Bausch + Lomb Responds to FTC Review Regarding Contact Lens Rule

Dear Eye Care Professional,

Through our mission of helping people see better to live better, we are committed to providing innovative products and resources to help protect your patients’ vision health and safety. In further support of this effort, I wanted to share a brief update regarding our response to the Federal Trade Commission’s (FTC) review of the Fairness to Contact Lens Consumer Act’s (FCLCA) implementing Contact Lens Rule.

Bausch + Lomb is a proud working member of the Coalition for Patient Vision Care Safety since it was formed in August 2015. The Coalition brings together contact lens manufacturers, eye care doctors and associations, and medical device trade associations to provide comment to the FTC and members of Congress on pathways to preserve patient access to contact lenses. By emphasizing the vital relationship between health care providers and patients, the Coalition is also requesting the FTC to strengthen existing health and safety protections.

In addition to the ongoing work through the Coalition and with the company’s team of legislative and government relations professionals on a national level, Bausch + Lomb is also tracking developments at the state level, where similar attempts may be made through state legislation to disrupt the FCLCA. Specifically, as Arizona is a state where these protections are directly at risk through pending legislative efforts, we are providing direct financial support to the Arizona State Optometric Society (AZOA) to assist in their efforts to advance the optometric profession and help provide the best care for patients. We will remain committed to engaging with, and supporting, organizations in other states that will be at the forefront of efforts to promote patient health and safety.

United with the Coalition, we stand firm in our request that the FTC continues to maintain and enforce the following at both the state and national level:

• Current standards requiring that contact lens prescribers include the specific brand and product name on patient prescriptions;
• Consumer safeguards prohibiting a seller from substituting a non-prescribed brand without consulting and verifying such substitution with the prescriber; and
• The one-year minimum contact lens prescription expiration date.

We also encourage the FTC to strengthen the rule by:

• Aligning the contact lens market with the dispensing/fulfillment standards in the pharmaceutical industry by requiring the quantity of lenses to be included on every contact lens prescription; and
• Addressing loopholes related to the current passive verification system to ensure consumers receive the exact contact lenses prescribed and to prevent sellers from processing contact lens orders for excessive quantities.

We hope you join our cause, and the overall work of the Coalition, by continuing to educate patients on the importance of safe and healthy wear and care of contact lenses.

Best Regards,

Mark McKenna

Senior Vice President & General Manager, U.S. Vision Care