16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #03959

Submission Number:
03959
Commenter:
Sheila Soltani
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 an optometry student at the University of California, Berkeley School of Optometry. We are alwats taught to 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. This way, they remain knowledgable about when to return for their eye exam and about how to safely care for their contact lenses. I am incredibly disappointed about the new FTC proposal, as it requires that all contact lens wearing patients sign an acknowledgement of receipt of a contact lens prescription and that our clinic maintains this form on file for years. This requirement seems to be a heavy-handed step which assumes that all doctors of optometry are not complying with federal law. It also would seem to disrupt the doctor-patient relationship by communicating to patients that they should be wary of their physician and assume that their doctor is a violator of federal law. We alwaysnmake sure that each patient leaves with a copy of their contact lens prescription with all of the necessary details.. I believe those that violate the contact lens rule should face the necessary disciplinary action. As a 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 a 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, Sheila Soltani