16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I am very concerned about the passive verification part of the rule, which often seems to lead to no verificaiton. My optometry practice receives many unintelligible, hurried telephone messages from various contact lens sellers, in which it is difficult to identify the patient and/or the phone number to reply to. We receive poor quality faxes over the weekend when we are closed. Of most concern, we have patients report being able to order contact lenses almost ad infinitum, for multiple years without being examined, with no documentation of us ever having received verification requests for those patients. This includes patients with conditions such as dry eyes or diabetes, in whom going more than a year without an exam increases their risks of developing complications even more so than the average healthy contact lens wearer. The prescription verification process seriously needs to be made more active and more formal.