FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #03435

Submission Number:
03435
Commenter:
Kathy Khong
Organization:
State:
Oregon
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
The US Federal Trade Commission (FTC) is proposing an unwarranted, unnecessary, punitive, and anti-business change to the "Contact Lens Rule" that will burden each doctor and their respective staff members with an administrative hassle that will erode the patient/doctor relationship and that will cost each doctor precious time and money. This useless bureaucracy takes time away from patient care and contributes to longer wait times and a less pleasant patient experience. Every patient has full access to their records through personal health records or on request in our office. This change would require each patient to acknowledge in writing the release of their contact lens prescription (As though their doctor cannot be trusted.), and those acknowledgements must be curated and archived by the doctor for a minimum of three years. This proposed rule change is the brain child of 1-800 Contacts, and is a solution in search of a problem. From 2001 through 2016, the FTC received only 135 complaints regarding prescription release out of the hundreds of millions of contact lens prescriptions issued. Very conservative estimates place that complaint rate at 0.00017763%. Even if the complaint rate were really 1,000 times that amount, it would still be less than 0.25%.