16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00605

Submission Number:
00605
Commenter:
David Holler
State:
North Carolina
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
It has been discussed that online retailers are lobbying to require that the pupillary distance (PD) is added to eyeglass prescriptions. PDs are measurements taken by an optician fitting the patient with glasses - they are not part of a comprehensive eye examination or refraction. Despite practicing for over 17 years, I have never measured a patient's PD. Automated machines pre-testing the patient will give an estimate but it is not consistent enough to use in an eyeglass prescription. Additionally, it does not give the monocular PD which is required to make a progressive lens and/or a high astigmatic prescription. Additionally, offices are now using EMRs so if a patient completes their exam and goes out to optical to see an optician - the optician can measure the PD but adding it to the prescription creates a logistical nightmare because they would have to add it after the doctor has already completed the exam and refraction. With this new measurement the doctor would have to reopen the EMR file to then print and sign the prescription. As we all know, patient wait times is the biggest challenge in medical practices today. There should be no question in anyone's mind that if one adds steps to the process it will inherently delay the process. My other concern is when eye exams and refractions are being discussed as one in the same. Most health plans are specific that a refraction (cpt 92015) is not considered a part of the examination. Vision plans combine the examination and refraction codes for one single negotiated rate. There are online websites that are intentionally confusing the consumer into believing that they are receiving an eye examination when in fact not receiving any examination of the eye in any manner whatsoever. Nobody is looking at the eye with a slit lamp and nobody is examining the optic nerve or retina. Since glaucoma is a silent, asymptomatic disease which causes blindness - it can only be diagnosed with an eye examination. Having some online doctor sign off on online prescriptions (such is the case with Opternative.com) will allow patients with an undiagnosed eye disease to go undetected. Protecting consumers - our patients - is getting more challenging when unscrupulous online retailers are intentionally misleading the public. Allowing this confusion can and will be catastrophic and has far reaching implications. Having doctors sign prescriptions for online drugs without ever examining the patient is a only step away.