FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #3035

Submission Number:
3035
Commenter:
David Sterna
Organization:
State:
Ohio
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
The necessity of the proposed is without merit. The knowledge that patients may choose to purchase contact lenses from a provider of their choice is universal. Combined with the fact that vast majority of contact lens prescribers already abide to the original FCLCA, the necessity of the proposed changes are without merit. The real issue that needs to be addressed are the unethical business practices of internet contact lens retailers that are designed to game the system and skirt existing regulations. The practices include late night and weekend robocalls that are impossible to respond to in a timely fashion, falsely claiming to be a patient's authorized representative to obtain contact lens prescription copies, and making multiple contact lens verification requests for the same patient. Our office has already experienced all three of these deceptive business practices by internet contact retailers. The FCLAC needs to re-worked to treat contact lenses as prescription medical devices as originally classified by the FDA. I would suggest that robocalls be banned. Also, the request of contact lens prescriptions by individuals other than medical professionals be banned.