16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #03642

Submission Number:
03642
Commenter:
Marcia Dettloff
State:
North Carolina
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
This letter is a comment on the upcoming Contact Lens Rule update. Requiring the additional administrative burden of having patients sign an acknowledgement that they received their contact lens prescription is ridiculous. As it is, patient's seldom send in their Rx to the online companies anyway. We are required to give an Rx to every patient AND we are still required to take time to verify the CL Rx at no charge? Companies like 1800contacts make it as time consuming as possible to verify the Rx, presumably so offices won't bother interfering with their sale. Instead of giving the patient's name up front so we can locate the patient file (assuming it is even our patient) their recording first goes through a long script about contact info where to fax the verification and warns that the fax number may have changed so you have to listen to it. After that it gives the contact lens rx info and, after nearly 3 minutes, it finally gives the patient's name. I routinely see patients that have been ordering contacts online for YEARS without having an Rx and those are only the ones that finally come in for an exam. I've had patients come in wearing different brands of contacts and different powers than what was prescribed. What is being done about that? The success of the vast number of alternate retailers is evidence that patients are aware that they don't have to buy their contact lenses from their eye care provider. Rather than burden every practitioner with additional paperwork, enforce existing laws against those that don't comply. I urge you to abandon this unnecessary rule addressing a non-existent problem. Sincerely, Marcia Dettloff, OD