16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00537

Submission Number:
00537
Commenter:
Amy Moschell
State:
Wisconsin
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Several of the things Sen. Charles Schumer (D-N.Y) is proposing with regard to eye glass prescriptions are not reasonable. 1. Eyeglass prescriptions are currently prescribed by Ophthalmologists (MDs) and Optometrists (ODs). Eyeglass prescriptions give individualized information regarding the strength of glasses needed by a patient. Interpupillary distance is not something that is measured by Ophthalmologists (MDs) or Optometrists (ODs). This is measured by opticians who dispense glasses. It is important that this be done by an optician, because this measurement may need to be adjusted depending on what type of lenses and frames are being dispensed. In children in particular, fitting the glasses requires the expertise of an optician who will do more than just measure the interpupillary distance to ensure the child has an appropriate frame that fits and that the child is actually looking through the lenses correctly. Bifocal lenses also require individualized fittings to allow the distance and near portions of the lenses to be matched to the patient's eyes. These measurement can vary quite a bit depending on the style of frame being used and the patient's facial structure. 2. Having an expiration date beyond 1 year is not a benefit to most people. Children's spectacles prescriptions have a reasonable expiration date on them (approximately one year from issue), because their eyes are growing and the prescription is often changing on a yearly basis. Wearing the wrong, outdated prescription could negatively and permanently affect visual development in children. Middle-aged adults tend to have frequent eyeglass prescription changes as they lose their ability to focus at near and require progressively stronger bifocals. Adults over 60 also tend to have frequent prescription changes as their cataracts develop. 3. With regard to verification of prescriptions to third-party vendors within a "reasonable" amount of time, there needs to be an understanding that most Ophthalmology and Optometry offices are not open nights or weekends.