16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00820

Submission Number:
Bradley Goldberg
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
As an Optometrist I would like to comment on the FTC's proposal to require a Doctor to measure and supply to a patient their Pupillary Distance (PD). I do not feel that this modification of the eyeglass rule is necessary and that this rule change would be burdensome to a whole class of providers.It also could result glasses being made incorrectly and raise the cost to providers of care. As an Optometrist I rarely measure the papillary distance (PD) when I do an examination.I center my phoropter's lenses over the patient's eyes but I almost never take a PD measurement.That is the responsibility of the optician selling them their glasses.If I own the optical shop that sells the glasses then my opticians measure the PD.If the patient leaves our premises and takes the Prescription elsewhere, then the sellering optician takes the PD.The measurements we take before making up glasses cost our staff time and therefore costs us money.This time and cost is part of the cost of a pair of glasses.The requirement that a PD be included in a prescription is a cost shift from the seller of the eyewear up to the prescribing doctor.Many doctors are not involved in the sale of eyewear at all.Ophthalmologists as a rule do not.Most ophthalmologist never learned how to measure a PD and their staff do not know how to accurately measure a PD as well.Forcing an untrained person to give an accurate measurement can result in improperly made eyewear.This would add to the cost of the businesses making up the glasses if they had to remake the glasses.If the manufacturer did not remake the glasses at no charge,then the consumer would bear the cost of the glasses or they would be useless.Either way the costs would go up. Many optometrists work in a host environment where they perform the examination only and the optical shop sells them the glasses. One of the ideas about mandating the release of a PD was to allow consumers the ability to purchase eyeglasses online.Prior to the advent of this business model no one complained that their PD was not included with their prescription.Newer online eyeglass companies such as Warby-Parker have developed the technology to they claim to accurately measure the PD online.If the technology is available to measure the PD online & the retailer can do it,then why even mandate that the Doctor take on this task?The retailer should bear the burden of measuring and manufacturing the glasses correctly.Many consumers think that eye doctors only determine a person prescription.This is incorrect.Doctors also assess the health of the eye and general health as well. There is a huge obesity epidemic occurring in America and as a consequence a rise of diabetic eye disease. Forcing the doctor to extend an Rx beyond what is in the best interest of the patient's best health is dangerous and will result in more people going blind, becoming disabled or actually dying from diabetes because their condition was not caught early enough.