FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #2723

Submission Number:
2723
Commenter:
Michelle Martinez
Organization:
State:
Texas
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
As an optometrist with sixteen years of issuing contact lens prescriptions, I strongly oppose any future FTC proposals that would have a business burden both to my patients and me. The new proposals for signed acknowledgment and document storing requirements for 3 years after each contact lens exams not only incurs unnecessary monies. It also requires me and my staff to spend more time on unnecessary administrative issues versus addressing the ocular issues that brought them to our clinic. As an eye doctor who follows the Fairness to Contact Lens Consumer Act, I have practiced for the first thirteen years of my career in a leased retail setting that prohibited me from selling contact lenses To the public. Please note that my patients are not confused about the various retail options for buying contact lenses. I have left that setting and have been selling lenses to my patients since October 2015. I have always given patients a copy of their prescriptions as soon as parameters were determined and when repeated requested. While some data shows that 40% of consumers buy contact lenses from independent optometrists, that still leaves 60% of consumers in the market free to purchase wherever they want. As a business owner, I have had to work extremely hard to establish loyalty in a optical industry that is changing constantly. These unfounded claims that seem to support these new proposed requirements only seem to try to counter the patient loyalities that we have worked so hard to earn. So, yes, I oppose these new proposed requirements because they do nothing to improve the services that I offer to my patients.