16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00836

Submission Number:
00836
Commenter:
Michael Alvarez
State:
Indiana
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
RE: Eyeglass Rule, 16 CFR part 456, Project No. R511996'' Having read through many of the comments, there seems to be a lot of misunderstanding regarding what constitutes an eye exam. An eye exam is an evaluation of the health of a patient's eyes and visual system and a refraction (the test to determine a patient's eyeglass prescription) is but a small part of that. The pupillary distance (P.D.) is the distance between a patient's eyes and this measurement is not taken as part of an eye exam but rather by the optician who sells the glasses. This is because a P.D. has no bearing on the ocular health of a patient. It is only needed when ordering glasses. I have been a practicing optometrist for 20 years and have not measured a P.D. since I was in school. Furthermore, since my office doesn't sell glasses, I do not even own a pupilometer (the device necessary to accurately measure the patient's P.D.). Requiring that each doctor purchase a pupilometer and then take the time to measure each patient's P.D. is unreasonable and duplicative since any reputable optician will recheck this measurement anyway. Furthermore, there are many other services provided by opticians necessary to attaining clear and comfortable vision. For instance, measuring the seg height and adjusting the frame to fit the patient's face are very important and can not be done before a frame has been selected.. Also, the optician can provide important guidance to the patient in selecting a frame that is most appropriate for the patient's needs. For instance, a patient with a very high prescription should avoid a large, square frame and would also benefit from a high index lens material. Prescription glasses are a custom product made specifically to meet the needs of each individual patient. The optometrist, the ophthalmologist, and the optician all play an important role in ensuring that each and every patient enjoys good vision and healthy eyes. In summary, requiring that doctors provide information (the P.D.) that the doctor does not normally measure and is not part of the medical record is unreasonable, wasteful, and not in the best interests of patients.