16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00509

Submission Number:
00509
Commenter:
Stephen Brueggemann
State:
Indiana
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Dear FTC, This correspondence addresses placement of the PD on the eyeglass prescription per the "Eyeglass Rule". The examiner, a fully licensed Ophthalmologist or Optometrist, measures for the power of the prescription and enters this data into the medical record and gives a copy to the patient for their use. The patient then proceeds to an optician to select a proper frame. Depending upon the patient's posture, the inter-pupillary distance markings on the choosen frame may be higher or lower in position than ideal center. This is the "work" in properly fitting the eyeglasses to a patient, which is reimbursed in the cost of glasses purchased at the point of purchase. Firstly, does anyone provide work or services for no reimbursement, i.e.. for free and secondly, who will "fix" the glasses if the patient's posture is not ideal or average which results in the PD not being optimally placed in the vertical meridian? Most of the time eyeglass ordering is best done in a "hands-on" setting and with the optician, who does not work for free. Additional charges will apply if the patient requires the PD to be placed on the eyeglass prescription. No liability should be assumed if the PD is placed and the patient obtains their eyeglasses elsewhere, e.g. the internet or other optical shop. This is not a standardized process, it is a patient tailored process that does not lend itself well to the prescription. Respectfully submitted.