16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #04037

Submission Number:
04037
Commenter:
Randall Fuerst
State:
California
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As an optometrist who endeavours to provide high quality patient care, my partners and I do our utmost to do so in a manner that is transparent, honest, and in the patients' best interest. We do so, while working to correctly code using ICD 10 , fulfill state and federal regulations, and all the CMS requirements. The FTC has the eyeglasses and contact lens regulations, that we fully comply with. Why is it that this new and more onerous regulation has to be put in place? Where are there abuses of the current statutes that would necessitate further draconian regulations? Contact lenses and contact lens prescriptions are readily provided to our patients. The biggest issue I and my partners face is the continual seeing of patients who show up with corneal damage due to cosmetic lenses bought from beauty salons and online providers who do not confirm validity of contact lens prescriptions. There are peer reviewed articles detailing the harm to consumers who trivialize contact lenses and lens wear (Dumbleton, et al.) ,which is the larger consumer issue. Please do not implement this further regulation. Thank you