16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I oppose the new FTC proposal to require that all contact lens-wearing patients sign an acknowledgement of receipt of a contact lens prescription and that the form be kept on file for three years. This requirement is a heavy handed step which presupposes that I have not been complying with federal law. It also disrupts the doctor-patient relationship by communicating to my patients, without justification, that they should be wary of myself, their Optometrist, and presume that I have been a violator of federal law. Additionally, while the FTC seems to dismiss the potential burden on myself and follow physicians for complying with this requirement, the proposal will undoubtedly add new costs for doctors and patients. It would require an additional step in the patient engagement process, which would necessitate ongoing staff training to ensure that doctors are meeting this unprecedented requirement.