16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00520

Submission Number:
00520
Commenter:
Charles Wesley
State:
Indiana
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
1. The proposed rule should use the term "refraction" instead of "eye examination" because not all examinations performed include the determination of glasses prescription (the refraction). This is causing ongoing confusion because people are being sold "refraction" as "eye exam"; the two terms are NOT interchangeable. Patients believe they are receiving a complete eye examination when many times they are only receiving a refraction. The federal government, specifically CMS/Medicare, EXCLUDES refraction as part of an eye "exam". 2. The determination of the interpupillary distance is not routinely performed as part of a refraction. That determination is and always has been the responsibility of the dispensing entity and the dispenser should be responsible for the accuracy of the fitting parameters. The PD has nothing to do with obtaining the refraction parameters.