16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00503

Submission Number:
Chris Swanson
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Thank you for reviewing this comment. I am a licensed optometrist and have personally fit thousands of contacts in my 16 years of practice. One thing is for sure. Each eye is different. Each eye has unique contours, tear composition, and unique optics. When we place a contact lens on the eye, if fit properly, we are able to create wonderful, healthy vision. However, when the relationship between a contact lens and the eye is not properly fit and maintained, I have witnessed patients permanently loose vision. This always creates a life changing and tearful moment for the patient. Since online competition has driven the price of contacts so low, there is not much profit for the doctors office. Patients assume that contacts are a commodity and with the help of the big online retailers, patients eyes are placed in danger. The big online retailers routinely fill invalid prescriptions and abuse the current system of verifying a patients prescription. Since they are not held accountable, this gives the online retailers a competitive advantage. Doctors face loosing their license for filling invalid prescriptions. Online retailers fill invalid daily without consequence. If the patient has any problems, the good ole family optometrist will be there to pick up the pieces. Unilateral pricing policy (UPP) introduced by some of the contact lens companies is an attempt to rectify this problem. Optometrist and contact lens companies train constantly to keep up with the changing contact lens technologies. UPP helps ensure that the value of all the research, development and training is not eroded by the big online retailers. Obviously, newer technologies have significant costs to bring to market. Contact lense companies should be able to compete freely and charge what their product is worth. It is not fair for the big online retailers to control the cost of contacts. Its ironic that the big online retailers don't like it when they have to compete on a level playing field with UPP. Doctors are professionally trained. Also, doctors are required by the state board to maintain the highest standards in managing the patient's care. Contact lens companies develop and great new products that benefit contact lens wearers. Big online retailers only take profits. Please make the online retailers play by the rules. Please advocate for our patients. Sincerely, Chris Swanson OD