16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00027

Submission Number:
00027
Commenter:
Jay Chretien
State:
Georgia
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
The system that is in operation for companies to verify a patient's prescription is dysfunctional at best. There are some online sellers that provide a fax that can easily be verified, but one in particular does some thing very sneaky. 1800contacts calls the office with a recording that is just about 5 minutes long. There is no information regarding the patient, the CL prescription that is being verified, or anything of value. All of the important information is at the end of the recording. That means that if you are patient/bored enough to sit through the whole recording, there is not enough time to pull the patient information to even verify the patient, prescription or expiration date. Furthermore, most offices are too busy to wait for that recording -- they put the call on hold and the Rx is automatically refilled when there is no response. I have worked in many offices that just put the call on hold then carry on with their duties. I can't blame them as front office staff at an eye doctor's office aer typically very busy. But what this means is that prescriptions are not getting verified. I believe the 5 minute recording is an intentional tactic to get the staff to put them on hold or hang up so that the Rx can be refilled. In fact, I have had patients that have refilled a CL Rx for over 10 years without having an adequate health evaluation. If the CL rule is to ensure sustained health for patients, this is counterproductive. It puts patients at risk for using medical devices that are likely the most significant risk of vision loss that those patients face. I believe that 1800contacts has devised a system that is, in it's very nature, deceptive and designed to get authorizations through default. Nobody has the time to wait through the recordings and even if they did, there is not enough time to pull the patient information to adequately verify the CL information.