16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #04271

Submission Number:
04271
Commenter:
Shelly Lapsi
State:
California
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As a practicing ophthalmologist, I am deeply concerned about proposals included in the Federal Trade Commission's proposed amendments to the Contact Lens Rule. While I would welcome changes to the Contact Lens Rule that prioritize patient safety, these proposals would create significant burdens on my practice and do nothing to address the fact that some sellers of contact lenses have engaged in business practices that jeopardize the safety of my patients. We have an EMR in place and it records if th prescription was printed. This ensures that patients can receive copies of their contact lens prescriptions. More paperwork doesn't translate to better customer service and just requires additional time that could be better spent in customer care. I have a small office and minimal staff. Additional time and man power necessary makes it more difficult to keep the cost and practice feasible. Such a burden should not be placed on small businesses that are already going to great lengths to comply with the Contact Lens Rule and do so despite serious concerns with the current prescription-verification system that we believe puts our patients at risk as more time is spent on un- necessary paperwork instead of fitting the patient This practice of unnecessary verification on a small staff generated more paperwork, that has to be scanned, subsequently shredded. Already we have paid employees to verify their insurance, spent money on confirming appointments, completed the refraction. To continue this on even smaller margins is not a feasible practice leading our practice to likely discontinue the practice Since 2004, the Contact Lens Rule has focused on making the sale of contact lenses as easy as possible. However, contact lenses are medical devices; this solitary focus puts patient safety at risk and places an unfair burden on small businesses, like my practice. I strongly urge the FTC to withdraw this proposal and re-approach the Contact Lens Rule with patient safety as its number one priority. Dr Shelly Lapsi Omni Eye Care [redacted]