16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00011

Submission Number:
00011
Commenter:
Heather Smith
State:
North Carolina
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As an eye care provider I have seen a very large number of patients that have purchased contact lenses online for years after their prescription expiration. Furthermore, some of them chose whatever contact lens and strength they wanted when purchasing online and the seller made no attempt to verify the prescription's validity. The passive verification system does not work effectively or, I believe, as intended. Online retailers have set up "robocall" systems, so that when the phone is answered at the doctor's office a recorded message just begins supplying information that needs to be recorded so it can be verified. In addition, these calls make it difficult to respond because no "hard copy" of the information is supplied to the provider. A further failure of the passive verification system is that online retailers are open 24/7 while practioners' offices have variable hours throughout the country. The retailers take advantage of this well known fact to routinely passively verify contact lens prescriptions while practices are closed. Contact lenses are medical devices, not just a commodity. Significant damage to the eye can result from improper contact lens wear and care. Current rules regarding verification and sales of contact lenses by online retailers are allowing them to increase their bottom line but are putting patients' ocular health at risk. I have seen a large increase in contact lens abuse since the contact lens rule went into effect. There need to be more regulations regarding the seller of these medical devices, not just the prescriber.