FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #3409

Submission Number:
Susan Gromacki
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
Dear US FTC, I am writing to request that you do not agree to the proposed amendment to the Contact Lens Rule. As doctors of medicine and optometry, we all give the patient a copy of his or her contact lens prescription upon completion of the patient's examination and ocular health evaluation. We are of course in favor of a fair marketplace for all products. However, there is a big difference between big business "sellers" and providers of medical care. Our aspirations could not be more different: sell product versus provide ethical medical care. The latter includes selecting the contact lens material, design, modality and replacement schedule that matches best with the patient's ocular health, prescription, and lifestyle. The patient participates in the decision of which type of contact lens s/he ultimately wears not just at the completion of the prescription, but also throughout the fitting and evaluation process. This is an important distinction to make, and I for one do not want some capitalist big business entity trying to make a buck influence my best medical judgment honed during 9 years of training and 24 years of practice. That is unethical. Also unethical are the "robo calls" these big businesses are placing during the late evening and early morning hours, long before my practice opens, to "verify" a patient's prescription. Have you heard a recording of their indiscernible voices? This compromises my good care in the name of the almighty dollar. As a result, my patient receives another year's supply of his lenses, which may or may not be the healthiest option for him one year later (due to changes in his ocular health or R+D of new contact lens materials) and, more importantly, contact lenses in hand, does not return for his annual eye examination. It is at this examination where I would detect glaucoma, cataracts, a retinal detachment and the like. These online contact lens sellers are compromising the health of my patients. Also, creating an amendment which causes the patient to sign a document confirming receipt of an Rx they are already receiving creates a redundancy that will create an extra time burden on both doctor and staff. The result will be, ultimately, increased cost of eye care to the patient to compensate for this extra time. Please let us try to keep the costs of health care down, not increase them. Thank you for this consideration. Sincerely, Susan J. Gromacki, OD, MS, FAAO, FSLS Director, Contact Lens Service Washington Eye Physicians & Surgeons Chevy Chase and Silver Spring, MD