16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00752

Submission Number:
00752
Commenter:
Elizabeth Diener
State:
Pennsylvania
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Regarding the Eyeglass Rule. The great discrepancy between refund/ exchange and redo policies between brick and mortar Eyeglass dispensers and online sellers is causing patients to request refunds and exchanges from the writer of the prescription instead of from where they bought the glasses. This includes situations in which there are typographical or Rx change issues. Normally dispensers provide redo services free of charge as a professional courtesy to fellow providers and to patients if brick and mortar. Online sellers often have very short or non existent windows of time for such refunds/ exchanges and redos. They also sometimes exclude Rx changes. This creates a burden on the office of the prescriber in the form of staff time. It creates an economic burden on the patients who get glasses that may need a redo and puts the prescribing office in the financial position of being pressured to pay patients who go to online competitors. That is not standard practice in any industry and is against all sound business practices. This does not occur between brick and mortar locations. The Eyeglass Rule should therefore obtain a provision that the release of the prescription does not entitle the patient to financial recovery of losses from glasses purchased outside, or at least that in office policies stating such are legal and valid.