16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00505

Submission Number:
00505
Commenter:
Leslie Falcon
State:
Arizona
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
This past week alone, I received 3 requests for ex verification. One expired 16 months ago, one 2 yrs and another was from a patient I had never seen. When contacted, the first patient had already received his lenses. Where is the regulation here? If this happened with a prescription medication, there would be dire consequences, Contact lenses are not like band aids, A contact lens is a medical device that sits intimately against tissue which, like the rest of our body, is dynamic. An improperly fit and improperly cared for lens can cause blindness, Blindness. There is a huge public health cost that must be factored into any rule making or changing. I also think that passive verification with today's technology is suboptimal. Many offices are not open 5 days per week, therefore 8 hours is insufficient time to respond to a faxed request. In addition, each patient is provided a written ( and now electronic too) copy of their rx. Why are we treating a contact lens rx any different from any other medical prescription? If I walked into a pharmacy and asked for any medication without a physical prescription, e prescribed or otherwise, I would not receive my desired medication.