16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00692

Submission Number:
00692
Commenter:
scott sanders
State:
Mississippi
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
The eyeglass rule is relatively straight forward. However online retailers place the burden of fixing/adjusting online purchases on the consumer's local eye clinics and opticals. This is often stated on their websites. Another potential issue revolves around whether a patient's pupillary distance should be included in the prescription. BOTH of these services are defined by Current Procedural Terminology (CPT) as 92340-92342 and are reimbursable. i.e. Mississippi Medicaid reimburses approximately $11 for such. 92340-92342 is defined as the "measurement of anatomical features and adjustment of frame". If the FTC changes this rule to include this in the prescription it would require these professionally defined services to be nonreimbursable for both private pay and 3rd party payers. this would result in a huge loss of revenue for eye clinics and opticals. I would also assume that the FTC could be legally challenged concerning this matter so changing the rule to include such may have legal ramifications that would need to be carefully considered.