16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00579

Submission Number:
Michael Doucette
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Reading the request for comments I feel compelled to write tou to let you know my beliefs merged with the general consensus of other eye medical professionals. On one hand the question of should a PD be included with a refraction has one benefit. That is that it allows a patient to order glasses on line and save money. The down side to this is first and foremost is that a doctor does not take a PD measurement, an optician does. An optician cannot write a prescription therefor the doctor adds a new mesurment to the get a prescription. This will result in the cost of a refraction to increase. The second thing is that a PD gives you only one measurement and that is your horizontal mesurment. your eye needs to be in the center of a lens. So you are still without a seg height which is a vertical mesurment. This can only be measured once a frame is in hand. This is why an optician makes the mesurment. The person selling the glasses takes the measurements. They also provide expertise with frame selection. Certain frames work well and inversely certain frames work poorly with a given prescription. These are things online glasses sales cannot help a patient with. Secondly when you buy glasses the optician adjusts the glasses and frames so that it optimises your viewing. Things like face form and pantiscopic tilt cannot be fixed online. By allowing and making it easy and possible to buy online you ask a practice to fix and adjust for free. Well this will become a thing of the past. We will stop doing courtesy adjustments because our money comes from our expertise and knowledge. Just like if you have a child in braces you cannot expect that another orthodontist will do an adjustment for free. You can't expect an Optemetric practice to do the optician work for someone else's work for free. This all starts to add on to the cost of an online glasses sale. I say this honestly and truthfully it can be dangerous to buy glasses on line. A miss made pair of glasses even with all correct mesurments can cause double vision. Even if things are right but is poorly adjusted. Poor face form or a not enough pantiscopic tilt causes distortion. Some of these things can be dangerous others can cause permanent damage to the patients ability to see. The bottom line in our practice we let patients know if they want to save money go to Walmart not online. We may loose a few sales of glasses but I am sure we won't loose a lot of money because we will increase our refraction fee and introduce a fee to adjust glasses. I was reading what a doctor wrote the other day that they charge more then a nominal fee for the adjustment. One person I talked to said in his optical shop he makes on average $200 per pair of glasses and he said he will start to charge $100.00 for adjustments for glasses that come from another source. Part of the cost is all the knowledge that comes to take care of our patients. I hope this helps. Keep in mind the take away is that savings will not follow online glasses sales.