16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
This rule simply needs a minor adjustment. Contact lens sellers, particularly online sellers, should be required to make multiple attempts to verify the prescription before selling the contacts. The ability to automatically sell contacts even without explicit confirmation of the prescription is a dangerous practice that encourages patients to think of contacts (and glasses for that matter) simply as a commodity rather than the medical devices that these things are in reality. If I am trying to obtain a contact prescription for a patient, I have to keep calling/faxing until I can receive a confirmation. Why should the online companies receive an exemption from that? Also, I would love to see the automated systems for verification abolished. They are a pain to deal with, are hard to hear, and do not provide sufficient information to guarantee success in obtaining a confirmation. Automated fax systems are also difficult in our practice as the fax machine is not in a frequented area of our business and sometimes have the same problems. A simple, quick phone call is much easier and would result in faster turnaround times for the patients as we could provide instant verification.