16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00252

Submission Number:
paul williston
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Passive verification is an unreasonable burden that costs my clinic thousands of dollars per year in administrative costs and loss of business revenue secondary to such administrative time/effort. not only must my staff take the time to give a written prescription to a patient to take their business elsewhere but i must verify that prescription for another company bringing in the revenue my office lost, which often entails us correcting the order the patient input incorrectly. that is time and money spent by my clinic to regulate an industry that does not revolve around patient safety. we often have to reply day after day to requests for the same order. why is one denial for an expired prescription not enough that we must keep denying it over and over? because the online vendor wants to make a buck off the sale and has no one else regulating them so they send the request daily in hopes we do not respond so they can legally fill the order. we have also had orders filled by 1800Contacts (from the mouth of the patient) that we called and denied. we have no way of really confirming how many cases like this there are because we often don't see the patient for months and they never report getting the order they placed. they only complain when they can't get it. I have seen multiple cases of complications related to contact lens overwear from patients ordering incorrect contact lenses online. the lack of regulation is a safety risk and burden on the healthcare community. and for what? because some online site that doesn't pay sales tax can make a buck?!?! meanwhile i pay sales tax, more income tax than i like while i treat and cure complications from contact lenses purchased elsewhere on a daily basis. what do i recommend? ACTIVE VERIFICATION!!! what pharmacy allows you to walk in, pick your drug, they call whatever doctor you select out of the phonebook and if the doctor does not respond in a reasonable time the prescription is filled? sounds crazy, right? that's what is happening with contact lenses and i have multiple patients that can vouch that the complications associated with them(even when worn correctly) are very real, very painful and cost alot of money to treat. the current system is broken. even though 1800 contacts is probably paying for your lunch, i hope you, the FTC, finally wises up and fixes it for the sake of all patients and eye care providers.