16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00619

Submission Number:
00619
Commenter:
Howard Rosenblum
State:
Tennessee
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I am trained as an ophthalmic surgeon. Optics and refraction are inherently part of my medical training. I can prescribe glasses. I do not know how to FIT glasses, take optical inter-pupillary distance measurements, measure facial asymmetries, segment heights, or the many other variables that opticians are trained for. The cost of providing care to my patients will increase if I must hire my own optician or optometrist. As I tell my patients, the correct prescription is only part of what goes into making the proper glasses. Fitting and choice of lens maerial, base curve, segment height adjusted to facial features, task assessment, etc. is a whole other process. I have never incorporated measurements for fitting glasses in my prescriptions. I rely on trained professionals for that. Please vote against requiring such additional assessments to my ability to prescribe spectacles for my patients. Thank you for your serious consideration.