16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00579

Submission Number:
Kristin Reed
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Contact lens prescriptions should be treated like any other prescription because they are medical devices and can cause harm of worn incorrectly. If a person has diabetes and feels their medication is too expensive or simply doesn't like it, s/he would have to request a change of medication by their physician. Why are contact lenses treated differently? If worn improperly, a contact lens can lead to irreversible damage to the eye. These complications can often be managed, but it utilizes financial resources from insurance companies that could be avoided. A contact lens prescription should include the brand of contact lens fitted, base curve, diameter AND the number of boxes allowed to be purchased to fulfill a year supply. A person who used any other medication or medical devices cannot take a single copy of the prescription to multiple locations to have it filled, so contact lenses should be no different, given they are a medical device. When I prescribe a contact lens, I do so based on the patient's needs and goals for his/her contact lenses. I also take into account personal hygiene, overall eye health, and other risk-factors (such as if the patient swims on a regular basis because water in the eyes and contact lenses do not go well together) before fitting a patient in a certain type of contact lens. I also allow all patients return to my office with any questions or concerns regard the lenses. By allowing patients to order any number of contact lenses from any location is putting way too much risk for their eye health in the hands of individuals who have little to no training regarding eye health. The current 8-hour window to verify prescriptions is also too short. My office has found that often times the lenses have already been sent to the patient before we have a chance to reply, even in the 8-hour window. Additionally, prescriptions can and do change over time. Why should we not require vision to be tested routinely to ensure the prescription is accurate? It keeps people safer behind the wheel, allows a child's visual needs to be addressed to prevent the development of amblyopia, among many other scenarios. Healthcare needs to be affordable and accessable, but removing safety nets, such as making sure a patient is healthy in his or her contact lenses is not a step in the right direction. In addition to the health implications contact lenses have, if a patient is able to order any contact lens brand so long as the base curve and diameter are correct, there is no guarantee s/he will be comfortable in those lenses. By doing a proper fit and assessment, my patients are able to wear a diagnostic set of lenses to ensure comfort before purchasing. If there are any issues with comfort, vision, or insertion/removal/care of the lenses, I am able to address it. I have many patients who wins up preferring the comfort of one contact lens brand over another, and I am able to prescribe accordingly. I implore you to strongly consider making changes to this rule to ensure the safety and health of my patients, even if it may be a little extra work to order contact lenses. At least we will know that we are abiding by our optometric oaths to provide quality health care without compromising our patients' health in any way. Thank you for your time.