16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00173

Submission Number:
00173
Commenter:
Peter Pham
State:
Virginia
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As a new doctor, I have seen many instances when this rule has been violated. Constantly the office phones are ringing not to take appointments or answer questions that patients have for the doctor but to field automated call from these third parties to verify out dated or even incorrectly prescribed medical devices. We as doctors have spent years learning about the health of the eye and still continue to educate ourselves about the latest advances in technology just so we can safely fit and prescribe the exact lens that will be not only clear but healthy for our patients eyes. We educate we train we preach to our patients the importance of proper care and replacement schedule only to have our prescriptions manipulated and abused. Too often I have seen third parties violate this rule by filling prescriptions for patients whom have never received an exam from me let alone a contact lens fitting. I've seen my prescription filled for years beyond the expiration date. Contact lenses are a medical device for a reason and when you allow patients to select there own brand adjust there power and wear them for longer you then allow patients to self prescribe medication. No where in the world has there been success when patient prescribe medication for themselves because they are not doctors. They have not gone through the extensive training and education required know what is best for them. Unless there is a way to regulate those third parties from taking advantage of this rule and bend it to make more money at the expense of the consumers ocular health and sight than this rule needs to be removed because all it does is allow the public to do further harm to themselves and others around them. How many more people need to go blind or how many more vision related accidents need to have before enough law suits fill our court rooms before the government takes responsible action and let the doctor do what they have been trained to do and don't let big business bully them into making an irresponsible decision that affects the public's health.