FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #3300

Submission Number:
3300
Commenter:
Steven Loomis
Organization:
State:
Colorado
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
I am a doctor of optometry providing essential frontline eye health and vision care in my home community of Littleton Colorado. I am concerned that eye doctors and our patients are specifically being targeted by the FTC with the onerous rules proposed by FTC relative to signed documents and contact lens prescriptions. The new rule would cost my small business hundreds to thousands of dollars in annual compliance costs which would necessarily be passed on to patients needlessly. It is very concerning to me that this agency would focus on doctors while the Commission allows retailers who blatantly violate the law to operate unchecked. Your agency's own complaint data confirms that doctors comply with the law, a finding that Members of Congress have specifically recognized in Congressional hearings with FTC officials and further affirmed on March 23rd through passage of 2018 government funding legislation (Public Law 115141) and the following report directive: Contact Lenses-The [Senate Appropriations] Committee is disappointed in the FTC's decision not to include the proposed patient safety improvements related to the prescription verification process in its draft contact lens rule and instead impose new paperwork requirements on patients and doctors that are unnecessarily burdensome. The Committee directs the FTC to prioritize patient safety and consider enforcement mechanisms under its existing authority or revisions to the draft rule that address sales of excessive quantities of lenses, illegal substitutions, and communication challenges associated with prescription verification, including robo-calls. The Committee further directs the FTC to continue to confer and consult with other Federal agencies, including the Food and Drug Administration, to optimize its enforcement and consumer education activities. There are many voices purportedly paying consultants to voice unfounded claims about why you should continue with the proposed rule. I urge you to listen to the nation's eye doctors and other public health experts in recognizing contact lenses as a medical device and by joining with the Food and Drug Administration (FDA) and the Centers for Disease Control (CDC) in making quality care and patient health and safety a priority in Washington, DC. Sincerely, Steven A. Loomis, OD