16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00620

Submission Number:
00620
Commenter:
Tina Reeves
State:
New York
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
The rule regarding the release of a person's eyeglass prescription is valid as it currently exists. Expanding the requirement that the prescription include additional information such as a pupillary distance measurement is not necessary. This measurement is the responsibility of the entity that makes the eyeglasses for the consumer. They need to be held accountable for any defects, errors and safety issues that may arise from the completion of the order. This is not the responsibility of the prescribing doctor unless that doctor takes the responsibility by agreeing to make the order for the consumer. There are many options available to a consumer to obtain eyeglasses in many price ranges while still being served by a properly credentialed individual without resorting to an unknown entity found on the internet or by mail order. Requiring this additional information from the prescribing doctor appears to be initiated by the internet and mail order vendors without concern for a consumer's best outcome; it is big business driving health care rather than leaving it in the hands of properly licensed and credentialed individuals. Allowing online purchasing of eye glasses also reduces the insurance companies' utilization of member benefits because members can not easily use those benefits to purchase eye glasses online. Those that can or choose to use those benefits have to self submit to their insurance companies which complicates their access to benefits. This is not in the consumers' best interest either. There is no good reason to require such additional information be provided to consumers when they receive their eyeglass prescription. It reduces the culpability of the eyewear producer and increases the liability of a doctor who has no control over the end product.