16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00599

Submission Number:
00599
Commenter:
Jennifer Lehman
State:
South Carolina
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
"Eyeglass Rule, 16 CFR part 456, Project No. R511996 In response to the above Eyeglass rule there are 2 areas to consider: Regarding General Issues: The current rule does conflict with the current Medicare decision that the service to actually calculate the patient's prescription, The Determination of Refractive State, is not a covered service. Therefore, Medicare consumers are being charged a fee for the service which produces the prescription. The Medicare handbook clearly states they do not pay for Refractions. The rule should include the wording that the testing required to produce the prescription may not be a covered service and therefore require the patient to pay for the service. The Rule should absolutely be modified in an effort to reduce confusion for the consumer when a provider's office tells them one thing and they claim something different. In regards to the specific issue of the definition of "prescription" being modified to include pupillary distance-- my answer is that it should not. The pupillary distance (aka PD) is specific to each individual consumer and the specific frame that the patient has chosen. Both providers and consumers would be setting themselves up for failure by requiring a measurement on something that may not exist yet (such as picking out a frame or purchasing a frame from one office and having glasses made somewhere else). This also would cause problems for those consumers who take the eyeglass prescription from their provider and order their glasses online. It would be inaccurate if they also purchased a frame online and then sent in for the glasses to be made with a false PD reading. The cost on small businesses would be negative, as patients who do order their glasses outside of a physician's office and had glasses made with an incorrect PD on it would seek corrective action from the prescribing physician--expecting them to correct the issue.