16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00684

Submission Number:
00684
Commenter:
Shirley Parent
Organization:
Opticians Association of Georgia
State:
Georgia
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Ophthalmologists and Optometrists are healthcare professionals who > provide primary vision care ranging from sight testing and correction to > the diagnosis, treatment, and management of vision changes. Both > Ophthalmologists and Optometrists have the ability to write an accurate > vision prescription for both contact lenses and spectacles. > > Once a vision prescription is written, a qualified optician then > determines the placement of spectacles in a fitting process that > includes calculating a /Pupillary Distance Measurement (PD) and a > Segment Height Measurement (Seg Height) to ensure a proper fit and > proper vision for a patient. /These are two very distinct processes with > different tools and expertise needed. > > /**/ > > Requiring the addition of a PD Measurement to the vision prescription > would force an optician by law to use that measurement even if the > measurement provided is incorrect. It is essential to the health of the > patient that a trained optician evaluate the vision prescription and a > patient's vision history in order to ensure that the proper measurements > are taken. This also leads to the question as to who would be legally > responsible for the spectacles that were dispensed. Would it be the > person who wrote the vision prescription with the PD Measurement or the > optician who filled the prescription based on the measurement of a third > party when it was incorrect? > > In addition, responsibility for remaking spectacles normally falls on > the dispenser (Optician) and the lens supplier. Using third party > measurements would put an unfair financial burden on the actual > dispensers of the spectacles to correct a third party's error in > measurement, which could be passed along to the patient. > > Also, requiring the addition of a PD measurement to the vision > prescription would possibly require Ophthalmologists and Optometrists to > purchase expensive measuring equipment which essentially makes them > opticians as well as eye examiners. Ophthalmologists and Optometrists > would then be forced to pass the expense of the any new equipment and > the time needed to take the measurements to the patient, thus increasing > the cost of an eye exam for the patient. > > The Eyeglass Rule requires a patient to obtain an updated prescription > more frequently than the patient feels is necessary. We advocate that a > yearly eye exam is needed for the protection of the patient; however we > would not be opposed to accepting a prescription written within a > two-year period, unless medical circumstances require a shorter duration > dictated by the prescribing Ophthalmologist and Optometrist. > > We also advocate that all vision prescriptions for both contact lenses > and spectacles should be verified by the prescribing Ophthalmologist and > Optometrist and that this process should be heavily enforced to ensure > the safety of the patient. The Contact Lens Rule currently requires an > eight hour period (business hours) for a vision prescription to be > verified. The same standard should be required under the Eyeglass Rule. > There is currently a loop-hole in the Eyeglass Rule that allows > dispensers to fill prescriptions without this verification process, > which puts the patient in harm's way. > > Finally, we advocate that dispensers (Opticians) should be responsible > for the measurements they personally take for the making of prescription > eyewear, not Ophthalmologists and Optometrists. Thus meaning that the > /Pupillary Distance Measurement (PD) should be taken by a trained > optician who would be making the spectacles and the PD Measurement > should not be a part of a patient's written prescription in order to > protect the patient from potential serious eye health risks./ > --