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SAMPLE LETTER 1 – cost of undiagnosed health problems Many adults with serious health issues – such as a brain tumor, retinal detachment, high blood pressure and glaucoma – look perfectly healthy and would qualify for an optician administered sight test. As an optometrist I have often been the first to detect general health disorders and diseases that have related eye health symptoms. Sometimes the patient notices a change to their vision, and sometimes they don’t. If they are sight tested health issues will be missed.
If a patient continues to purchase contact lenses or glasses with no valid prescription year after year, health issues will be missed. I can’t believe the government would implicitly encourage people not to get a full eye exam. If they’re not concerned for the health of British Columbians, they at least should be concerned over the high costs of treating serious diseases that have been left to progress without early treatment. SAMPLE LETTER 2 – Erosion of health standards The Health Services Ministry says it wants to modernize the regulations on eyewear.
But the prestigious World Council of Optometry (WCO) – representing 150,000 optometrists in more than 60 countries – sees a dangerous erosion of health care standards. ”The world is watching a paradox unfold in Canada. While the Third World is attempting to raise delivery standards through consistently improving the level of education of all eye care personnel, the B. C. government appears to be consciously dropping standards of eye care to the very lowest in all of North America,” the WCO states.
Here in the United States, we’re looking to Canada as an example of a system that protects the vulnerable and provides appropriate health care for all. Removing regulations that protect public health is a big step backwards. SAMPLE LETTER 2 It is with some admiration that I have watched and heard of how hard the two of you have worked to organize and improve our health care system. As a BC Liberal member and donor, my family and I have been very supportive of our current government administration.
It is in this context that I found your recent proposal to change the Opticians and Optometrists' Regulations to remove limitations on the restricted activities of our professions absolutely mind boggling. If this type of legislative facilitation for an internet provider of contact lens and eye glasses has been arranged in any other jurisdiction in North America, or for that matter the world, I would respectfully ask that evidence of this be shared. Even if another jurisdiction has made such a decision, it is still the wrong thing to do.
The other matter, which is that of opticians being officially legislated to "sight test", is also a first in North America. As you are most likely aware, a recent Ontario court decision found a sight testing optician to be in contempt of court for continuing to sight test and the owner has been fined millions of dollars. Last year in my optometry clinic, we had a forty-six year old healthy female patient with an asymptomatic retinal melanoma. If she had been sight tested, she would be on her deathbed now. Two and a half years ago I diagnosed a pituitary tumor in a healthy thirty-four year old male.
If he had been sight tested, he would have been dead within six months. He had the tumor removed two weeks after my diagnosis. Thankfully, our BC Liberal party has shown it has the flexibility to rectify the inevitable occasional error in judgment that will occur when implementing thousands of varied provincial Regulations and Policies. I can assure you that these proposed changes will not enhance the eye health nor eye care of our public. Please feel free to contact me at any time to discuss this matter.
I look forward to your continued consideration of these important decisions. SAMPLE LETTER 3 Dear Sir, I ask for a moment of your time to discuss the recently announced changes to the regulations concerning the selling of eyeglasses, contact lenses, and sight testing by your government. I am an optometrist who has practiced for the past 22 years in Nanaimo, and have several serious concerns about these proposals. The Minister of Health, Kevin Falcon has proposed that glasses and contact lenses can now be dispensed without a prescription.
There is nowhere in the Western world that this is currently permitted. How the BC Government feels that the dispensing of a medical device without a prescription is helping the public is beyond comprehension. The federal Health Protection Branch and the FDA in the U. S. , considers contact lenses as a Class 1 Medical Device. When worn, a contact lens is immersed within the cornea and conjunctiva, and as such is tested and approved using the same protocols as heart valves, heart stents, and other devices placed in direct contact with bodily fluids and tissues.
It is regulated as such because the potential for harm, serious harm, is deemed high enough to require the most careful level of testing possible. Contact lenses can be purchased from a large number of sources, including optometrists offices, opticians stores, big box outlets such as Costco and Walmart, and on-line. In Nanaimo, there are 15 locations selling glasses and contact lenses. The level of competition for the sale of contact lenses has reduced them to extremely low mark-ups, but this must not further reduce them to the level of mere commodity items.
Other jurisdictions have worked with our industry to come up with acceptable protocols for the sale of contact lenses online and otherwise, recognizing the importance of patient's providing a valid, non-expired contact lens prescription. If B. C. truly wants to modernize the sale of contact lenses, as Minster Falcon has worded it, then the protection of public health must not be completely eliminated for the sake of consumerism, when there has been no evidence that BC consumers are overpaying or having trouble obtaining contact lenses.
Point 1: Contact lenses must only be sold or dispensed with a valid contact lens prescription. Another change to the regulations will allow the sale of eyeglasses without a valid prescription, by ANYONE. No longer will the dispensing and sale of glasses be done by a trained professional. Without the requirement for a prescription, anyone can modify or change the power of glasses. There are a myriad of serious eye and systemic diseases that cause blurred vision or change in the power of eyeglasses.
Under this proposal, a consumer can go online and order a new pair of glasses and ask, "for a little more power". Nothing in these proposals will prevent such a scenario. Someone could potentially go decades without a proper eye exam. Numerous States in the U. S forbid the sale of over the counter "magnifying glasses" because those jurisdictions feel the risk to the public of self-diagnosing is too great to allow the sale of such readers. Yet here in B. C. , anyone, including those without so much as an hour's worth of training, will be selling glasses and modifying the power at whim.
How can this possibly be a good thing? As I've mentioned above with contacts, consumers in this province have plenty of options and price ranges available to them for the purchase of eyewear. The Province simply cannot allow the willy-nilly modification of lens power by untrained lay people. Point 2: Eyeglasses must only be dispensed or sold with a valid, unexpired eyewear prescription. The third proposal made by the Minister is to formally allow independent sight testing by non-doctors.
Keep in mind that there is nowhere in North America that allows this, and the only known jurisdictions that do allow for it, are areas with minimal health care, and practically no eye care. These are all second or third world countries. Why is the Ministry of Health prepared to take a step backwards, rather than move eye heath care forward, especially in the area of preventative health care? The Colleges of medicine and optometry are in place to protect the public, NOT to advocate for their professions. Both of these respected groups have come out strongly against the very idea of sight testing!
How is it possible that adding a new class of providers of health care can be done without even consulting the Colleges that are in place and mandated to protect the safety of the public? Seriously, despite the press release on this issue stating that consultations took place, neither College was consulted! This is a move absolutely beyond reason. I don't understand the government's unwillingness to consult with those involved, despite the fact that we are "in the trenches" and know what is going on. Perhaps the government assumes we re too self serving, and trying to preserve a monopoly (which is preposterous, as I've indicated above there is no lack of competition in this field). If the government won't listen to optometrists and ophthalmologists, then I do hope that the CNIB is a credible independent expert on this matter. According to their own statistics, each year about 4,700 British Columbians lose their vision. This vision loss costs in excess of $2. 1 billion in direct health costs as well as indirect costs such as lost productivity.
How is allowing the public to have a test of their eyes which completely ignores any testing what-so-ever of the health of the eyes, going to reduce this tremendous cost in both dollars and quality of life? It is inconceivable that these costs for vision loss will do anything but rise - the CNIB has estimated that 75% of vision loss can be eliminated with timely and regular eye health exams. Please explain why spending more on preventable health costs is a good thing at this time! If you have not received a copy of the CNIB's letter, I can e-mail or fax it to you.
Two years ago the Ministry of Health in Ontario soundly and unanimously defeated a motion to allow sight testing by opticians in that province. An optician who continued to sight test despite that ruling was fined over one million dollars for defying a court order to cease and desist. Patients in this province have always had the right to their spectacle prescription at any time. In my office, I issue every patient a copy of their prescription and recommend that they at least tuck it away with their travel documents, in the event they are away from home and break or lose their glasses.
The Minister cannot argue that patients are lacking for access to their prescription. This is certainly not sufficient grounds to justify the dangerous practice of sight testing by non-doctors. Point 3: Sight testing should not be permitted in a province such as B. C. which has plenty of qualified and well distributed eye doctors throughout the province. This is a dangerous proposal which will result in loss of sight and even lives. The final proposal which I wish to address is the notion that optometrists must provide their patients with a "PD" measurement.
Many measurement are required for the proper preparation of eyeglasses, one of which is the Pupillary Distance (PD), or more simply the distance in millimetres between a patients eyes. This is a measurement that is not taken nor required during an eye exam, but rather taken by the optician who is selling or dispensing eyewear. For reasons that escape me, the Minister has proposed that one person or company (that which is providing the eye exam) MUST perform work on behalf of an entirely different individual or company (that which is selling glasses) with no compensation.
This is akin to forcing restaurants to grill a steak for you if you bring it in. Or making a tire store mount tires for someone who bought them on the internet. Making shoe stores measure your foot for free so you can order shoes on the internet. Soon perhaps I can purchase clothes on the internet and have a local tailor alter it for free. I'll be able to purchase spark plugs on the internet and have a local mechanic, with all of his tools and associated overhead costs, install them for free. I could go on with the analogies, but I'm sure you understand my point.
The previous issues I've discussed involve concepts and procedures about eye health care for which there is little understanding by the general public. However this issue, making one group do work so that another can profit by it is easily understood by everyone from kids who have run a Kool-aid stand, to anyone else who even remotely understands the concept of free enterprise. I don't know how the Minster thinks such a proposal will even remotely be followed, let alone survive a court challenge.
Point 4: The expectation that optometrists will take the measurements on behalf of an online retailer is ridiculous and should be immediately dropped. Mr. Cantelon, I thank you for your time in reviewing this issue, and I would be most pleased to discuss these points and answer any questions you have. As a member of the Select Standing Committee on Health, I appreciate your desire to be well informed on all matters concerning the health of your constituents and I hope you will find the time in your busy schedule to meet with me, if even for a few short minutes.
Thank you again for your time, and I shall be contacting your office about a meeting. Sincerely, Michael T. Kellam, OD FAAO optometrist Example Letter 3- B. C. optometrist who once practised in the US. My name is Dr. Gurpreet S. Leekha, and I have lived in your neighbourhood for the past 3 years. I am an optometrist, who moved back to BC after practicing in the US health care system for 5 years in New York City. One of my main reasons for moving back was I had become tired of being witness to how poorly health care was delivered to the general populace, the under-insured and especially the uninsured in New York City.
Having grown up in Coquitlam, and on frequent trips back to Canada, I knew every Canadian received better general health and eye care than most Americans could even dream of. I couldn't wait to come back to live and practice in BC, despite the apparent 20-30% reduction in salary I would have to digest. Optometrists in NY State have been treating eye disease, prescribing medication, and managing eye health and systemic health conditions for the past decade.
On April 1st, 2009, BC Optometry legislation caught up with the United States and much of Canada, allowing optometrists to prescribe medications to treat eye conditions, saving patients a trip to the emergency room or a long wait in a walk-in clinic, and savings thousands of dollars in public health care costs. So I couldn't have been more shocked when I heard the BC Minister of Health, Kevin Falcon, announce on March 19, 2010 that to keep a local internet commerce business, Coastal Contacts (http://www. clearlycontacts. a/) operating in BC, he would be striking down the very laws that made me proud to practice here. He decided, without consulting with BC optometrists or ophthalmologists, that as of May 1st, 2010, it would no longer be required to see a doctor for an eye exam, in order to be prescribed eyeglasses or contact lenses in BC. Further, apparently on advice provided by representatives of this internet business, Mr. Falcon decided that it is not necessary for patients to have a contact lens (classified as a regulated medical device by Health Canada) rescription in order to order contact lenses online. I cannot put into words how strange it feels, after spending 4 years studying the medicine and science of protecting and treating eye health -- including the safe and healthy fitting of optical polymers to the sensitive human ocular surface -- to have a non-physician decide, against all available scientific advice, that it's all of a sudden ok to allow anyone, even your teenage child, to purchase and fit lenses to their own eyes. Or, for that matter, to allow opticians to test eyes for prescribing purposes without checking eye health.
It is not just shocking that BC will become the only jurisdiction in North America that will allow such unregulated sales of medical devices without a prescription, or to allow eyes to be tested by non-doctors. What is alarming is that this is a regression compared to recent health care legal changes in our neighbour to the south. In the United States, a similar attempt by a larger online retailer, 1-800-CONTACTS, was shot down by federal legislation in 2004, after it was determined that a few hundred patients had suffered negative consequences from purchasing unregulated contact lenses from the internet.
Of note: even though BC consumers will be able to, after May 1st, buy any contact lens online, whether it fits their eyes or not, and put it in their eyes, US consumers (and all other Canadian consumers) will continue to be protected from this unnecessary risk by their federal (and provincial) regulations. Health Canada states on their website: "Contact lenses are medical devices which, like drugs, provide benefits while posing certain risks. If you wear contact lenses, you should take steps to minimize these risks and protect your vision. "The most important step you can take is to have your contact lenses prescribed and fitted by a qualified eye care professional. " (http://www. hc-sc. gc. ca/hl-vs/iyh-vsv/med/lenses-lentilles-eng. php) A 2008 study published in Optometry (The Journal of the American Optometric Association) determined that consumers who purchased contact lenses online without the guidance of a prescriber (optometrist, ophthalmologist or contact lens-fitting optician) suffered higher complication rates and eye health problems: "Those who purchase contact lenses over the Internet or at stores could be more at risk for unhealthy eye care practices.
Eye doctors should take the time to emphasize to all of their patients about important eye care practices, especially for those who purchase contact lenses over the Internet or at stores. Also, our data suggest that there are some individuals who are not likely to regularly see an eye doctor. Therefore, there should be better monitoring of Internet stores and traditional stores that sell contact lenses to ensure that contact lenses are provided only to consumers with a valid prescription. " (www. aoa. org/documents/optm-447-Fogel. pdf) May 1st is only 4 weeks away. But a lot can happen in 4 weeks.
For example, BC parents should be outraged that the decision to allow their children to wear contact lenses has been taken away from them. Contact lenses will, as of May 1st, now be purchased online without a prescription, just like buying a song from iTunes. com, or clothing from eBay. ca. Anyone who has sought a doctor's care for adverse events from contact lens wear (which is most contact lens wearers, at some point in their lifetimes) should raise their voice and share their stories of near-vision loss, and the importance of properly fitted lenses and after-care from their prescribers.
And let's not forget the health problems often identified during routine eye exams. Many BC patients have had their eye, brain, kidney, liver, lung and breast cancers discovered during either routine visits to their optometrists, or visits initiated by symptoms like blurry vision, or an apparent change in their vision they thought was glasses-related. Ms. McNeil, in your former role as the president and CEO of the BC Cancer Foundation, surely you must have come across patients whose survival of their cancer diagnosis was made possible due to early detection?
On a daily basis, I dread the moment I look into the back of my patient's eyes, and find a lesion that could be cancerous. I am fortunate in that only 2 of my patients, over the past decade, have ever been diagnosed with cancer detected during my examination. But both of them survived. Had they assumed their blurred vision was a change in their glasses prescription and sought an optician's sight-test, or assumed a change in their contact lens prescription and ordered new contacts online, we would have 2 less BC consumers to take care of.
Is that how BC's government takes care of the health and welfare of its citizens? The current system of requiring consumers to have a valid prescription before buying contacts online has only one apparent limitation, according to Mr. Falcon: doctors and opticians are hesitant to release the prescription for fear of losing the sale to another office or online company. As an optometrist, I am always releasing prescriptions at the time of finalizing the parameters or when requested by the patient, and I am aware of the legal requirement to do so.
If this is the only concern, why not simply enforce this rule whenever it is violated? It seems awfully silly to punish all British Columbians and all optometrists when only a rare few are not complying with this rule. Second letter SAMPLE LETTER 1 – Patient with vision change Not everyone understands the difference between and sight-test and a proper eye exam. I didn’t until the glasses I got from a sight-tester didn’t work for me. That’s when I went to my optometrist who detected a health issue that was causing my vision to change.
Unless you have an optometrist or ophthalmologist looking at your eyes, there’s no way to know for sure why your prescription is changing. There’s no way opticians should be allowed to give you new glasses unless an optometrist has ruled out any health problems first. SAMPLE LETTER 2 I went to my optometrist for a routine exam and he detected that I have glaucoma. I had no symptoms before seeing my optometrist. If I had gone for a sight-test, nothing would have been picked up because my vision seemed fine.
With glaucoma, by the time you have noticeable vision changes, the damage is already done. Now I’m on medication and need to go for check-ups with an eye doctor every three months. I hate to imagine what could have happened if I didn’t have that regular check-up. I don’t think it’s right to let people go for automated sight tests when there’s so much at stake. SAMPLE LETTER 3 – general eye health concerns Dear Minister Falcon/ MLA, I have heard that you are planning to let non eye doctors prescribe eyeglasses without an eye doctor checking the patient’s eye health.
This is a terrible idea. Lots of eye diseases have no symptoms at the beginning. If the government allows simple eye testing by opticians, people will think it is safe not to have regular, thorough eye exams to check for disease. People will suffer irreversible vision loss from diseases like glaucoma that cause no symptoms until it is too late to be treated successfully. Stop this ridiculous and dangerous regulation from going through. The health of British Columbians depends on you making the right decision. SAMPLE LETTER 4 – general concerns re: eye health
I understand you are planning on introducing regulations to allow opticians to dispense eyeglasses without the patient having a full eye exam and that people can buy contacts and glasses online without having their prescription professionally verified. I also understand that this level of eyecare is not allowed anywhere in North America. Eye health evaluation is part of what I expect as part of an eye exam. And allowing online providers to sell contacts and eyeglasses without a valid prescription and without any onus on the seller to verify it is ridiculous.
Automated sight-testing by opticians does not allow for eye health determination. And “buyer beware” isn’t right for filling prescriptions. Reducing standards to the lowest in North America is not what I expected nor want of your government. I am concerned about the proposed changes and expect that changes you do make will still require seeing an eye doctor for an eye health review as part of getting a spectacle prescription, and that you won’t make patients responsible for verifying the accuracy of their own prescriptions.
Example of a real letter sent by a patient with a brain hemorrhage: I have told my optometrist that he may use my name and case as an example as to why a full eye exam is so important. I feel that I owe my life to my optometrist, Dr. Rodgers, and visiting ophthalmologist Dr. Talbot. If it had not been for them I may very well have died, as I was walking around with a medium to large sized bilateral subdural hematoma, with very few symptoms aside from a headache and my eyes bothering me. Hence my visit to my optometrist’s office.
If the regulation proposed had been in place and I had not gotten a full eye exam, I may very well have walked around until I fell unconscious or died. Chuck Montgomery Mr. Falcon seems keen to introduce these legislative changes to comply with the belief of Mr. Roger Hardy, president of Coastal Contacts, Inc, that glasses are too expensive in optical stores and therefore should be deregulated. Is Mr. Falcon also planning on applying this logic to the dental profession, and allowing the fitting of braces and mouthguards by online companies?
Or will the BC Ministry of Health encourage us to buy our own medicines from online pharmacies without a prescription, in order to save a few dollars and bypass the need to see a physician? Ms. McNeil, I would appreciate anything you can do to limit the sweeping scope of the regulatory changes proposed by Mr. Falcon, and to allow optometrists and ophthalmologists to continue to protect the eye health and welfare of British Columbians. I appreciate you taking the time to read my concerns. Please contact me if you have any questions on this or other topics related to eye care in BC.
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