16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00649

Submission Number:
00649
Commenter:
Rubow
State:
New York
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
With regard to item #10, modifications should be made to reduce the cost to small businesses by requiring on-line retailers to request verification, specifically, 1800contacts, through a route that is intelligible, which includes a fax, or a live person. Right now, we mostly receive unintelligible computer generated voice recordings, requesting prescription verification. Many times it is impossible to make out any of a number of items in the message, including patient name, address, brand of contacts etc. This then requires a call to the "Dr. Verification"phone number, which is a recording asking for a phone number to be called back. We then have to wait for someone to return the call. In addition, it should be required that if an actual live person leaves a message, they speak slowly and clearly. Very often, if the entire recorded message is not completed within the allotted time on our answering machine, we then receive a message from an actual live person, where the person speaks so fast, it requires playing back the message 4 or 5 times in order to be able to get all of the information. All of this back and forth can take up an entire hour, which, being a small office with one doctor, unnecessarily wastes time and money. In addition, we have experienced instances, where a patient may have initially placed an order with 1800contacts, but then chose to purchase from us, but yet were told that they could not cancel because the order was already placed, or if the rep allowed the cancellation, said the patient could not get a refund, but would receive a credit for a "future" purchase. And this is all within the 8 hour window. This is neither fair to the patient, nor the small business owner, who has a right to sell the contacts to their patient. 1800contacts has filled prescriptions, even though the patient specifically requested us to cancel the order on their behalf. This issue needs to be clearly addressed, as to what the rule permits in situations such as this.