16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00550

Submission Number:
00550
Commenter:
Rebecca Loerzel
State:
Minnesota
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Passive verification needs to be eliminated. Contact lens orders should be handled the same way pharmacy orders are, where a copy of a valid prescription is necessary. Doctors are required to give a copy of the prescription to the patient when the fitting is complete, and I believe it is extremely rare that this does not happen without the patient even requesting the copy. I have seen MANY patients get prescriptions filled that are incorrect or long beyond their expiration date. We receive verification requests from patients that were in our office two days before and clearly know their prescriptions are expired, and I suspect most of these are filled whether we confirm/deny it or not. Also, eight business hours is simply not a reasonable amount of time for verification, and often is not even honored. Most offices are busy and may not be able to respond this quickly. Faxes may not be received at all. Phone calls are intentionally very long and muffled so we cannot obtain the proper information. It is well known that patients will provide false provider information to take advantage of the passive verification. My colleague once ordered contacts for herself, then sent the form back indicating the prescription was not valid, but boxes were still shipped to her. I once called a patient immediately after receiving a fax, so I could clarify something with him prior to sending it back, and he said he got a shipment email from the website less than two hours are placing his order. I have also seen many patients receive boxes in their old prescription instead of their new one, even when we have sent back a verification form. (Many requests we receive contain the previous Rx instead of the newest one.) Continually wearing contact lenses while avoiding eye exams is dangerous to the patient's ocular health. Many complications are asymptomatic until significant irreversible vision loss has occurred. Shipment of incorrect lenses may cause damage to the eyes and vision. Passive verification simply is not safe.