FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #3367

Submission Number:
3367
Commenter:
David Seibel
Organization:
State:
Missouri
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
Dear FTC, I am an optometrist who owns an independent private optometric practice in St. Louis, MO. I am past Chair of the American Optometric Association Contact Lens & Cornea Section. I have lectured, written and performed research in the contact lens field globally over my 30 years of practice. With that back ground, I express grave concern for the proposed changes of the Contact Lens Rule. As an independent private practitioner, I am already almost choked out of practice by the increasing compliance demands put upon a doctor with MU1,MU2,HIPAA, pre-authorization on every patient pharmaceutical prescription written and constant battles with medical insurance payments. Adding another burdensome contact lens regulation stating the already obvious fact to my patients that they can get their contact lenses elsewhere and having them sign an affidavit to keep on file for 3 years is yet another governmental over reach. All my patients are well aware and reminded daily with extensive marketing by direct mail, radio, emails, TV ads and social media to buy their contact lenses elsewhere. My and my staff's time is already stretched to the limit. If we are forced to comply with these regulations, we will again be spending more time with government regulations and less time providing badly needed care to an ageing public with daily increasing health care needs. I have a much greater concern for the eye health of my many patients who are getting expired contact lens prescriptions refilled time and time again with out an annual eye examination. I implore the FTC to not place another regulatory straw on the already broken back of the eye care physician. Sincerely, David B. Seibel, O.D., F.A.A.O. Past Chair, AOA-Contact Lens & Cornea Section