CooperVision has been very active in fighting to preserve contact lens patient safety and wearing experiences. There have been several recent developments that we are proud to be a part of and want to take this moment to share with you.

Broadly, our most significant activities have come from the efforts of our Professional Affairs organization along with a team of CooperVision employees and consultants to lobby at the state and federal levels for policy changes designed to preserve the doctor-patient relationship. CooperVision firmly believes that patients spending time with their eye care professionals to discuss the features, benefits, and care of their contact lenses will further enhance the wearing experience – hopefully leading to fewer drop-outs, better hygiene and comfortable outcomes. One of our core values is being a partner, and we approach our legislative, regulatory and policy initiative from that perspective.

Another invaluable component of our efforts has been our membership in the Coalition for Patient Vision Care Safety, which supports a common mission of promoting patient eye health and safety. Through this effort, we have joined with the American Optometric Association and other contact lens manufacturers to push for reforms of current contact lens-related policies. In particular, we have advocated for a modernization of the Contact Lens Rule, requesting the Federal Trade Commission to close loopholes that threaten eye health. For example, on some online reseller web sites, it is possible for patients to request an almost unlimited quantity of lenses, in effect risking that patients will not see their eye care professional until well after their contact lens prescription expires. CooperVision would like to see a commonsense approach that would place reasonable limitations on quantities so that patients can have fair access to lenses, but their eye health is not jeopardized as a result. Additionally, we have advocated for enhancements to the passive verification process, mostly through a recommendation to eliminate robocalls which reduce true direct communication between a prescriber and a seller.

In 2016, we increased our lobbying efforts in light of the many state legislative proposals affecting the contact lens industry. CooperVision employees worked with consultants to join the fight against Arizona’s proposals to extend contact lens expiration periods. That bill was successfully defeated.

Additionally, we opposed Utah’s proposal to allow the use of “telemedicine” for prescribing medical devices, including contact lenses. That bill was successfully defeated. Finally, we fought against proposals to ban UPP in Rhode Island, New York and other states. Those bills were successfully defeated. So we had a very good year in those state legislative battles in which we were involved.

We have found that there has been no decrease in legislative and policy-making activities during late 2016 and early 2017. On January 30, 2017, we and the Coalition submitted comments on the Federal Trade Commission’s proposals to modify the Contact Lens Rule, including opposition of the burdensome proposal to add forms that require patients to acknowledge receipt of prescriptions. CooperVision does not see that as a meaningful or necessary change for patient safety, compared to other things the FTC could be focusing on, such as robocalls and reasonable quantity limits. In fact, our letter – as well as the Coalition’s letter – requests that the FTC reconsider its prior decision not to prohibit robocalls and not to include quantity limits. We strongly believe that those two actions would do a great deal to ensure patients receive the best care they can from their eye care professionals. A copy of CooperVision’s letter to the FTC is included here for your review.

The Coalition for Contact Lens Patient Safety recently launched a web site – www.visioncaresafety.org. On the Coalition’s web site, you can learn more about the Coalition’s activities and get the latest information about some of the federal activities related to the contact lens industry. More importantly, the website allows patients and eye care professionals to take direct action by sending their own letters to the FTC about the importance of patient safety. We encourage you to visit the website and make your voices heard. In addition, we are hoping that federal legislation (like the 2016 “Cassidy” bill) is re-introduced in order to improve the Fairness to Contact Lens Consumers Act. If such legislation is presented, CooperVision’s team is ready to provide lobbying and other resources in support of getting a meaningful bill passed into law.

Thank you for taking the time to learn more about our efforts with respect to regulatory and legislative matters. We invite you to visit www.visioncaresafety.org and get involved with these important issues.

-Michele Andrews, O.D. 
 Senior Director, Professional & Academic Affairs, CooperVision

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