16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00580

Submission Number:
00580
Commenter:
Jeffrey Kiener
State:
Ohio
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Should the Rule be extended to require that a prescriber provide a copy to or verify a prescription with third parties authorized by the patient? No. The patient should be responsible for providing the Rx to the third party. The patient may fax, e-mail, or even attach a photo of the Rx via text message. A prescriber has to process these requests and incur a not-insignificant operating expense. This solution presents a much lesser economic burden for the patient than the prescriber. Should the Rule be extended to require that prescribers provide a duplicate copy of a prescription to a patient who does not currently have access to the original? Yes, if a small administrative fee is allowed per request. Should the definition of ''prescription'' be modified to include pupillary distance? Absolutely not. For technical reasons too esoteric to describe in a short space, pupillary distance alone is ENTIRELY inadequate to obtain correct funtionality for spectacle lenses. The FTC should not administratively decide what is acceptable practice of optometry/opticianry/ophthalmology without significant expert testimony. Please feel free to contact me for further clarification/testimony.