16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I'm writing to comment on Eyeglass Rule, 16 CFR Part 456, Project No. R511996. I have in the past obtained eye prescriptions from an ophthalmologist with the intention of purchasing eyeglasses and prescription lenses from a third party seller. In those cases the Eyeglass Rule has been very helpful to me insofar as I was able to obtain the prescription without unwanted and unneeded purchases from the ophthalmologist. For that reason I recommend that the FTC maintain this rule. On the question of pupillary distance, I have sought lenses from vendors whom required this information. In each case I did happen to have a prescription which included it, but it would have been a significant -- and unexpected -- inconvenience were that not the case. I cannot comment on whether PD information is a requirement in all cases for eyeglasses, but if some manufacturers do require it that seems like sufficient reason to have it included in the standard definition of "prescription" under the Eyeglass Rule. Finally, when it comes to providing duplicate copies of eye prescriptions to patients whom cannot access the original I think that whatever practices are followed more broadly in the medical profession should also apply here. There are numerous HIPAA-compliant electronic records vendors and eye prescriptions consist of only a small handful of numbers. So it would seem eminently possible for ophthalmologists to retain complete records for all of their prescriptions and provide duplicates of this information if requested. Thank you for taking the time to read my comment.