16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Dear Commissioner: I am opposed to the proposed changes to the Contact Lens Rule. The rule as proposed does nothing to protect patients and only adds intrusive clerical burdens. Optometrists follow--and will continue to follow-- the rules regarding the dispensing of contact lenses. I believe the rule changes should focus on unscrupulous marketing and business tactics that put patients' eye health at risk. An example of the new rules putting unnecessary administrative burdens on optometric offices is the requirement to keep forms indicating that the doctor had met the requirements of the law for three years. What problem is this requirement aimed at helping? I believe the rules should be aimed at online retailers. A 2015 consumer survey found: 1 in 4 reported receiving a different contact lens brand than had been prescribed. 1 in 3 reported an online retailer advised them to substitute a non-prescribed lens due to supply issues. 1 in 3 reported that they purchased contact lens with an expired prescription. The proposed changes do nothing to solve these issues. These issues are what threaten the public's eye health, not doctors telling patients where they can purchase contact lenses. My job as an optometrist is to ensure my patients' eye health is priority. Incorrect contact lenses threaten a person's vision and eye health, although many take that for granted. I believe that patients' should have choices about where to purchase their contact lenses, but they shouldn't have to worry about getting the correct lenses every time. I have no problem giving a patient his or her contact lens prescription as long as it is going to be filled correctly. I think this legislation is creating more problems for patients and not solving any of them. Thank you.