16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00251

Submission Number:
00251
Commenter:
Leahy
State:
Massachusetts
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
For the same reasons we do not allow patients (consumers?) to do the following, we constantly see problems and issues from doing so with contact lenses: contact the drug store and tell them on your say-so that you are using a certain drug, dose, frequency, concurrent treatments (we know the patients never confuse any of that), and then the drug store sends a fax or voicemail to what could be one of the doctor's offices he works at, which has 8 business hours to have the doctor review the prescription and check the expiration date, respond that the information is adequate and up to date, even if it is expiring TOMORROW, and furthermore if it is not responded to within 8 hr, the order is sent out (sale is made). Less patient ed=more noncompliance. Patient now has an extra year's supply of what is, in many, many cases intentionally, the wrong or defective product, often unintentionally being used incorrectly. Now, add in a recognized history of not really caring to sell the patient the correct or unadulterated product in the first place. So the patient loses in the end, after paying essentially the same price for inadequate care and inferior or dead-wrong product. Patients would buy no other name brand item this way - ask them if they google "Rolex" and buy a watch from the first site that pops up and claims "we got watches" and expect it to be a legitimate Rolex. They wouldn't. But they do it with something they put in their eye! They only do this because they are assuming YOU, the government is watching out for them, and you are NOT. You are enabling unscrupulous peddlers. This has been their history, but instead of bad lenses in a vial that they get and sell, we now get 100 or more bad lenses in a molded lot (yes, not all lots come out perfect, and guess where the rejects go!). This is what is going on despite everyone wishing someone that cares is watching over this. It is classic caveat emptor. In the end patients really do not save money due to similar pricing, and at times have extra office visit due to problems, but mostly just suffer unwittingly and then finally come in, or simply drop out of lens wear due to dryness, awareness or irritation from inferior product, lack of proper follow-up care and lack of proper compliance education (the industry loses almost 2 for every 3 new wearers, most all due to such issues, vs. the still-very-rare serious vision-threatening infections). And these peddlers are depending on that - no one sees the dropouts, they just fade away, thinking they cannot wear lenses anymore or it becomes such a chore because their eyelids have lost tolerance blinking over the inferior quality lenses. I see contact lens patients at a major Boston eye hospital and often when they are having problem with such product, they don't even make the connection until we ask where and when they got the lenses, and then and only then do they make the connection, again because they assume because is says"Acuvue" on the box that someone with authority is watching over the chain of custody of that product. Again, they would buy nothing else that way, so it has to be the missed perception they have that these are legitimate lenses. We spend half our time educating our patients and constantly re-educating them - no one wants to think about or clean or remove or replace their contact lenses until they are noticed, which is too late! Without this necessary follow up care, habits degrade rapidly, causing dissatisfaction and drop out due to symptoms or consequent increased and arduous effort required to continue to wear lenses. The very name of the act impunes our profession and personal integrity, that we have been cheating them all our professional lives. No doctor spends more face time or effort for less compensation or perceived value than this profession does, and this act is a slap in our face and a patient disservice, especially in this day of disposable lenses that are priced so similarly everywhere anyways.