16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #03772

Submission Number:
03772
Commenter:
Jasmeen Bhangu
State:
California
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Dear Chairwoman Ramirez, I am a student-doctor of optometry. Not too long from now, I will provide eye care in the form of prescription contact lenses for many of my patients. As a doctor, and in accordance with the American Optometric Association's Standards of Professional Conduct, my primary ethical responsibility is to place my patients' interest above my own. First, I would like to make clear that I will comply with the requirements of the Fairness to Contact Lens Consumers Act (FCLCA) and the corresponding Contact Lens Rule by providing copies of contact lens prescriptions to contact lens wearing patients at the end of the contact lens fitting process. I am disappointed to learn that my ability as a future doctor of optometry will be limited by this new rule, which will place an additional burden on my ability to properly deliver primary eye care to my patients. Part of my responsibility as an eye care professional is to form a working relationship with my patients to properly assess their needs. This new rule will undoubtedly compromise the doctor-patient relationship. In closing, let me make clear that those who violate the contact lens rule should face enforcement action. As a law-abiding, ethical student-doctor and as a student member of a national organization -- the American Optometric Association -- that advocates for full compliance and has sought FTC guidance for its doctor education materials, I fear being penalized in a severe and ongoing way for the potential actions of very few outliers. Accordingly, I respectfully request that the Commission look again at the costly impact of this burdensome proposal and, in doing so, give new and careful consideration to how it will harm tens of thousands of small and mid-sized eye care practices in communities across our country and serve as the basis for an utterly false and hostile presumption for my patients. Sincerely, Jasmeen Bhangu OD Candidate 2020