16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #04031

Submission Number:
04031
Commenter:
Rodney Melgard
State:
Minnesota
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As a practicing Optometrist for 36 years I have seen my share of federal and state mandates. And I may have been annoyed abit but I would eventually adjust an move forward. I have been confused the last few years in regards to the FTC approach to contact lenses. At his point in time, contact lenses are a prescriptive device. As such, licensed practioners are responsible for the evaluation of the cornea, design of the lens and continuing care of the patient's corneal health. It takes a prescription to order and wear appropriate lenses. Can you imagine Internal Medicine doctors putting up with online pharmacy vendors dispensing Insulin, high blood pressure meds and Plaquenil as they feel appropriate because they can circumvent prescribing guidelines? I don't think so. I am honest with our patients and offer them a lens Rx so as to purchase lenses from any retail site or online vendor on this planet, or on Mars. Or if they prefer convenience, customer service and competitive fees they can purchase at our office. I never withhold prescribing information and I would tend to assume moat of the 25,000 practicing optometrists and contact lens techs would do the same. We are burdened during our day with an overabundance of demands on our time related to computer patient record systems and medicare guidelines. We don't need another signature form which achieves nothing to add to our day. Unscrupulous online lens vendors push for these actions. they send prescription requests on a Sunday and we have 8 hours to respond. Nobody at your agency seems to have any concern for the function of a health care office but online vendors get your ear. This is about providing another opportunity for those vendors to take a script and squeeze a margin out of it. In our office we take care of patients and we make a living. Online vendors are all about a sale with no service and no concern for a patients eye health. And if there cared , they wouldn't fill 3 year old prescriptions like I have seen before. I feel this signature request is unnecessary, nonproductive and and of no use to patients or doctors....but maybe to politically connected online corporations. Vote NO at the upcoming hearing . Thank you. Respectfully, Rod Melgard, OD