January 29, 2018

Kentucky House Health & Family Services Chair Representative

Addia Wuchner

cc: House Health & Family Services Committee Members, Co-Sponsors of HB 191


Dear Chairwoman Wuchner,

Our coalition, Americans for Vision Care Innovation, would like to flag a very important issue for consumers and taxpayers that is currently before your committee; the right to get prescriptions for contact lenses and glasses renewed online.

Your committee is scheduled to hold a hearing on HB 191 in the coming days that would severely restrict the rights of consumers to get an online prescription renewal for glasses or contacts in Kentucky. We have deep concerns about this bill and would urge you to slow down the process and gather some more information about the possible impact of this bill before proceeding. We have outlined some important information for you below and stand ready to provide more information at your earliest convenience.

Kentucky is known across the country as a leader when it comes to protecting and strengthening consumer and patient rights and promoting cost savings in the healthcare system. Your current laws allow for the use of telemedicine for online vision tests and prescription renewals. More than 40 million Americans wear contact lenses and millions more wear glasses.

Americans for Vision Care Innovation is a bipartisan coalition of taxpayer advocates, consumer groups, think tanks and innovative companies, working with leading eye doctors, who have joined together to ensure consumers across the country have access to the latest cost-saving and time-saving eye care technologies. The companies that have joined our coalition compete against each other in the marketplace, but are united in support of the use of telemedicine for vision care and online prescription renewal.

Our mission is simple. We want to give voice to millions of consumers and taxpayers who deserve the benefits of safe new vision care telemedicine technologies that will make their lives easier and healthier. We seek to inform legislators, local community leaders and the broader public about how online vision tests can improve access to eye care for eligible consumers. We also want to dispel the myths about online vision tests that are being spread in a troubling misinformation campaign by those who stand to financially gain from outlawing these services.

Disturbingly, the American Optometric Association (AOA), the lobbying group representing optometrists, and some contact lens manufacturers have been mounting a massive campaign to ban these new technologies state by state. We have heard many reports from across the country that legislators have been given incorrect information about the use of telemedicine for vision care and online prescription renewal services; and we think it is important for you to consider all the aspects of this issue before acting.

Here are some of the key facts you should know:

  • First, consumers must have a prescription from an eye doctor in order to use these services initially. These new, online technologies are designed to help get prescriptions renewed, not to replace comprehensive eye exams. For millions of Americans, their prescription changes very little between the ages of 18-50, so they shouldn’t be forced to rearrange their work schedule, travel – sometimes for hours for those in rural areas – and pay for expensive comprehensive exams every time they simply want their prescriptions checked. The American Academy of Ophthalmologists, the world’s largest association of eye physicians and surgeons, recommends that healthy adults under the age of 40 receive an in-person eye exam every 5 to  10 years; among older patients, the recommended interval is 4 years or less. This means that for many of your constituents, there is no need to return to a provider’s office on an annual basis simply to renew a contact lens
  • Second, these new services are easy to use and are available 24 hours a day. Your constituents no longer have to rush across town or take off work to get a prescription renewed – or worse, travel for hours if they live in a community with no eye These services are also generally far less expensive for consumers than visiting an eye care provider in person.
  • Third, customers who use these services go through eye health screenings as part of the process and their online prescription renewals are reviewed and approved by ophthalmologists and optometrists, who are specifically licensed to practice in the state where the exam
  • Fourth, using online prescription renewal services can lead to improvements in eye health. Medical research shows that stretching one’s contact lenses beyond the manufacturer- recommended wear schedule is one of the leading causes of eye Giving consumers the option of renewing their prescriptions online through licensed eye care providers can help reduce this risk and the tendency of many consumers to wait too long before renewal. In addition, customers who don’t qualify for using the service for health reasons are prompted to go in person to their eye care provider, leading to an increase in consumers obtaining such exams on a timely basis.
  • Fifth, ophthalmologists and other members of the medical community generally oppose bans on the use of telemedicine for vision care and online vision tests. They believe these new technologies can be used safely when doctors have oversight and banning them could severely jeopardize the development of vision saving and lifesaving technologies to treat diseases like In fact, the federal government is currently running an ocular telehealth demonstration project in the Indian Health Service to monitor and treat diabetes patients supported by both ophthalmologists and optometrists.
  • And finally, these technologies have the potential to save taxpayers millions of dollars. State and federal governments pay millions of dollars each year for eye care services for their employees and those who receive medical benefits from their Allowing these plans to utilize telemedicine for contact lens and glasses prescription renewals could result in big savings for taxpayers. And in the future, as State Medicaid programs evaluate vision care options, proper policies toward telemedicine for vision care could deliver greater value both to participants and taxpayers.

We strongly believe that legislators who have all the facts about online prescription renewals and online vision checks will make the right choice for their constituents and will allow these important technologies to continue to operate in Kentucky.

Kentucky’s contact lens users are entitled to the greatest possible degree of choice and convenience in the way they renew their lens prescriptions – and at the lowest possible prices.

The passage of HB 191 in Kentucky will result in less choice, higher costs and more inconvenience for Kentucky consumers and could drive up vision care costs across the state. We encourage you to oppose HB 191 and convene all the stakeholders in the near future to discuss a consensus approach moving forward.

We are more than happy to speak with you and your staff in more detail at any time if you have questions about online prescription renewal or the information we present in this letter. Please contact us with any questions.

Thank you for your time and consideration.



Andrew F. Quinlan, President, Center for Freedom and Prosperity

Chuck Muth, President, Citizen Outreach

Ken McEldowney, Executive Director , Consumer Action

Cary Samourkachian, President and CEO, Lens.com

Brent Wilkes, Chief Executive Officer, League of United Latin American Citizens

Dr. Elena Rios, President and CEO, National Hispanic Medical Association

Pete Sepp, President, National Taxpayers Union 

Dr. Steven Lee, Co-Founder and Chief Science Officer, Opternative

Lindsay Mark Lewis, Executive Director, Progressive Policy Institute

Zach Graves, Technology Policy Program Director and Senior Fellow, R Street

Yaopeng Zhou, CEO and Co-Founder, Smart Vision Labs

Cindy Williams, General Counsel, 1-800 Contacts