16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00234

Submission Number:
00234
Commenter:
Jeffrey Kubo
State:
California
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
The current Rx verification process needs to be modified. There is a huge loophole in the current process that some patients take advantage. I frequently get Rx requests from a Sunday fax and because my office is closed on Monday, I'm unable to verify the RX until Tuesday. Because the allotted 8 hours is past the retailer has already filled the Rx (whether it is accurate or current) already. Many times the patients that Use this loophole are the ones where their last exam was 2-5 years ago. These are the patients that need to be seen annually because usually they are the ones who are noncompliant with their lens care and disposal schedule. I give a copy of the patient's contact lens Rx to every patient so the patient should be able to email a copy to the retailer just like what is needed at a pharmacy. One of the retailers has a commercial that tells the patient that they have their contact lens Rx. All they have to do is look at the box. When retailers run their business practices like this, one has to question whether or not they have the patients best interest in mind. It is already difficult to explain the potential harm noncompliant contact lens wear is and that they are medical devices that must be monitored at least once a year when you have retailers that are trying to sell the patient these medical devices like they are a pair of Nike's. I do not sell contact lenses to patients, I only perform the medical portion of their eye exam so there is not a conflict of interest for me. I have a problem when I don't see a patient for three years and have they have a red eye that is a result of noncompliant contact lens wear and I ask them how have they been getting their contacts and they tell me sheepishly, "through the Internet." Please take this into consideration before you sign off on a new Contact Lens Rule.