16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
In my experience, there are loopholes in the current Fairness to Contact Lens Consumers Act, that allow the original intentions of the law and the best medical interest of the patients to be side-stepped. For example, because of passive Rx verification, many patients are given incorrect prescriptions, or are allowed to order medical devices (contact lenses) with an expired or falsified prescription. It also allows the contact lens seller to sell the patients more lenses than are medically prescribed. Quantity limits should be considered. I don't know of a single eye doctor who would dispense a prescription for a medical device (contact lenses) that allowed the patient to purchase a 3 year supply, yet patients are able to purchase this and more by applying the loopholes built into the current law. The responsibility for providing verification of the Rx should be in the hands of the patient, not the seller. In many cases, for instance, patients are allowed to dictate their prescription into an online form, and the seller contacts the provider on their behalf to verify the prescription. If the provider does not confirm within 24 hours, the prescription may be filled anyway regardless of its accuracy and expiration. This is not in the best interest of the consumer, but rather the pocket books of the online contact lens seller.