16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #03918

Submission Number:
Stanley Woo
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Chairwoman Edith Ramirez Federal Trade Commission Office of the Secretary, Constitution Center 400 7th Street SW, 5th Floor, Suite 5610 (Annex C) Washington, DC 20024 Dear Chairwoman Ramirez: As Dean of the Southern California College of Optometry at Marshall B. Ketchum University, I am charged with leading our institution to train the finest optometrists in the country to practice to the fullest capacity of their scope with adherence to the highest standards of professional ethics expected of health care practitioners. First and foremost is an emphasis to put our patients' needs above our own personal interests. While contact lenses may be perceived by the lay public as a simple correction for refractive error it is classified as a medical device. The Fairness to Contact Lens Consumers Act (FCLCA) and the corresponding Contact Lens Rule assure that patients are provided with prescriptions. The doctor-patient relationship is sacrosanct, and especially important given the potential adverse health impact of contact lens overwear and/or abuse. I am writing in opposition to the new FTC proposal to require that all contact lens wearing patients sign an acknowledgement of receipt of a contact lens prescription and that I keep this form on file for years. The requirement is disrespectful, burdensome, and unprecedented for any health care profession to my knowledge. The unwarranted interference in the doctor patient relationship undermines the trust that patients place in our care. In my opinion, the focus of the FTC would be better served enforcing existing regulations of the Contact Lens Rule to crackdown on unscrupulous business practices of online contact lens sellers that have been putting the health and safety of patients at risk for more than a decade. On behalf of our optometry students and alumni, I urge the FTC to take into consideration the fine work of optometrists throughout the country who have provided high quality, professional, and ethical care to their patients. Please show some respect for the sanctity of the doctor patient relationship that we have earned by demonstrating integrity, compassion,and dedication to an exceptional patient care experience. Sincerely, Stan Stanley Woo, OD, MS, MBA Dean and Professor