16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00036

Submission Number:
00036
Commenter:
My-Hanh Vu
State:
New York
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Hello, I am an optometrist and am writing to relay my experiences with 1800-Contacts and other online retailers. I have had several patients in the past year who come in for their contact lens exams well past the one year indicated on their prescription. Patients often come to their exam upset that they can no long order online because we "would not let them" fill their expired prescriptions. I am going to share 3 examples that are typical of what I experience daily. One patient had been filling 1800-Contacts orders for 8 years using the same prescription. When he came in, he exhibited corneal neovascularization and was headed towards an infection. We were able to revisit proper contact lens care techniques and prevent a possible infection. In addition, we were able to educate him on the latest technology in contact lenses and he was very grateful. A second patient was an established patient that had been getting contacts from 1800-Contacts for 6 years. He had submitted many requests throughout the years to renew an expired prescription and we have denied the requests. Somehow, he was still able to get his order through them. He finally came in in 2015 and had proceeded to become a glaucoma suspect by then. He was once again educated on the importance of annual eye exams for the overall eye health. Another patient was an established patient who has a history of red eyes and ulcers. Even so, he continued to fill his prescriptions online and his last exam was August of 2012. His records indicated that he tried to order contact lenses in 2014. His request was denied due to expiration date. We faxed the form back to 1800 in a timely manner. Even so, the request was filled so the patient had contacts for another year. On 7//30/15, the patient called and was upset at us for explaining to him that he needs a new exam to reassess his corneal health and make sure he is in the most suitable contact lens. This practice villainizes the profession that actually cares about our patients' eye health. The practices of 1800-Contacts and some other retailers commoditizes contact lenses rather than promoting it as an FDA medical device. In addition, when patients click the button that automatically allows online retailers to elicit the patient's prescription every single year thereafter, they often don't realize that that is what they are clicking. Rather, patients should have an email sent by online retailers reminding them to get an annual eye exam. I am a proponent of an open market but only when upright and straight forward business practices are followed by all parties involved with the best interest of the patient. Please hold these retailers accountable for taking in to account their bottom line rather than what is best for the patient. Best regards, Dr. My-Hanh Vu