Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Optometry
 
chapter
Regulations of the Virginia Board of Optometry [18 VAC 105 ‑ 20]

1 comments

All comments for this forum
Back to List of Comments
5/29/20  1:29 pm
Commenter: Gerald R Neidigh, Grove Eye Care

Comment on Petition to limit number of contact lenses
 

While I understand the thinking behind this request for rule making, I do not agree with trying to implement this type of regulation through this process.  More specifically I do not feel this should be handled at the state level.  There are organizations and alliances already working with the FTC and FDA on this issue and others like it with regard to contact lens abuses. Furthermore, adding this requirement/restriction on a contact lens prescription will create many issues and hardships for the practitioner as well as the patient.  There are many variables the doctor must consider when prescribing contact lenses including best lens for the patient based on the comprehensive eye exam, recommended wearing schedule, etc.  Also, patients do not wear their contact lenses the same way nor replace them with the same frequency.  Some actually replace them more often than the recommended wearing schedule and thus could require the use of more contacts throughout the year.  This limitation creates an unnecessary hardship for the patient and doctor, potentially wastes time and energy.  There is also the issue of enforcement.  Tracking the number of contact lenses each patient receives in a given year I see as a daunting and unnecessary task for Board of Optometry. 

CommentID: 80172