16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00469

Submission Number:
00469
Commenter:
Brian Wnorowski
State:
New Jersey
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
THe determine of interpupillary distance for the fitting of eyeglasses is and has always been the responsibility of a licensed optician. Shifting this requirement now to the physician instead of the optician is an undo burden on the physician. Opticians are trained and licensed to take this measurement the physicians are not. It is going to require physicians to make significant investments in training, equipment and time to accomplish this task. THe effect of that ruling is going to essentially INCREASE the cost of the medical care. You are now asking a physician to perform a task that is currently done by someone who, in general, has a lower overall payscale. The effect is going to be a significant INCREASE in what the physician now charges patients to peform a refractive exam. THat increase in fee is likely to be larger thn what an optician charges to do the same service. Moving responsibility to complete a task from someone who is in a lower payscale but actually has more training to complete the specific task to someone in a hgher payscal with less training to complete the task will just lead to more inaccuracies in the outcome of the task and an icreased cost. Not what the US healthcare system needs at this point.