WWW.DISSERTATION.XLIBX.INFO
FREE ELECTRONIC LIBRARY - Dissertations, online materials
 
<< HOME
CONTACTS



Pages:     | 1 |   ...   | 2 | 3 ||

«October 26, 2015 Donald S. Clark Federal Trade Commission Office of the Secretary 600 Pennsylvania Avenue NW. Suite CC–5610 (Annex C) Washington, ...»

-- [ Page 4 ] --

11. What evidence is available concerning the degree of industry compliance with the Rule?

It is clear there is wide spread non-compliance with several components of the Rule.

1. Selling Lenses Without a Prescription: There are many retailers selling contact lenses without a prescription when the Act and Rule “prohibit any person that engages in the manufacture, processing, assembly, sale, offering for sale, or distribution of contact lenses from representing, by advertisement, sales presentation, or otherwise, that contact lenses may be obtained without a prescription." A listing of websites potentially violating this requirement is included below in Appendix B. These larger retailers violate the Rule along with individuals who attempt to sell contact lenses through websites such as Facebook, eBay, and Amazon.com.

2. Selling Lenses With an Expired Prescription: Consumers have acknowledged in several surveys or studies they often buy contact lenses after their prescription has expired. Some sellers ask customers to reorder lenses after the prescription has expired.

An expired prescription is an invalid prescription, and sellers should not knowingly seek to verify an invalid prescription.

3. Quantities of Lenses: Retailers who allow patients to purchase large amounts of contact lenses beyond what is reasonably necessary for the duration of a prescription also violate the pro-competitive benefits of the Rule (See Appendix A) by restricting a patient to a single seller for potentially many years.

4. Incomplete Robocalls: While the AOA believes the Rule should no longer allow robocalls to be used to verify prescriptions, the Rule is clear in that “calls from automated telephone systems must fully comply with all applicable Rule requirements” just like calls that are not robocalls. The AOA often hears from doctors of optometry who indicate the information received via phone was not complete and did not provide sufficient information to verify a prescription.

5. Lack of Retailer Contact Person: While the Rule specifies retailers must have a contact person who is “reasonably accessible to the prescriber,” the AOA has received many reports from doctors of optometry that it is extremely difficult to get in contact with anyone at 1-800 CONTACTS to discuss problems with a patient’s order. Therefore the AOA strongly urges the FTC to require sellers to respond to prescriber verification questions within eight business hours and prior to any sale.

6. Brand Switching: While the Rule indicates a ‘‘seller may not alter a contact lens prescription," the AOA has received reports from members that patients have been able to select lenses from online retailers other than those prescribed by their doctor.

12. What modifications, if any, should be made to the Rule to account for changes in relevant technology or economic conditions? What evidence supports the proposed modifications?

As is detailed above in questions 8-12, allowing the use of robocalls must be eliminated. This revision would account for changes in technology and an overall attitude shift regarding the use of automated phone calls that has occurred in the ten years since the Rule was drafted.

14 The AOA stands ready to assist the FTC in working towards the best and safest contact lens market for patients. We appreciate the opportunity to comment on this Rule. If you have questions or need additional information, please contact Rodney Peele, Associate General Counsel for Public Policy, at rpeele@aoa.org Sincerely, Steven A. Loomis, O.D.

AOA President

–  –  –

15 16

–  –  –

www.9mmsfx.com http://www.aalens.com/ http://www.angelcontacts.com/collections/circle-lenses http://www.boulonguise.com http://www.brilliantcontacts.com/ https://www.buyingforbeauty.com http://candylens.com/ http://circlelens2u.com/ http://colorcontacts.silkfair.com/ http://www.colorlens4less.com http://www.contactlenshouse.com/index.asp http://www.cosplayeyez.com/ https://www.daysoftcontactlenses.com/US/Default.aspx http://e-circlelens.com/shop/main/index.php www.eyecandys.com http://www.geocolouredlenses.com/ http://www.hollywoodcolorcontacts.com/index.php http://honeycolor.com http://www.iszocirclelens.com/ http://klenspop.com/en/ http://www.kawaiilovebeauty.com http://www.lensvillage.com/ http://loveshoppingholics.com/ http://magicangeleyes.com/ http://maplelens.com/ http://myeyecolors.com/ http://ohmykitty.com/ http://www.thedollyeye.com/store/circle-lenses/ www.pinkyparadise.com http://www.pricesmartcontacts.com/ http://rainbowcomplete.com/ http://sandysaccessories.com/ http://www.shellysdanceandcostume.com/accessory-products/color-contacts/ http://shopcoloredcontacts.com/ http://shop.playthingsmiami.com/CONTACT-LENSES_c6.htm http://www.shop.9mmsfx.net/main.sc http://thedollyeye.com/ http://uniqso.com/ http://www.whatlenses.com/ http://www.yesstyle.com/en/beauty-circle-contact-lenses/list.html/bcc.11966_bpt.46 Saveonlens.com 17

–  –  –

GROUPON “Non-Prescription Contact Lenses” 23

Pages:     | 1 |   ...   | 2 | 3 ||


Similar works:

«Patient-Room Design: The Same-handed, Mirror-image Debate. Hospital professionals across the United States—and the design resources they work with—are debating the merits of each approach. The issue comes down to whether same-handed or mirror-image standardization does a better job at improving patient safety and staff efficiency, whether in new or renovated facilities. And if so, at what cost? Research Summary / 2011 The people who make America’s hospitals work—nurses, doctors,...»

«143 DURBIN MEDICAL SUPPLY CATALOGUE Books and Teaching aids Books and Teaching Aids DURBIN MEDICAL SUPPLY CATALOGUE Books and Teaching aids 9.1 General medical and nursing 9.2 General surgery and critical care 9.3 TB, HIV/AIDS and STD 9.4 Women's health 9.5 Newborn and child health 9.6 Laboratory 9.7 Community and urban health 9.8 Drug information 9.9 Equipment Issues 9.10 Health care services: management, training and technical 9.11 Free publications 9.12 Teaching aids 9.13 Charts and models...»

«IHTSDO Launches Global Health Terminology Workbench Tools to Benefit Member Nations and Other SNOMED CT Users Copenhagen, Denmark: January 22, 2008 – The International Health Terminology Standards Development Organisation (IHTSDO) launched today a new IHTSDO Workbench with tools to develop, maintain, and facilitate the use of SNOMED CT in health systems around the world. IHTSDO’s 11 Member nations and other SNOMED CT users will use these tools in a shared web-based environment. Helping...»

«Manor Hall Guide for the Sinclair House Couple and Family Flats 2016/17 Welcome to your new home. This Guide will help make your stay in our accommodation as happy and successful as possible. This information is for the Sinclair House couple and family flats and should be used with the Handbook, which contains general rules and regulations for living in a University owned residence. Please read this Guide now and keep a copy for reference throughout the year. The Essentials Who should I call in...»

«JOurnAL OF APPLIEd CLInICAL MEdICAL PHYSICS, VOLuME 15, nuMBEr 5, 2014 Characterization of MOSkin detector for in vivo skin dose measurement during megavoltage radiotherapy Wei Loong Jong,1 Jeannie Hsiu Ding Wong,2 Ngie Min Ung,1a Kwan Hoong Ng,2 Gwo Fuang Ho,1 Dean L. Cutajar,3 Anatoly B. Rosenfeld3 Clinical Oncology Unit,1 Faculty of Medicine, University of Malaya, Kuala Lumpur, Malaysia; Department of Biomedical Imaging and University of Malaya Research Imaging Centre (UMRIC),2 Faculty of...»

«Battling Poverty in the Golden State Recommendations for the California Statewide Poverty Commission Melissa Boteach and Jodie Levin-Epstein October 2010 Background The Census’s 2009 poverty data revealed that 43.6 million Americans or 14.3 percent lived in poverty last year. This is the largest number since the Census started keeping track in 1959. Moreover, more than 100 million Americans or 33 percent were low income, barely scraping by and living below 200 percent of poverty, or $44,000 a...»





 
<<  HOME   |    CONTACTS
2016 www.dissertation.xlibx.info - Dissertations, online materials

Materials of this site are available for review, all rights belong to their respective owners.
If you do not agree with the fact that your material is placed on this site, please, email us, we will within 1-2 business days delete him.