16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00570

Submission Number:
Erin Jones
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
The PD measure is NOT part of the prescription of eye glasses. It is a measure taken in the fabrication of glasses for proper eye centration in the frame. It is not measured during the exam but in the process of ordering glasses and is therefore the responsibility of person ordering the glasses. It is a critical part of the job description of opticians. It is not part of a routine eye exam. It is not used in determining the prescription of the glasses. The phoropter is set in a different manner than the optical centers are set for prescription eye glasses. Additionally, for the new lens technology, the optical centers not only need to be set horizontally in the frame (the PD) but also vertically. The vertical measure is unique to every person/frame combination. In requiring that PD's be part of the prescription (so that people can order custom made lenses on line), you are ignoring the total concept of optical centration. If a consumer would like to order glasses online, I cannot stop them. However, they then become their own optician. They can take the responsibility to measure the PD. They can take responsibility for the accuracy. If they want my staff to measure it, then there is a charge for the service. If they want me to verify that the glasses were made accurately, there is a charge for the service. They are requesting my professional opinion. I can become my own barber and cut my own hair. But I am choosing to "practice without a license". No barber, beautician etc would feel obligated to fix any error I made without compensation, nor are the being asked to by the FTC. One care mechanic is not held responsible to fix another mechanic's errors without compensation for the service, nor are they being asked to by the FTC. However, you are asking optometrist, opticians, and ophthalmologist to provide a service for free that is not part of determining the prescription of glasses It is a part determining the fabrication of glasses. Traditionally, we have bundled services as a courtesy to patients such as fitting and repair of spectacles (CPT codes 92340-92371). However, with increase of online glasses sells, decreasing insurance reimbursement, and increasing overhead costs, it is becoming increasingly difficult to provide these services at no charge. Office will be force to charge for each and every service, minor repair etc. Regulating that PD become a required part of prescriptions has nothing to do with making it easier for people to shop for glasses elsewhere. They have bought glasses from someone other than their eye doctor for years. It has everything to do with online companies trying to increase their bottom line because they CANNOT perform the required duties to complete their job in fabrication. They are trying to regulate a way for someone else to do their job for them. Patients can get their prescription to shop for glasses anywhere. They can get their PD measured. They are upset because they are now having to pay for a service that has traditionally been bundle priced with the glasses. Unfortunately, if the PD measure is forced to be bundled in a routine eye exam without compensation (like refractions have been for some insurance companies), it will force providers to unbundle services elsewhere. As an industry we have been generous at giving away services for free. Repairs, adjustments, verification of prescription accuracy will quickly be charged for and rightly so. We are using our resources, time, and professional knowledge and skills. They are all distinct services as per current procedure terminology standards. When considering your decision, make sure that you are truly trying to protect the consumer and regulating free trade. Requiring PD on a prescription is not. That freedom already exists. Requiring a PD on prescription is for the sole purpose of aiding an industry that by nature cannot complete the steps necessary to do their own job.