16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
This proposed regulation to make us provide "Complete" eyeglass prescription information is well intended but will create more cost for consumers and more confusion in the process of obtaining a pair of eyeglasses. Currently our training as physician ophthalmologists consists of measuring the power of glasses that are needed by our patients. The process of determining the placement of lenses in a frame and the distance of the various portions of those lenses as they relate to the eye are done by a qualified optician who is trained and has expertise in that task. Ophthalmologists are NOT trained in that area, and to perform this task will take valuable time away from our mission to provide medical care to our patients. We will of course be forced to purchase extra equipment and train ourselves and our staff to in large part become opticians to provide this service and this will cost dollars whose cost will then be passed onto consumers. The idea for us to provide this service is solely so that remote internet vendors can profit from our work. There will be more patients with unsatisfactory glasses if this goes forward since the true task of fitting the glasses will be separated among different providers, many of whom will have no personal contact with the consumer for a service that requires hands on care. I strongly urge you to reject this proposal which will have many unintended negative consequences for our patients.