16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00662

Submission Number:
00662
Commenter:
Matthew Lisenby
State:
Colorado
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
The following improvements need to occur in order to protect patient safety: The verification process needs to be improved. My office gets an unusually large number of calls beginning after hours on Friday and Saturday from the commercial contact lens retailers. This is apparently easier for the CL seller since the verification window will likely expire during that time before my office staff can ensure the Rx is correct, unexpired and valid. This will cause some proportion of patients to get the wrong lens resulting in complications to the eye and possibly permanent loss of vision. Maintaining the Rx for the particular brand of lens is important. When I have fit and verified the safety and efficacy of a lens, I am using a specific device fit to a variable biological tissue. switching from one brand(AKA fit) to another will fundamentally change the safety and efficacy of the lens. The material that a lens is made from is just one important variable in the fitting process. Every individual eye, patient and situation is different and the best fit, product, cleaning regimen and habits surrounding contact lens prescription are best made between the patient and the board certified eye care professional. The passive verification system is rife with flaws. A contact lens buyer could enter any eye doctor's office number and that request could be ignored (since the patient data doesn't even match a current pt) yet the Rx will be filled anyway! patients routinely get more than a 1 year supply of CL's from an Rx intended for 1 yr. This will lead to delay in eye care and undetected irreversible visual damage. Regarding spectacle Rx's and consideration of including the pupillary distance; this process does require time and equipment and is not a traditional part of a regular eye exam. Also,it is just one small part of fitting a pair of eyeglasses. pupil centers are rarely perfectly symmetric from the nose anyway and the fit of glasses varies more per frame choice. Requiring this of the Dr's office is just propping up an internet trend of online glasses sales. Matt Lisenby, OD