16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I am writing to express my dissatisfaction in the proposal by the ftc to require eye doctors to have a signed acknowledgement, which would "My eye care professional provided me with a copy of my contact lens prescription at the completion of my contact lens fitting. I understand that I am free to purchase contact lenses from the seller of my choice," would then need to be stored by the doctor for three years. This is an ill-informed and burdensome proposal that would target doctors and patients, rather than the abuses of the internet contact lens sales industry -and it must be stopped. The real abuse is the internet contact sales industry that still does not adequately verify contact lens rx before dispensing, dispenses supplies that exceed the suggested wearing time and substitutes contact lenses. Doctors take an ethical vow at the time of their graduation to care for their patients to the best of their ability, the internet contact lens industry vow is to generate more revenue, even at the cost of the eye health of their clients. In fact, they don't even refer to them as patients. Please reconsider this burdensome requirement on the doctors and patients. We are already trying to manage all of the regulations of the ACA and the PQRS/MIPS/MACRA, HIPPA and other alphabet soup programs mandated by the government. This new proposal will do nothing to improve patient outcomes. In this day and age, patients already know they have a choice and we release their contact Rx when the fitting has been finalized. That should be sufficient.