16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As an Optometric Physician for 30 years, my primary goal as a provider is to assure that I care for the persons who have been placed in my trust to the best of my ability and help to assure they appreciate the blessing of sight for as long as they live. We labor to assure that we provide the newest and most improved methods, materials and devices available to that end and as such support the importance of close monitoring and evaluation of our patients who choose to wear corrective contact lenses as the use of any such device is not without potential complication. As such it with much dismay that I understand that the FTC has appeared to have turned a blind eye to the ongoing unscrupulous practices of some of the online contact lens sellers who appear more concerned with their financial bottom line and less concerned with the health and well being of the patients we labor with every day to care for. Additionally to add such an absurd and time wasting policy as a document to the patient record (to retain for 3 years) indicating that the patient has received a copy of their prescription is an additional indication of a lack of understanding of the problem at hand. Standard of care would indicate that a patient who is wearing contact lenses should be examined annually to help guard against sight threatening complications that can occur in instances of non-compliance of care and reckless practices. Requiring additional documentation indicating the release of the contact lens Rx is not only adding additional time and labor to the care process but given that the document remains in the record 3 years could convey a confusing message to the patient and give them the impression that their correction is good for longer than is prudent for their health and well being. It appears to be a revision that has not been well thought out as it adds additional demands to an already bloated health care system, leaping to the conclusion that all providers are not ethical enough to comply with the requirements without an additional task. Please take time to reconsider this burdensome revision and the cost implications for the time and labor needed to address this issue.