16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
To whom: I am a practicing optometrist who does follow the rules and hands a written Rx to every patient. I believe that patients have no trouble receiving written contact lens prescriptions in the US. It appears that you have been misinformed by online contact lens dealers. The real issues are online vendors lack of willingness to follow proper protocol in verifying contact lens presciptions and their perfect willingness to do anything to make a sale regardless of what is in the patient's best interest. They do work around the verification system in order to fill rxs that are long out of date, now even substituting at will whenever they wish. These issues do generate a significant number of patient problems including red eyes right up to loss of vision in patients. There is no concern for the patient's welfare, only for making another sale. Doctors are ALWAYS willing to help patients but are not always willing to help online sources make a sale when it is clearly not in the patient's best interest (for example, ten years after last being checked a by a doctor). You have been misled by these corporations who wish to make it easier to violate the law and more importantly hurt patients. In addition, the additional monitoring required in your current proposal is both burdensome and unnecessary. You need to dig deeper into what is going on here and really get to the bottom of the real issues. The current proposal is misguided and will serve no one but those who wish to circumvent the current laws and without regard for patients' welfare. It needs to be reconsidered.