16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
To the committee; While I agree with the American Optometric Association's points regarding the proposed modifications to the CL act, I can only say that from a practicing physician's standpoint, I find the proposed regulation overkill for a problem that is exaggerated by contact lens retailers. All of our patients have the right AND the ability to take their CL prescriptions to the provider of their choice. These companies wouldn't be making billions of dollars a year if that wasn't the case. And now, with private equity companies purchasing most of the retailers, the mantra is to maximize corporate profit to make the investment lucrative. To make private doctors have pts sign a document that states they not only received their Rx, they were told they could go elsewhere AND have to keep it on file for three years is just putting an undue burden on our practices. If the patient does not receive their prescription or feel they weren't allowed to purchase their CL elsewhere, a complaint should be file and the doctor help responsible for non-compliance. But to make every practitioner do what is being proposed is administrative over-indulgence.