16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00092

Submission Number:
00092
Commenter:
D. Penn Moody
State:
Indiana
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I believe in free enterprise and believe patients should have the right to buy their contact lenses where they choose. However, from an eye doctor's perspective, I have several problems with it: 1 - The reality is we get calls / emails for prescription confirmation at very odd hours from contact lens sellers. I believe they do this so they can conform with the letter, but not the spirit of the law. 2 - I have seen many cases where the contact lens wearer was allowed to order even though his prescription is expired. 3 - I have seen numerous cases of red eyes, some very serious with corneal ulcers, caused by patients reordering lenses without having their eyes examined. Many of these occur when a patient will order a large supply just prior to their prescription expiring. 4 - There is gross misrepresentation of the pricing of contact lenses by many online sellers. My suggestions: 1 - Tighten up the ruling so that there must be an actual written prescription / order from the doctor before the order can be filled. This is similar to pharmacy law. "Direct communication" is too broad of a term for this application. 2 - Make it so only enough lenses to last until the expiration date of the prescription can be sold. No more buying another year's supply two weeks before the RX expires. Again, this is more in line with pharmacy. 3 - Make it so contact lens sellers cannot make statements about what others charge for the lenses. Thank you for taking the time to read my comments / suggestions. Dr. Penn Moody