players in an industry may lead to the realisation that those players have common interests that lead them to act against the interests of the consumers of the products of that industry.

                    To be honest, I haven't seen any evidence of that, beyond what you'd expect in a normal supply chain scenario.

                    I do see some wild accusations of collusion and monopolistic business practices (is that a thing?)

                    Of course, there's still that BIG question of what laws have been broken, and who have broken them?

                    If it's the laws itself that you're not satisfied with, then you will need another line of action.

                    Another question that's not been answered is, are you a conspiracy theorist? All I've seen is how your theories are considered a conspiracy based on truth. Is that a confession?

                    • Craigminns on 29/12/2018 - 18:13
                      -1

                      @CMH: A confession of what?

                      I've simply pointed out that there is a lot to be concerned about in the veterinary industry, based on what I've been told by vets and clients and on my own experiences and research.

                      I think there would be a lot of support from within the industry and it might lead to more vets being properly paid and less waste.

                      It's becoming more and more apparent that self-regulation has to be kept a check on.

                      Anyway, go to twitter if you're interested.

                      • p1 ama on 29/12/2018 - 20:27
                        +4

                        @Craigminns:

                        I've simply pointed out that there is a lot to be concerned about in the veterinary industry, based on what I've been told by vets and clients and on my own experiences and research.

                        Which vet is breaking the law and which law is that vet breaking?

                        • Craigminns on 18/01/2019 - 06:45

                          @p1 ama: That would be telling. The ACCC is the proper authority for that information.

                          • CMH on 18/01/2019 - 12:30

                            @Craigminns: ACCC isn't going to investigate anyone you don't specifically name in your complaint.

                            They do the investigate if your complaint isn't valid neither.

                            So it's a valid question: Which vet is breaking the law and which law is that vet breaking?

                            If you can't answer that ACCC has nothing to investigate. Simple as that.

                            • Craigminns on 18/01/2019 - 18:27

                              @CMH: And I've already given you a valid answer.

                              • CMH on 18/01/2019 - 19:39

                                @Craigminns: I can't for the life of me find it.

                                Which vet is breaking the law and which law is that vet breaking?

                                The ACCC is the proper authority for that information.

                                How is that a valid answer?

                                • Craigminns on 18/01/2019 - 19:42

                                  @CMH: Because that's the answer you're going to get. What authority do you have to demand I answer your question.

                                  I really think this discussion has reached the end of its useful life. Thank you for participating.

                                  • CMH on 18/01/2019 - 19:57

                                    @Craigminns: Lol.

                                    Then say you don't want to answer the question. That's a valid answer.

  • marcnunes on 28/12/2018 - 16:30

    Every year when I have to pay my pet premium I fell ripped off. I would like to have the freedom of changing providers every year but I would need to serve the waiting period again. That would be 30 days for sickness and 6 months for cruciate ligament.
    Yes, you can have the cruciate ligament waiting period removed but you would need to take the dog to a vet for an examination and pay for it.
    Every year they increase 10% my premium and I am afraid to cancel and my beloved one get cancer or something ultra expensive and I would need to put him down.
    Why on earth they do not accept waiting period served like other insurances?

    • Ti-au on 30/12/2018 - 00:52

      Well thats something you can legit complain about… I'm just not sure to whom….

      • Craigminns on 30/12/2018 - 05:44
        -1

        Lovely to watch you guys, every trick in the book. Now it's "of course you're right, but there's nothing you can possibly do about it".

        There will be an enquiry and people will get a chance to have their say. Including you.

        • p1 ama on 30/12/2018 - 11:25
          +2

          There will be an enquiry and people will get a chance to have their say.

          That's not how an enquiry works.

          Enquiries are based on research, evidence, facts and reports by experts.

          They are not members of the public getting up and telling stories about their experiences. Whilst this may form a component of an enquiry, it's a small component.

        • Ti-au on 30/12/2018 - 12:00
          +2

          Including you.

          I don't own a pet or am a vet.
          So why would I complain?

          Now it's "of course you're right, but there's nothing you can possibly do about it".

          Actually the person whom to complain would be to Politicians to get the legislation changed, however getting legislation on to the floor and approved (by usually both houses (and by both parties)) is actually quite difficult.

          They could complain to the new body Australian Financial Complaints Authority (AFCA), but pre-existing are allowed in Human insurance, so why would pets get it different? Also it is disclosed, so ACCC can't get really involved (Competition and Consumer Act 2010).

          Hence we know who to complain to - Politicians - but what is the chance the legislation will get introduced? About 0% chance.
          Hence I should of been more clear - "…Im not sure to whom, to get the outcome you desire" (if the outcome is elimination of waiting times).

          There will be an enquiry and people will get a chance to have their say.

          First its an Inquiry not an enquiry. And from my understanding the only way the ACCC holds an Inquiry, is via direct order from the Government. Meaning the Treasurer of Australia makes a Ministerial direction to the ACCC to hold an Inquiry.
          I will be very happy for you when the Treasurer of Australia orders the ACCC to investigate the RSPCA and 'pets'.

          And of which 100% did nothing to change the prices (dairy milk (milk sold at farm gate), Strata insurance Nth QLD , electricity supply).

          Do you know how expensive Inquiries are to setup? Over $5-10M or so (RCs cost over $50-75M). Yes with their limited budget and after a Royal Commission, the ACCC is going to set up Inquiry about 'pets'?

          It would be better to get them to do a Market studies. But you know better. Eh.

        • CMH on 30/12/2018 - 14:09
          +1

          Lovely to watch you guys, every trick in the book. Now it's "of course you're right, but there's nothing you can possibly do about it".

          So who exactly said you're wrong and can't do it, and then changed tune?

          • Craigminns on 31/12/2018 - 08:55
            -1

            @CMH: Oh my good lord…

            • CMH on 31/12/2018 - 15:10

              @Craigminns: Sorry, my bad.

              Silly me asking for clarification from you.

              • Craigminns on 18/01/2019 - 06:44

                @CMH: Silly you asking for me to repeat myself.

  • Pantagonist on 28/12/2018 - 17:43
    +1

    Spoiler alert.

    Provided you follow the ACCC's advice and change the nature of your complaint to be something that actually falls within their remit, here's what you'll get back:

    Dear. Mr. Minns

    Thank you for writing back to us about the veterinary industry. We have recorded the details of your report. We can offer you information about our investigations policy and what the ACCC can and can't do for consumers.

    Information on investigations – our policy

    The ACCC does not comment on its enforcement investigations unless it is in the public interest. There are a range of factors that limit our ability to comment on investigations such as ensuring fairness to individuals, companies and businesses being investigated, or the potential to jeopardise investigations through the untimely release of information.

    However, in some circumstances it may be in the public interest to provide comment on an investigation. We take a range of factors into account when considering whether to make a statement, including if:

    • information about an investigation is already in the public domain
    • the ACCC has been publicly called upon to respond to an issue or undertake an investigation
    • comment is necessary in order to maintain public confidence that the ACCC is fulfilling its responsibility by investigating issues of public concern
    • comment is necessary for investigation purposes, for example, in order to encourage witnesses to come forward
    • making a statement could prevent widespread misconduct, or allay public concern.

    For more information, read our media code of conduct or keep up-to-date on the latest news by subscribing to receive ACCC email alerts, RSS feeds or e-newsletters.

    What we can and can’t do for consumers

    The Australian Competition and Consumer Commission is an independent Commonwealth statutory authority. We are Australia’s competition and consumer regulator. We promote competition and fair trading and regulate national infrastructure to make markets work for everyone.

    What we can do for consumers

    We can:

    • accept and record your reports of information about business practices and behaviours that are of concern to you. We will respond to your report where we have information that may help you, or you have asked a question about your rights or obligations under the law.
    • provide you with information about your rights under the law via the ACCC website, ACCC publications or when you contact our Infocentre. Where relevant, written responses are provided within 15 working days.
    • provide general guidance about the Competition and Consumer Act 2010 and refer you to the ACCC’s website and our publications for further information
    • refer you to another agency if your issue doesn’t fall under the responsibilities of the ACCC
    • provide information about product safety recalls and mandatory standards
    • provide information about the ACCC and what enforcement action we've taken
    • investigate alleged breaches of the Act (where it meets our compliance and enforcement policy priorities) and take enforcement or compliance action, where appropriate.

    What we can’t help you with

    We can't:

    • act on your behalf or provide you with legal advice on your rights and obligations under the law
    • make formal decisions on whether a person or business had breached the law as only the courts can do this
    • regulate or set the prices for goods or services such as groceries or fuel
    • provide dispute resolution services between consumers and businesses.

    We do not:

    • ordinarily comment on the level of complaints about particular businesses or the status of any ongoing investigation. Where we do, this is as a publically available statement.

    We have recorded your report

    We appreciate you reporting your matter to us. All information is potentially valuable to help us identify trends and where we can most effectively direct our resources, so we encourage you to report any behaviour or business practice that is concerning to you.

    What the ACCC does with information from reports

    The ACCC focuses on enforcing the laws we administer in circumstances that have the potential to harm the competitive process or result in widespread consumer or business detriment. We use reports received from the public and small business, as well as other sources of intelligence, to inform our work. When the ACCC takes action, it is to remedy market problems; we are not a complaint handling body and don’t resolve individual disputes. You can read more about how we prioritise our work and what we can and can't do for consumers on our website.

    We hope the information we have provided today is helpful.

    Yours sincerely
    Faceless Commonwealth Public Servant

    Then, after all the work you do, expect never to hear from them again.

    • Craigminns on 29/12/2018 - 05:17
      -1

      Perhaps, but perhaps not.

  • arman1201 on 29/12/2018 - 08:47
    +3

    Craigminns
    Member Since
    23/12/2018

    Full disclaimer partners a vet.
    Getting trolled/triggered hardcore boys and girls.
    lulz

    • Craigminns on 29/12/2018 - 13:40
      -3

      Hahaha

      You're funny, you know.

      • HighAndDry on 09/01/2019 - 10:24
        +2

        I'd go out on a limb and say that 99% of people are funnier than you are.

        • Craigminns on 18/01/2019 - 06:44

          Quite possibly. I suspect the RSPCA and their "corporate partners" don't think I'm very funny at all.

  • HighAndDry on 08/01/2019 - 15:54
    +3

    Yeah, OP just comes across as a disgruntled pet owner with an axe to grind. And possibly also a conspiracy theorist. Collection of quotes from just this thread, starting with:

    Craigminns on 23/12/2018 - 10:15
    I have already done significant research. I believe my understanding is sound.

    And then demonstrating that this is far from the case:

    D'oh, completely missed that, well done. I appreciate people checking my work, it's easy to make mistakes as I'm sure everyone understands. (context: comparing price of 2 pills vs price of 1 pill)

    I haven't researched costs of veterinary services as yet.

    Thanks, I wasn't aware of that. (context: OP wrongly believed pharmacists couldn't fill vet prescriptions - they can)

    I am a reasonably well informed consumer and have never been aware of this till now (context: same topic as above, blaming others for his own ignorance)

    THIS ENTIRE COMMENT

    Vets have been looking after animals for a long time, the science is largely solved. (same comment, but… especially hilarious and ignorant)

    As I have explained several times, this is an evidence-gathering exercise, not a witch-hunt and I believe I have been even-handed. (for clarity, my emphasis)

    Also that OP is a conspiracy theorist:

    I suspect there may be plans by some of the parties involved to try to have this page removed and I'd like to try to preserve your evidence.

    If there is cartel conduct found to have taken place I'd like proper punitive action taken against the perpetrators and the cartels dismantled.

    If, as I've been informed, the industry is creating serious mental health problems for practitioners, (and really that entire comment…)

    if charges are inflated to the extent that animal ownership is taken out of the reach of willing pet-owners on incomes which could support fair costs, then the Anti-Discrimination Commission may have an interest in the matter. (actually from the same comment)

    My feeling is that the poster is a vet who is feeling under threat

    It's OK folks, the page is already downloaded and saved.

    Ah, the life of a corporate pr hack must be so intense.

    • Craigminns on 18/01/2019 - 06:43
      -1

      conspiracy
      /kənˈspɪrəsi/
      noun
      noun: conspiracy; plural noun: conspiracies

      a secret plan by a group to do something unlawful or harmful.
"a conspiracy to destroy the government"
synonyms:   plot, scheme, stratagem, plan, machination, cabal, intrigue, palace intrigue; More
deception, ploy, trick, ruse, dodge, subterfuge, sharp practice;
informal frame-up, fit-up, racket, put-up job;
rare complot, covin
"the company was involved in a conspiracy with bookmakers to manipulate starting prices"
    the action of plotting or conspiring.
    "they were cleared of conspiracy to pervert the course of justice"
    synonyms:   plotting, collusion, intrigue, connivance, machination, collaboration; treason
    "he was due to stand trial for conspiracy to murder"

      Phrases
      a conspiracy of silence — an agreement to say nothing about an issue that should be generally known.
      "the ministers took part in a conspiracy of silence over the decision to close the steelworks"

      Yep, seems to fit.

  • Baghern on 13/01/2019 - 10:24
    +2

    Recalled this thread when I just read this article

    https://www.abc.net.au/news/2019-01-13/vet-shortage-as-suici…

    It reminded me that students I knew/heard of going into Vet studies were usually kids of Rich parents.

    Everyone knows the pay sucks for the requirements of the job. It looks like they don't realise the idiots like the op who thinks everything should be super cheap.

    It almost like modern childcare services, everyone wants it no one wants to pay for it.

    • Craigminns on 18/01/2019 - 06:41
      -1

      Actually, I care very much about the plight of graduates and vets in general. I don't blame the animal lovers who decide to devote their lives to animal welfare for the state of the industry. They are exploited ruthlessly by the unscrupulous big players.

      It's the shonks who should be worried about this submission. The ethical, dedicated members of the industry should welcome it, they will be much better off if an ACCC broom goes through the rat's nest.

      The RSPCA has very little to be proud of in their role either. They are an organisation carrying a Royal seal. I don't think Her Majesty will be best pleased by some of the evidence that's been given to me.

      • SydStrand on 24/01/2019 - 00:21
        +1

        Who are these 'unscrupulous big players' you're complaining about? Genuinely curious. The overwhelming majority of vet clinics are small businesses, and if you actually knew owners like I do, you'd know they aren't rolling in money. Even Greencross, the largest employer of new grads, is far from a monopoly. So point your finger where you think all the money is going.

        The problem isn't some shadowy cabal exploiting vets, but the fact that it's tough, often traumatic, work and we don't get paid a lot. It's not because our bosses are screwing us, there's just less money to go around for salaries when mandatory non-personnel expenses (like the X-ray machines you complain about) are so high, and it's not helped by malcontents like yourself who have been spoiled by Medicare into devaluing the cost of healthcare.

        • Craigminns on 28/01/2019 - 19:45

          I agree that most vets are not doing well. The industry has been captured by a cartel.

          I'm not sure why you're attacking me, I'm most definitely on the side of good, ethical veterinary practice. I'm also not sure why you would want to defend Greencross/Petbarn unless you have an association with them. Do you? They have most assuredly come to dominate the industry, both in practise ownership/franchising and in retail and distribution supply chains. Can you point to any competitive operations?

          They are the largest employer of graduates and the graduates are grossly underpaid. I've had one such get in touch, telling me of her experiences. There is constant pressure on salaries with a large influx of new grads entering the industry every year.

          I'm very much aware of the pressures on vets. I thought to become one once, but couldn't bear the idea of putting down animals or inflicting pain on them as a young bloke. I greatly appreciate the young people who make it their choice of career and I think they've been badly let down by their profession and the industry. I'm told that the suicide rate among vets is some 4 times higher than that of the general population, according to the AVA.

          The pressures on vets to purchase unnecessary equipment have been high. I'm still unpacking the reasons. Not every practise needs an X-Ray machine, or to lease blood testing equipment from Idexx. Not every vet needs to have comprehensive surgical facilities. The medical profession has not followed this model for decades. In rural practise it can be justified, but not in an urban environment, where networks of expertise would be much more sensiible. Vets don't need to devote their waiting rooms to expensive displays of Hills petfoods. My community doesn't need 5 or more vets within a 5km radius and 2 Petbarn stores within not much further distance. Trying to make a living in that environment, dealing with a declining pet-owning population, gives some vets a high incentive to overcharge and overservice to make ends meet. I have a number of stories to share with the ACCC describing such practises.

          I've had dogs all my life. I've dealt with many vets. The cost escalation over the past 10 years has been rapid and unjustified, and has been supported by and in turn supported the peddling of greatly overpriced insurance products. I believe I can make out a strong case for presentation to the ACCC for investigation of conduct that is not in the interest of either the practitioners or the consumer. You are apparently a vet: if you'd like to help your profession get past this, I'd welcome your getting in touch on the [email protected] address. Other vets have.

        • Janert on 31/01/2019 - 21:00

          Hey Strand. I'm genuinely curious to know what your stance is on vet issuing veterinary prescriptions? Also curious as to whereabouts in Sydney you practice if you don't mind me asking?

  • CMH on 17/01/2019 - 22:04
    +1

    Wow, thread still going. OP has abandoned this quest ages ago, or we'd have heard about this great submission by now.

  • truebredlabradors on 08/07/2019 - 10:34

    While I agree that there are some Vet chains that may have a monopoly in some areas with their brick-and-mortar stores, given the huge amount of online Vet supplies available, their monopoly seems limited to the provision of Vet services and not so much Vet related goods (other than maybe prescription medicines).

    I think consumers need to really shop around, including for Vet services, as they seem to vary a lot. In price and quality of services.

  • WordsToSayIt on 21/09/2019 - 22:13

    It's the equivalent of Big Pharma. People who want their pets to live, and not just survive, should use holistic vets or learn preventative care from Dr Andrew Jones.

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