16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #03747

Submission Number:
03747
Commenter:
James Young
State:
California
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
This regulation, especially the requirement for a separate patient acknowledgment form, would be burdensome for small department store based leased solo practitioner offices like mine which only provide exam services and cannot sell contact lenses or eyeglasses. I and many similarly situated colleagues are already constrained by time, lack of adequate storage space, and financial resources to properly administer this proposed regulation especially in an environment of growing managed vision care insurance usage, carriers' increased documentation requirements, and relatively low vision exam reimbursements. Since per my lease I cannot sell contact lenses, I strongly believe the overwhelming majority of my patients know they are completely free to shop their contact lens prescriptions. Indeed, I've observed many of my contact lens patients are already shopping online with their smartphones while they are still on premises, so given this behavior the extra acknowledgment form seems redundant and a waste of valuable time at least for my type of practice setting. Given the foregoing, I would urge the Commission to carefully reconsider the implementation of this proposed regulation. Maybe exempting practices which do not sell contact lenses from the required separate signature acknowledgment form or imposing this form requirement upon practitioners with a complaint history of anti-competitive behaviors like not releasing contact lens prescriptions in a timely manner or at all would be more sensible in satisfying the spirit and objectives of this regulation. Thank you.