FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
The proposed amended Rule is unconstitutional in the following ways, 1. State sovereignty a. Every state has its own professional board to decide what are the regulations of prescribing and medical records keeping. b. There are no health risks of patients regarding current regulations of individual state's contact lens laws. c. All prescriptions are released to patients after contact lens fitting and follow up. d. There are no public policy concerns to support the proposed amend Rule. e. There are no conflicts with present state laws and federal law regarding Contact Lens Fairness Act (Act). There is no state law obstruct any of the Congress' purposes and objectives regarding the Act. f. Current state regulations of every state require doctors to release prescriptions to patients so patients can go to any place to have the contact lenses fill. Current regulations do not interfere any commerce. In fact, current regulations encourage commerce. 2. Affect livelihood of prescribing parties. a. Unnecessary overhead incurs from this proposed amend Rule is between $28,800 and $46,000. No medical doctors, dentists, chiropractors, or nurse practitioners or any other health care professionals need to have a copy of "receiving prescriptions acknowledgement" for patients. Here, the FTC does not have (1) a patient health risks prevention purpose, (2) any public policy reasons, or (3) any legitimate commerce concerns. Enact this proposed amended Rule shall not be the best interests of the people. More importantly, the FTC should concentrate on the enforcement of the Act or other probabilities to combine advance technologies to increase the compliance of the Act.