16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00055

Submission Number:
Lethu Truong
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
The 8 hour rule should be changed. Online contact lens sellers send requests at extremely odd hours and even on holiday hours in which we are not open and they don't respect the clinics ours of operation and fill contact lens orders without proper authorizAtion. Online vendors need an actual working contact number for us to call if we need further information about verification requests. The number provided NEVER works and this brad Scott guy they say to contact is probably non existent. We are never able to contact anyone to get more information. Verification requests needs more information! They send a name, that's it. Sometimes no name and just an address! No date of birth, no other information to help us verify the correct patient and prescription information. Proper authorization needs to be documented and monitored better. No one is getting penalized for not following proper protocols and the system is beyond easily abused. Patients report getting their contact lenses from online vendors your multiple years without getting their yearly/ every two year health evaluations. I get requests from online vendors about patients who have never been to my office or hasn't been in for 5 years for contact lens prescription and I wouldn't be surprised if they were able to fill their expires prescriptions. I have vendors trying to substitute different materials and base curve for patients just because of price or availability. I have overheard people discussing how they cheat the system and just make up a doctor when they order online and they always get their contacts. How is it that a medical device can be so easily abused and filled? I even have patients who are still in the contact lens evaluation process without a finalized RX getting contact lenses from online vendors already. How is that possible? I have too many patients that come in and have corneal scars from contact lens abuse, corneal neovascularization, corneal hypoxia, corneal ulcers, stem cell deficiency, etc. Most of these patients end up having their contact lens benefit revoked because their corneal health is too poor from prolonged abuse for many years without proper care and health evaluation. I even had a patient who had one clear contact lens in her eye for and unknown amount of time. She did not know it was there and reports that she does not have ANY clear contact lenses at home. She only wears color contact lenses and she has been wearing it OVER her clear contact lens AND sleeping in it!! She did not even know when her last contact lens evaluation was. She only came in because she was having trouble seeing. Needless to say she is not allowed to wear contacts anymore but she did not come back for any of her follow ups and is probably still abusing contact lenses that she is somehow able to obtain still. The 8 hour rule should be extended to 3 days at minimum. Online vendors need to provide valid and working contact numbers, More patient information needs to be supplied on the verification request. Most importantly, online contact lens vendors need to follow the rules. They need to stop filling prescriptions without valid rx and valid authorizations. They need to stop encouraging patients to abuse their contact lens privileges by avoiding eye health exams and follow ups by getting year supplies at the end of their expiration date.