FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
Dear FTC Commissioners, Requiring doctor's offices to have a form and keep files documenting the provision of a patient's contact lens prescription does nothing to solve the problems regarding contact lens prescriptions. For one, having provided the prescription does not mean the patient will have it when they need it. Secondly, patients are already ordering their contacts frequently without prescription and being provided contacts without prescription from numerous online sources. Already, doctors are required to provided contact lens prescriptions, and can be found at fault by their state boards for not providing them. A new issue is an entire contact lens business, Hubble, built around providing their brand contact lens which no doctors are prescribing. Lenses that are old technology, just cheap because they are cutting all corners, even the eye exam and evaluation. The provision of a contact lens prescription comes when the doctor has evaluated the health of the eye, the measurements of the eye, the advisability of contact lens wear, provided education regarding contact lens wear, and importantly, evaluated the fit and effects of said contacts on the eye, often requiring a follow-up visit to assess. Therefore, on the day of the initial exam assessment, there is not yet a contact lens prescription established. The patient must return wearing the lenses for the assessment that results in the provision of the contact lens prescritpion. In some cases, the patient fails to return for this important visit, and so there is no contact lens prescription finalized. This proposed requirement of contact lens prescription release and consent of provision becomes not so clear, confusing to the patient, the misunderstandings becoming more adversarial while the doctor is just trying to provide the best, most responsible care. The problems with contact lens prescriptions, a medical device that has the potential to cause injury, are mostly resulting from the online market providing them without prescription, oftentimes without the patients even having had any eye exam at all. Do not add another misguided form to our offices, on top of the ever- present HIPAA agreements, and the necessary medical and financial forms that we all face every time we go to a doctor. Please do not add this unnecessary and confusing burden. Sincerely, Lori Beals, O.D.