16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00553

Submission Number:
00553
Commenter:
David Holler
State:
North Carolina
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
This post is to comment about the current FTC Contact Lens. It is my understanding that there are online retailers who wish to change some aspects of this law and I have concerns that they do not have the patient's best interest at heart. Not a single day goes by without coming across some case where an online retailer has clearly skirted around this rule. Today was one such day so I am going to comment on today's patient - whom is not unlike other such patients that we see. Today's patient was last seen in our practice August 2012. At that time her eye pressure was high and she was considered a glaucoma suspect. She wears monthly contact lenses for up to 2 months and sleeps in them occasionally. We sold her a one year supply at that time (told her to replace monthly) and she has purchased contacts on 2 later occasions (from 1800Contacts) - even though her contact lens prescription was expired. We never received a phone call or fax to confirm her prescription or to verify if it was valid. Today her eye pressure was higher and her optic nerves have changed. We diagnosed her with glaucoma and started her on eye drops to lower her eye pressure. Examination also showed 4 scars in her cornea from corneal ulcers (normally caused by contact lens overwear). She recalled occasions when her eyes were red and bothered her but she never sought treatment. This patient is an example of someone that should have been seen at least annually. Had 1800contacts faxed us a prescription verification or told the patient that her prescription was expired we might have been able to prevent the infections and treated her glaucoma earlier. We will find out at her follow-up if she has developed any visual field defects from the high eye pressure. She told me that she would have come annually if she new it was this important (she dropped her home phone line and changed her email so we were unable to send her a recall). She said that 1800contacts assured her they would "contact her doctor's office." I assured her this never happened. This is a typical patient. We discuss seeing them back annually. When they run out of contact lenses they cannot recall how long it has been since their last visit so they just go online to try to order. They think they do not have time to schedule an appointment and they feel like the vision is fine. Unfortunately we are left with no opportunity to discuss their risks for glaucoma or discuss their corneal health unless they come in for an examination. We do not mean to hold their contact lenses hostage but it is sometimes the only way to bring them in to discuss these things. It is no different than a phsician requiring an examination to renew a medication (like birth control or a cholesterol med.). We need to see patients annually to evaluate their eye health before releasing a contact lens prescription. If the FTC Contact Lens rule is to change - it needs to become more strict with how it polices online sales. Retailers are altering their tactics to skirt the law and this continues to compromise the health of millions of eyes.