16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00123

Submission Number:
00123
Commenter:
Zierlein
State:
Arkansas
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As a practicing optometrist, I feel the passive verification aspect of the law is widely abused and puts my patients' ocular health at risk. I have seen numerous instances of prescriptions being filled without any verification at all, patients actually receiving contact lenses before a prescription has been verified, orders being filled for a different type of lens simply because they are cheaper, and excessive amounts of contacts being sold thereby allowing patients to go 3, 4 or even 5 years without having an eye exam. I have also experienced patients deliberately providing false prescriber information knowing that with the passive verification process their prescription will like get filled. These practices leave patients vulnerable to serious complications and infections, some of which can cause permanent blindness. I think a system that treats contact lens prescriptions in the same manner as all other drug prescriptions would be much better (a written copy must be provided or sent electronically from the prescriber, number of lenses and refills stated, whether or not a substitution is permitted, etc). While I understand the law was inacted to protect patients' ability to price compare, I feel that when it comes to medical devices that safety should be the main priority, and with the current system unfortunately it's not.