16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
1. The definition of prescription should not include pupillary distance as it is an extra step and dependent on the type of prescription being filled. For exam reading glasses vs. computer glasses vs. distance glasses would have different pupillary distance specific to each need. And pupillary distance alone does not justify a correct prescription because you also need an optical center, which can only be taken when frame is present. If both measurements are not taken correctly with eyeglass frame present, consumer's would get induced prism causing headache, eye strain etc. This rule would affect specially small businesses as it would drive more customers away from small businesses and when the prescription is made wrong, they go back to their eye doctors costing extra time. 2. As a courtesy, most offices do provide a duplicate copy of prescription to patients upon request. This should not be required by law because it already is done. It would be like passing a law that everyone must wash their hands after using the restroom, most people already wash their hands, the select few that don't shouldn't be used to punish everyone. This would cost small businesses in staff time as well as paper for every patient who misplaces their prescription. This modification would not benefit consumers as it already something already done. 3. Most third party company's keep record of all their past orders and send out verification requests to fish for new updates to patient information with-out patient approval. We have had many occasions where we call a patient to let them know if the verification is approved or denied and many times the patient did not request a verification, or even place an order through the third party company in several years. Modifying this law would just give them more incentive to take advantage of consumers by gaining their personal information without their request. This modification would cost small businesses again in staff time and administrative costs, taking away from the time we can spend providing excellent care to our patients. This would not benefit consumers, because it would take away time from their in office experience when the staff are busy searching to provide verification's for third party company's.