16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
To Whom It May Concern: I would like to take just a moment to address concerns about the FTCA. While the intent of allowing patients to search for the best price on their contact lenses is (in principle) a worthy ideal, the reality of it is, more often than not, a system that allows for abuse. Too often prescriptions are being filled by third party vendors who have NO interest in patient health and are only concerned with bottom line profits and lens sales. These contact lenses are medical devices that, along with the ability to provide sight, have the potential to cause great harm. Because of this, fitting parameters MUST be strictly adhered to. This includes brand name, fitting parameters, number of boxes available to order and EXPIRATIONS. When lenses are not supplied according to doctor prescriptions, (in my opinion) that prescription has become abusive in nature and non-valid. Ultimatly, abuse of the system by third parties and patients puts MY license on the line in the event of a lawsuit!!! I have a problem with such a system. In today's electronic world there needs to be a better way to insure that patients are not harming themselves by filling an expired prescription or receiving lenses that are not specific to doctor's written prescription. I am not advocating for suppression of patient's right to choose where they receive their contacts. But rather, a better system of enforcement that holds these third party companies to a higher level of accountability, much like a pharmacy is accountable when they dispense pharmaceutical drug products. Above all, we must not loose sight of the fact that contact lenses are first and foremost a medical device that assists in the process of vision. Thank you for your time.