16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I am all for an open market. I have no problem with patients using a WRITTEN prescription to get their contact lenses from other vendors. The problem with the current contact lens rule is that the patient doesn't need to use a written prescription to acquire their lenses. Contact lenses, like medication, are supposed to be dispensed via a prescription; however, The Contact Lens Act does not treat a contact lens Rx in the same way as a prescription I would write for medication. A written prescription is not required to purchase contact lenses online since a patient can enter their parameters and then a doctor must verify it. Patients should have to send in their written prescription just like they have to do when purchasing medications online. Doctors should not be expected to verify the parameters of a prescription that they have already written, require a written prescription as is done for medications. Since the online vendor is not required to receive the written prescription, unlike medications, before dispensing the contact lenses patients will often report the wrong doctor to the online vendor in hopes that the prescription verification request will be ignored and they will get their contact lenses without a prescription. This happens a lot since patients merely need to continue to reporting incorrect doctor information until a doctor's office fails to verify or deny the request or hope that their doctor's staff will be too busy to respond and they'll be able to fill an expired or non existent prescription. All of this could be prevented and patients' health preserved if a written prescription is required to verify the parameters instead of requiring the doctors to answer a robocall or fax to verify something that was already verified by the written prescription.