16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00226

Submission Number:
Michelle Sancho
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Over the years, I have seen abuses by patients and online vendors, alike, with this Rule. I've had numerous patients who admitted to having contact lenses "just shipped" to them (without doctor verification) for up to 5 years. Some of these patients have developed severe eye infections, necessitating repeat office visits, expensive medications to treat their conditions, loss of ability to work due to pain and some left with permanent scarring of their eyes causing loss of vision. One of my patients with keratoconus (degeneration of the cornea) admitted to ordering several gas-permeable contact lenses from 1800-Contacts, which were shipped to him at his request over the span of 4 years. By the time he came in for an exam, his best corrected vision with a gas-permeable contact lens degraded from 20/25 to 20/60 due to extensive scarring and damage to the cornea. The online contact lens ordering companies have degraded the public perception of contact lenses to be perceived more as a commodity and less as a medical device that needs to be monitored on a regular basis. Patients are repeatedly surprised when they have eye damage from a contact lens, particularly when I inform them that it is illegal for these online vendors to keep sending more contact lenses without doctor authorization. As for the time frame for doctors to verify prescriptions/respond to requests...MANY times, lenses have already been shipped (before my 8 hour, business hours window) when we call to inform these online companies that the prescription has expired (or worse, that this person was never a patient of our practice). Since there is no real punishment to the company for shipping without direct approval and the patient is happy to have more contacts without evaluation from the eye doctor, the eye doctor is demonized as "money hungry" when we complain. We are trying to protect our patient's eyes from possible damage. It is the same as a Primary Care Physician requiring an annual physical to monitor medications taken for Hypertension, elevated cholesterol, etc. before the patient is authorized to fill his/her prescription. Additionally, the concept of "generic" contact lenses to be substituted for brand contact lenses is also an unsafe concept. I have many patients whose eye cannot tolerate different materials, diameters, base-curves, oxygen transmissability, etc. Just because a generic lens is available in the patient's power does not make it a safe/good lens for that patient. Different lenses/materials fit differently which can cause damage if the generic lens is not professionally evaluated for safety with that patient. Contact lenses are medical devices which can absolutely cause permanent damage to the eyes when not monitored properly, by an eye doctor, with a microscope (slit-lamp). Online "eye exams" where the patients are not properly evaluated with a microscope by an eye doctor, is another risk to the population of contact lens wearers.