16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00589

Submission Number:
00589
Commenter:
Richardson
State:
Kentucky
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Additional information such as pupillary measurements are an element of dispensing not prescribing. It should not be a requisite of a prescription. There is a whole profession that specializes in dispensing, because taking this measurement requires someone specially trained and the function of a spectacle Rx is dependent on this. I would assert that many prescribers are not well versed in taking this measurement. I personally have an investment in a $9000 machine that carefully takes pupillary measurements in a physiologic fashion. I provide this service, via my optician and double checked by my optician, free of charge for patients that consume product from our office. Additionally, the entity providing the final product should be responsible for the measurement, because many call backs and complaints arise from a mis-marked pupillary measurement. If the pupillary measurement becomes a requisite to the prescription, I will increase the cost of all of my prescriptions to reflect the time and materials necessary to do this correctly. This will likely double the cost of my prescriptions and create friction with those dispensing the product and potentially receiving call-backs. Again, it is necessary for the dispenser to do this measurement.