16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Comments regarding Fairness to CL consumers act. CL internet companies as a whole disregard expiration dates. 1-800 CL is the worst offender. I have patients that fill the expired CL rx for years, returning only when they have a problem. This happens as 1-800 requests refills on Sundays, Sat nights and days when they know you are not in the office. They also use a phone verification system that is difficult to understand and disruptive to the office. I have to think they use the phone verification system to avoid leaving a paper trail of their abuses. The Center for Disease Control (CDC) states that eye infections, often resulting from improper CL care send a million people to the doctor each year. On my annual visits, I always stress the importance of compliance with proper lens care in order to prevent serious complications. Additionally, 1-800 CL is campaigning to be able to switch patient's out of lenses that were prescribed for them to another brand of their choosing based on base curve data alone. Bad idea. The base curve is only one factor in CL fitting. The material, edge quality and other factors contribute to CL success. I give a CL rx when a patient has tried the lens and is successful with that lens. I cannot guarantee that a patient will be able to wear another lens safely and comfortably. If they cannot wear the lens, they face an economic loss, having bought lenses they cannot wear. I don't think that is fair to patients. Allowing 1-800 CL to take over the care of patients is not in patients well-being as the company trivializes all aspects of CL wear. Profit, not patient well being is the prime motivation of 1-800 CL. As a Costco affiliated doctor, I do not sell CL and have no economic interest in CL sales. I am concerned for the well being of my patients.