To: David Lifferth,
Subject: Hb 304, Utah Optometric Association
Date: Sun Feb 28 01:49:33 MST 2016

4001 S. 700 E. 5th Floor, Salt Lake City, Utah 84107 Phone: 801-364-9103



27 February 2016



Dear Representative Lifferth,

The Utah Optometric Association has been working with the sponsor of HB 304 to make appropriate changes that would ensure patient safety with online prescribing of devices.  Though we sincerely appreciate Representative Peterson’s efforts to work with us to address concerns, the most recent amendments and version of HB 304 still fall short of what we feel is needed to ensure appropriate safeguards that assure patient safety with regards to online prescribing and dispensing of contact lenses.

A questionnaire OR tool does not allow for evaluation of the corneal health which is necessary to know if continued contact lens wear is recommended, as such assessment is only currently possible with the magnification of a biomicroscope.  It is an essential component of the examination process that would be irresponsible to bypass.  HB 304 skips that step of the examination, which would be similar to monitoring a patient with diabetes without periodic testing of blood sugar levels.

With regards to in-person follow-up examination, The American Academy of Ophthalmology makes the following recommendation:

Experienced contact lens users should generally be examined annually. Routine follow-up examinations are important to promote safe contact lens wear”:  Any reference to an AAO recommendation for a four-year period between eye health exams applies not to contact lens patients, but to “individuals without risk factors”, and the specific recommendation schedule in its entirety can be found here: Further information is included in an attachment. 

Additionally, the American Optometric Association as well as the CDC, FDA and FTC recommend annual eye examinations for individuals wearing contact lenses. Currently forty-two states allow for a one-year expiration date, eight states including Utah have a two-year expiration date and no state allows for longer than two years. The current version of HB 304 allows for four years between visits. That is too long and is in conflict with the recommendation of the medical community. The cornea is living tissue prone to changes induced by contact lenses, which are medical devices that require yearly monitoring.

The UOA continues to oppose HB 304, as it does not yet provide for adequate safety for contact lens wearers.  We applaud Representative Peterson for his forward-thinking and pursuit of innovation, but feel that the implementation of such cannot bypass established guidelines.  The UOA, the AOA, the UMA, the UOS, the Optometry Licensing Board, and The Moran Eye Center all oppose this bill due to its implications for the safety of our patients; and observe that the company advocating most heavily for its passage maintains a business model by which profitability depends on the number of boxes of contact lenses sold to its customers.

Please oppose HB 304, and contact the Utah Optometric Association if you have further questions.






Alyssa White

Utah Optometric Association

Executive Director


Cell (360)607-3407

The contents of this email message and any attachments are intended solely for the addressee(s) and may contain confidential or privileged information.  This message may be legally protected from disclosure. The Utah Optometric Association maintains strict confidentiality and security of records in compliance with the  Health Insurance Portability and Accountability Act (HIPAA) in addition to other federal and state laws. If you are not the intended recipient of this message, or if this message has been addressed to you in error, please immediately alert the sender by reply email and then delete this message and any attachments.  If you are not the intended recipient, you are hereby notified that any use, dissemination, copying, or storage of this message or its attachments is strictly prohibited.


AAO Contact lens recommendations.docx