FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #3255

Submission Number:
Garrett Milner
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
Dear Committee, with love and respect, I request that you do not propose an additional paperwork burden on our offices requiring us to document that patients were given their prescription. I find it impossible to believe the vast majority of patients are not given their prescription routinely. This simply is not a common enough issue to warrant such a burdensome new rule--plus, it makes us look terrible in front of the patient--"Please sign this Ms. Jones, the government doesn't trust us to follow the law." In this modern information age, patients are keenly aware they can get their contacts wherever they like. Any patient with the barest internet skills can get contacts without a prescription--I, like all eye doctors, commonly see patients who have been illegally sourcing their contacts from 1-800-Contacts and the like for years without a valid RX. A new player, Hubble, doesn't even bother to use the underhanded business tactics of 1-800-contacts--they simply substitute their inferior product, no RX needed! I had a patient today who orders "Daysoft" contacts from the UK, no Rx needed! Please take time to see things from the care provider's perspective: running a busy clinic, following all the rules, scrapping to pay the bills in an era of stagnant or declining reimbursement, our employees must often take time away from patient care to answer robo-calls from 1-800-Contacts or Hubble--you can imagine our exasperation when new proposed rules would INCREASE our busywork, without addressing the glaring ability of large internet retailers to flout the law with seeming impunity. Remember, the IPO filings of 1-800-contacts openly admit a possible danger to their business model is the fact they don't follow the law in man cases. Don't let them change the law to get their way. I beg you, please take any energy or resources that would be targeted at increased burden on prescribers, and direct it towards unscrupulous internet retailers, such as Simple Contacts--here is an exchange I had with that company, please note how they do not follow the law, demanding I place an order of product to get RX: "ME: Hi guys, I want to take your test, but I'd like to buy my contacts somewhere else. How can I get a copy of my prescription? SIMPLE CONTACTS: We'll send you a copy of your prescription when your first order with us leaves the warehouse. And we're more than happy to price match any of our competitors so that you're not losing any money on that first order! ME: I am confused. It's a national law that I get my prescription after the test, no order necessary. I can't remember the name of the law... I googled it: https://www.ftc.gov/tips-advice/business-center/guidance/contact-lens-ru... so in conclusion, I pay you guys $30 and get a copy of my prescription? SIMPLE CONTACTS: My apologies for being unclear! You're right, we'll give you a copy of your prescription either way, I just wanted to let you know that we can price match, and standard shipping with us is always free, so there's rarely a reason not to complete a full order! If you'd just like a copy of your prescription, just place an order with us the normal way, then let us know that you only want your prescription. We'll release the hold on your credit card for the product, only charging you for the prescription." THANK YOU FOR YOUR TIME, please trust us to do right by our patients.