16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #03741

Submission Number:
03741
Commenter:
Ryan Schott
State:
Florida
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Currently most states have laws stating that a contact lens prescription is released upon the completion of a "fitting." Even in a rare instance where a prescription release is overlooked, no objection is ever given to release of the contact lens prescription. The prescription is a part of the patient's medical record, and therefore the patient is always entitled to it. It is burdensome and costly to require separate and unnecessary signed documentation regarding the release of a contact lens prescription. No other medical profession is required to obtain separate documented consent for the release of the patient's own record to the mentioned patient. It should be evident that this proposed amendment to the current contact lens rule benefits no one except online contact lens vendors. We have never seen abuse in our office from local contact lens suppliers, opticals, or pharmacies. However, we often see attempts made by internet contact lens retailers to fill expired prescriptions for patients. I would also add that the 8 business hour rule (the timeline we have to verify a prescription request) should be enforced. Often, the online retailers are filling prescriptions before they even receive verification, which is illegal. Adding more of an administrative burden and unnecessary inconvenience to doctor's and patients with the passage of this amendment, will incur more costs, and shift the burden of those costs to patients. The laws in my state (FL) already state I must release a prescription once a fitting is complete, which we do. If any amendment must be made, perhaps instead we could make it national policy what my state has already adopted? Why don't we make it law that the prescription must be released, why do we need to have in person documentation saying the prescription has been released? This seems like its only an issue to the online contact lens vendors who want to have copies of the Rx, so that they may fill them as needed without regards to the health and well being of my patient's eyes. I ask that you continue to help me protect my patients by stopping the illegal selling and abuse of online contact lens vendors, and NOT adopt this amendment. Thank you so much, Ryan Schott