16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00625

Submission Number:
Brittney McWilliams
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I was not yet an optometrist when the "Eyeglass Rule" was first passed but here are some of my observations since starting practice just over 4 years ago. I lease space from an optical and have no ownership in the sale of optical goods. Every patient I see who elects a refraction is given a paper copy of their glasses prescription at the end of their exam. Information given includes the Rx as well as recommended materials based on our discussions about their lifestyle, needs, and wants for their vision. If a patient elects now to purchase glasses online I offer my time at no charge to check the accuracy of those glasses. Studies have been done that show more often than not online glasses are not made to industry ANSI standards including impact resistance or safety standards. I find errors quite often in both the transcription of the Rx by the patient or online entity as well as in the making of the materials themselves. The online optical industry whittles a complex process down to purely the Rx and a pupillary distance (PD) measurement. There are multiple ways to measure a PD, all of which depend on the frames chosen and the manner in which the patient will be using said frame. For instance, if a patient elects to get reading only or computer glasses, that PD is different than someone who elects a bifocal. Any optician or brick and mortar optical has staff trained to provide such measurements once the frame and lens options have been selected. It is not possible to provide an accurate measurement before that process has been completed. I believe it is misleading for an online optical to act as if such a measurement is all that is needed for an accurately fitted pair of spectacles. Other necessary measurements include vertex distance, optical center, and pantoscopic tilt for example. All of these measurements and more are necessary for a proper fit and visual comfort. Nothing frustrates me more than seeing someone pay for a pair of unusable online glasses because these measurements were not taken into account. I've also seen the other end of this spectrum where a pair of spectacles induced headaches that led to a full medical workup for a patient including an MRI and bloodwork. How sad that precious healthcare dollars were spent because an online company sold someone a pair of glasses without being able to account for the necessary measurements and fitting of those glasses. In summary, I believe a copy of a patient's glasses prescription should continue to be released at the end of their examination. I believe that prescription cannot include information that cannot yet be measured until the frame and lens selection is complete. I believe that information should be obtained by an in person optician to allow both properly made and comfortably fitting glasses. Thank you for your time in reading my submission.