16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
RE: the Contact Lens Rule -- time to be updated. As an optometrist that prescribes contact lenses, I can say with certainty that for most patients, you can't simply substitute a similar contact and get the same fit, comfort or ocular health. We are prescribing a specific contact lens for specific reasons, and there is no generic substitute. The contact lens sellers should not be able to change a patient's prescription to suit their business practices. ANY changes should be expressly authorized by the prescribing doctor. I don't see what education, training, and experience makes a contact lens retailer able to arbitrarily change prescriptions that doctors went through extensive education to be legally authorized to do. These requests for verification of prescription must be made through documented means. I file any request for verification in the patients file. The infamous "robocalls" from the elusive "Brad Scott" cannot be independently verified -- both whether the message was sent, or received, and what the doctor's response was. This is a huge problem for documentation / enforcement purposes. I have never attempted to prevent my patients from access to their contact lens prescriptions. However, as the prescribing doctor, my responsibility includes their continuing eye health, and the actions of some contact lens retailers interferes with that. My professional responsibility is to my patients, while the retailers is to their own interests. A revision to close the loopholes would serve to protect the eye health of our patients, the public.