TN Licensing Board Declaratory Order

[wabmorgan]

Bump

[chip anderson]

There are enough CE hours out there for free. So why should the cost of same matter?
In fact 90% of those we have to sit through are basic BS and sales pitches. So what has
"education" got to do with the matter. Unfortunately and in part because of the aforementioned
aspects of "education" most of us attend CE courses only for certification, not knowledge. Didn't
used to be that way.

Chip

[tmorse]

The part of this that is BAD for us is requiring only the LDO and apprentices being the only ones able to do anything. This may cause a temporary wage war but in the long run it will lead to lower wages for LDOs at the point that there are more LDOs in the market place.

Not the experience in Ontario, Canada... Only LDO's and apprentices can dispense and for the last 40 years... yet wages still the highest in Canada and plenty of work.

[HarryChiling]

The big picture is that TN opticians not being able to perform vision screenings means that children in the state that are currently benefiting form vision screenings will be taking one step back in eyecare. Forget pay is licensure is revoked, think about the many consumers that will get progressively worst eyewear, look at current posts on this forum for news about TX opticals provideing shoody eyewear, look at NY opticals not having licensed opticians on staff. These are stories ripped from the current news about the alarming state of eyecare. I am afraid that corporations have done major damage to the reputation of our profession and have doen everything within their power to make dispensing look like a cheap parlor trick instead of the art and science it is. I wish TN good luck in this trying year and if I can dig up any dirt for you give me name, rank, and serial number.

[wabmorgan]

One could only hope that would be the outcome here.... but I doubt it.... especially given the highly "retail" enviorment in the US.

Typically though.... if you increase the number of LDOs, pay goes down becasue of a lack of demand.

If our licinsure get revokes.... it will lead to most LDOs leaving the field.

Would you work for half of what you were making???

[JennyP]

For those who aren't familiar with some of our TN regulations:
1) Each Licensed Optician (who is eligible by virtue of having been licensed long enough and who is "in good standing" with the board) may have 2 apprentices.
2) Applicants for apprenticeship are screened and many who apply are rejected or told to reapply for various reasons.
3) There is ONE school for opticianry in TN, and it is not centrally located in the state, or even in a highly populated area. (I know because I graduated with an A.S. in their 1st class back in '73!) This community college program begins a new class of students every TWO years, limiting the number of potential graduates and potential licensed opticians.
4) Even if you enroll and study in the college program you still have to pass the ABO and NCLE and the state practical exams as do the apprenticeship people.
5) Our continuing ed credits required for maintaining our licenses must be via proctored and face-to-face classes, not mail-in or online study guides (which may be good for review and learning even if not for credit).
6) There are not enough licensed opticians in TN to meet the demand of the regulations and still maintain customer-friendly hours and convenience (ie: driving less than 10 miles from home).

Now for the rant:
I am licensed here in TN. I work at a chain store. I am not salaried. Once upon a time it was my goal to manage one of our stores. For 7 years I worked as a sales supervisor (key holder) AND optician (non-salararied, basically a token supervisor with no extra benefits and many more headaches). I didn't have the highest #s and I had some grey hair which may have interferred with my goal of moving up to salary. I finally figured out that it was in my best interest to step down from the key holder position and concentrate on what I did best: customer service, trouble shooting and dispensing.
Recently it has been a blessing that I did not have the added burden of management responsibility. My husband has been very ill and has had 5 brain surgeries and bypass heart surgery in the last 18 months and two episodes of blood clots that had to be treated with time in the hospital. My store's management team has finagled the part time use of opticians from 2 of our other stores to cover my days off and any unscheduled absences as we had one wonderful optician retire and 2 others seek other positions. I currently have one apprentice and I am in the process of trying to sign up a second apprentice.

I think I work with the finest team in the city, maybe in the state, and they know that they can call on me when any optical question arises (I may not know all the answers but I have a lot of great references to tap!) Some of my team have better fashion sense in their little fingers than I have in my whole body, and I think we compliment each other in skills and abilities. I think its a shame to deny our customers/patients/clients their skills simply because they don't have a licensed optician to sign up under. (I know on busy Sundays when we have only 2 people working our retail floor and a store full of shoppers needing help and wanting glasses, heaven is definitely not the word that comes to mind! I'd hate to think our TN Board plans to encourage this kind of licensed h**l.
We need more schools and better promotion of our specialty with good pay. It won't come overnight.
I, for one, will quit if it gets worse. I do NOT need the stress.

By the way: Roy, last year you said it would be like this!
Hey, when are you coming back to Chattanooga??

[Roy R. Ferguson]

Hi All:

This thread has slipped slightly so let me address a copy of issues that has popped up. My company, The Learning Curve, is that group that supplies continuing education to opticians in Tennessee. Is this something I wanted to do? Not really. The courses began in response to requests from opticians throughout the state who felt alienated from the state society. Their complaints were wide and varied but I do not recall one concerning cost.

In Tennessee we have one opticianry program that is located in the Eastern part of the state. While Director of this program in the early 1990’s, I wrote and proposed a distance learning program designed to provide an educational component for the states apprentices. The idea was to teach this coursework until a sufficient demand was demonstrated in an area to justify an additional opticianry(s) program. This was vehemently opposed by the state society.

In 1992 when the OAA adopted a minimum education resolution, the Tennessee Dispensing Opticians Association (TDOA) was the only state society that voted to oppose the resolution. In later years the organization was offered, and refused to support, two college programs designed to provide college degrees to licensed opticians in the state.

Twenty years ago the TDOA was arguably one of the finest state societies in the United States. When the past few years are examined, beyond paying a lobbyist and the vague “fighting for our license” argument, it is difficult to locate positive ideas, positions, or programs espoused by the group. The organization did support the resent declaratory order that I’ll discuss in another post.

Respectfully,
Roy

[Roy R. Ferguson]

Hi All:

To examine the practical aspects of this declaratory order on the Tennessee licensed optician, consider the optician who is opening an independent dispensary. The employees must include one licensed optician who can directly supervise no more than two apprentices registered under that license. If the optician goes on vacation, or becomes ill and does not wish to close the operation, another licensed optician must be hired and signed up as a supervisor. That is an impossible process to accomplish on short notice.

If one, or both, apprentices become ill or pregnant, a short term unlicensed replacement cannot be hired since a Tennessee optician can only supervise a maximum of two registered apprentices. The Optometrist down the street can open a similar operation, staff it with unlicensed “fashion consultants,” and never visit the operation. In Tennessee these unlicensed employees can fit both eyeglasses and contact lenses without direct supervision from the Doctor.

Since store managers and district managers of optical chains and dispensaries in Tennessee must be licensed opticians, watch for these positions to be either eliminated or the positions renamed in the near future.

Finally, opticians cannot perform vision screenings. Does this mean that the licensed optician working with an Optometrist or Ophthalmologist cannot do vision screenings at a health fair? Does this mean the students enrolled in the Roane State Community College Opticianry Program can no longer do vision screenings in the community? What about the prevention of childhood blindness through the use of the PhotoScreening camera? Does this mean the Licensing Board would rather children go blind than allow an optician to participate in the program? Has the Board decided that the only Tennessee citizen not qualified to perform vision screenings is a licensed optician?

The bottom line is the TDOA supported this declaratory order and all the ramifications. While action was intended to apply to chain firms in Tennessee, the final order appears to be much broader.

Roy

[Stormy]

I am not licensed in Tn.but am very interested in what's going on there.I'm licensed in South Carolina.The law here clearly states that penalties for violations of it can be imposed against a corporation, association or person aiding and abetting in a violation.However the board insists that they only have jurisdiction over a licensed optiician. If this is true who has jurisdiction over the corporation etc... and at what point do they step in if a violation has occurred?Thus far it appears that some of the(non-licensed)decision makers are in no way being held accountable for their actions.
I would love to get some feedback from optcians holding licenses in other states. It may help to shed some light on the REALLY big picture.Let's face it, the big chains already have their pie chart. We are all just looking at a slice of it.

[chip anderson]

This is one of the reasons why I often say: "Be carefull what you wish for" in licenseing and legislation. First thing you know those that should not have any authority over you are making the rules.

[wabmorgan]

Bump

[Stormy]

[quote=Roy R. Ferguson;223811]Hi All:

To examine the practical aspects of this declaratory order on the Tennessee licensed optician, consider the optician who is opening an independent dispensary. The employees must include one licensed optician who can directly supervise no more than two apprentices registered under that license. If the optician goes on vacation, or becomes ill and does not wish to close the operation, another licensed optician must be hired and signed up as a supervisor. That is an impossible process to accomplish on short notice.

If one, or both, apprentices become ill or pregnant, a short term unlicensed replacement cannot be hired since a Tennessee optician can only supervise a maximum of two registered apprentices. The Optometrist down the street can open a similar operation, staff it with unlicensed “fashion consultants,” and never visit the operation. In Tennessee these unlicensed employees can fit both eyeglasses and contact lenses without direct supervision from the Doctor.

Since store managers and district managers of optical chains and dispensaries in Tennessee must be licensed opticians, watch for these positions to be either eliminated or the positions renamed in the near future.

Finally, opticians cannot perform vision screenings. Does this mean that the licensed optician working with an Optometrist or Ophthalmologist cannot do vision screenings at a health fair? Does this mean the students enrolled in the Roane State Community College Opticianry Program can no longer do vision screenings in the community? What about the prevention of childhood blindness through the use of the PhotoScreening camera? Does this mean the Licensing Board would rather children go blind than allow an optician to participate in the program? Has the Board decided that the only Tennessee citizen not qualified to perform vision screenings is a licensed optician?

The bottom line is the TDOA supported this declaratory order and all the ramifications. While action was intended to apply to chain firms in Tennessee, the final order appears to be much broader.

Roy Some of these positions may be eliminated.And some of them should be!At the disrict level I would imagine that many don't have a clue,at least that's been my experience.Even at the regional level I have seen people in power that came from loss prevention......Huh? Yeah?

[wabmorgan]

W
huh???

[BoardPetitioner]

Hi All:

If the optician goes on vacation, or becomes ill and does not wish to close the operation, another licensed optician must be hired and signed up as a supervisor. That is an impossible process to accomplish on short notice.

Is this not what optometrists and all other health care providers must do if they are sick or go on vacation? If an optometrists wishes to provide exams or services while on vacation or sick they normally have someone with proper credentials fill-in or else do not provide them. They do not simply let anyone else perform their duties who is not an OD or MD. Why should opticians be encouraged to do so? Are you saying our duties as described in our scope of practice are not important enough to be performed by only licensed opticians? Isn't that what the retail chains have been trying to say for many years in many states?

The Optometrist down the street can open a similar operation, staff it with unlicensed “fashion consultants,” and never visit the operation. In Tennessee these unlicensed employees can fit both eyeglasses and contact lenses without direct supervision from the Doctor.

Where in the state code or State Board rules for Optometry or Opticianry do you find a statute or rule that approves or condones unlicensed employees fitting, adapting, or dispensing ophthalmic materials or services. I have found only the opposite according to TCA 63-8-102
(12) “Practice of optometry as a profession” means:


(C) The orthoptic training, the adjusting, or fitting or adapting of lenses or prisms or eyeglasses or spectacles to remedy or relieve defects of vision or muscular anomalies; or
(C) The orthoptic training, the adjusting, or fitting or adapting of lenses or prisms or eyeglasses or spectacles to remedy or relieve defects of vision or muscular anomalies; or
(D) The supplying, replacement or duplication of an ophthalmic lens or frame;



and TCA 63-8-113
a) It is unlawful for any person not duly licensed in accordance with this chapter to:
(1) Engage in the practice of optometry;(3) Attempt by any means whatsoever to determine the kind or power of ophthalmic materials needed by any person to remedy or relieve defects of vision or muscular anomalies;(8) Make measurements involving the eyes or the optical requirement thereof for the purpose of prescribing ophthalmic materials;(9) Unless otherwise authorized by law, fill an order or prescription for ophthalmic materials; or (10) Unless otherwise authorized by law, sell or dispense ophthalmic materials.



and TCA 63-8-113
(c) It is unlawful for any licensed optometrist to:

(4) Appoint agents or other persons to take orders for optometric services or ophthalmic materials;


63-8-114. Exemptions. —



Nothing in this chapter shall be construed:

(5) To prevent licensed dispensing opticians from preparing, adapting and dispensing ophthalmic materials within the scope of their lawful practice.


Am I missing something here or is there a statute somewhere stateing that ANYONE other than an apprentice, licensed optician, or optometrist can prepare, adapt, sell, or dispense ophthalmic materials? Please let me know so I may use it for future reference. Does it not seem odd that only dispensaries owned by opticians would be required to provide prescription ophthalmic materials by licensed or apprenticed staff only? And if all who are licensed under the "Professions of the Healing Arts" (Title 63 of TCA) are required to keep the health and well-being of the consumer upper-most at all times, as the "Code of Ethics" states, then shouldn't the consumers in TN be entitled to prescription eyewear prepared and dispensed by those credentialed to do so?

Since store managers and district managers of optical chains and dispensaries in Tennessee must be licensed opticians, watch for these positions to be either eliminated or the positions renamed in the near future.

Renaming would be seen by the board as a ploy to circumvent and I believe would be addressed as such. Eliminating the positions would not be feasible as there would be no accountability, direction, or productivity without management.

I hope I quoted this correctly? I tried to edit this to address only the lines quoted, I am not trying to change any of the authors comments, only respond to them.

[BoardPetitioner]

What good is it anyway, to be licensed in a profession of the healing arts in TN, if you let persons with no license, training, certification, and/or experience perform some or all of the duties of your particular licensed profession and those same persons directing you on how to perform the duties you studied, trained, tested, and paid to obtain a license for? Is being an optician really only worth a few dollars more to hang your license in a dispensary and let anyone and everyone perform your licensed dutiues because your non-licensed supervisor said it was OK? How many of your duties are you willing to relinquish before your licensed services or a fellow optician's are no longer required because there is enough non-licensed staff available? How many of you know opticians whose hours were cut but non-licensed sells and services were still being provided? Maybe it's happened to some of you. If ODs or MDs let a person who is not licensed refract, just one small, mechanical portion of their overall duties, then how long before that same person is writing RXs or even attempting foreign body removals? The consumers' health and well being is the licensed health care providers responsiblity, are there really some of you who truly feel that this can be provided for better by persons not licensed and in many cases hired without any experience? I hope surgeons don't use this same idealology! The laws referred to in this declaratory order have always been in place. They were put in place to protect the citizens of Tennessee from receiving ophthalmic goods and services from persons who do not have a clue. They were put in place to protect licensed optical professions from being performed by people not qualified to do so. There are no other reasons for putting them in place. Why should they not be clarified and enforced?

[wabmorgan]

Post Deleted

[Roy R. Ferguson]

Hi All:

If an optometrists wishes to provide exams or services while on vacation or sick they normally have someone with proper credentials fill-in or else do not provide them. They do not simply let anyone else perform their duties who is not an OD or MD.

That is very true and an excellent point. In this case, the Doctor simply obtains the services of another OD or MD and the office is covered. In the event of sudden illness, the licensed optician in Tennessee may also hire a temporary replacement. This replacement may not supervise the apprentice(s) registered to the first optician until approved by the Board. This is a lengthy process at best. Until Board approval is received the apprentices may perform no services, even under the supervision of this licensed optician. For the independent optician this is a sizeable hurdle.

Where in the state code or State Board rules for Optometry or Opticianry do you find a statute or rule that approves or condones unlicensed employees fitting, adapting, or dispensing ophthalmic materials or services.

In 1988, a complaint was filed with the Board of Dispensing Opticians regarding two Optometrists operating a satellite office staffed with an unlicensed salesclerk. The OD’s were physically present in the office four hours each week. During the other 36 hours the receptionist/salesclerk dispensed eyeglasses and contacts. This was investigated and confirmed on two different occasions by state investigators. On April 26, 1993 the Division of Health Related Boards wrote:

The complaint you filed against Dr. XXX XXX has been received and reviewed by both the Board Consultant and our legal staff. Based on our review, it was determined that no action should be taken at this time.

The reasons for that action are as follows:

1. No violations of the Practice Act.

Does it not seem odd that only dispensaries owned by opticians would be required to provide prescription ophthalmic materials by licensed or apprenticed staff only?

Another excellent point! Please refer to the previous paragraph.

Roy

[BoardPetitioner]

Hi All:

If an optometrists wishes to provide exams or services while on vacation or sick they normally have someone with proper credentials fill-in or else do not provide them. They do not simply let anyone else perform their duties who is not an OD or MD.

That is very true and an excellent point. In this case, the Doctor simply obtains the services of another OD or MD and the office is covered. In the event of sudden illness, the licensed optician in Tennessee may also hire a temporary replacement. This replacement may not supervise the apprentice(s) registered to the first optician until approved by the Board. This is a lengthy process at best. Until Board approval is received the apprentices may perform no services, even under the supervision of this licensed optician. For the independent optician this is a sizeable hurdle.

Where in the state code or State Board rules for Optometry or Opticianry do you find a statute or rule that approves or condones unlicensed employees fitting, adapting, or dispensing ophthalmic materials or services.


In 1988, a complaint was filed with the Board of Dispensing Opticians regarding two Optometrists operating a satellite office staffed with an unlicensed salesclerk. The OD’s were physically present in the office four hours each week. During the other 36 hours the receptionist/salesclerk dispensed eyeglasses and contacts. This was investigated and confirmed on two different occasions by state investigators. On April 26, 1993 the Division of Health Related Boards wrote:

The complaint you filed against Dr. XXX XXX has been received and reviewed by both the Board Consultant and our legal staff. Based on our review, it was determined that no action should be taken at this time.

The reasons for that action are as follows:

1. No violations of the Practice Act.

Does it not seem odd that only dispensaries owned by opticians would be required to provide prescription ophthalmic materials by licensed or apprenticed staff only?

Another excellent point! Please refer to the previous paragraph.

Roy

Roy,
I am not argueing that the process of transferring sponsorship could not be made easier by possibly printing the form from the board web site and faxing it to the board administrator or something of that nature for those rare emergency ocassions. Maybe that is something you or the TDOA can propose to the board. What I am argueing is that the best way to have dispensary coverage is by qualified personell. NOT by having one license in a dispensary with seven sales techs or "stylists" fitting progressives and the like under the "umbrella license". You surely would agree with this.

As for the case from 1993 you refer to above, I couldn't agree more that the board advisors and attorneys do as little as possible in efforts to stop non-licensed services. As you know, the actual six member board never even views a complaint until the investigations division and the board advisor and attorney decide it is important enough for the board to hear. In this particular case however, optician law states that nothing in our laws should be construed as requireing the licensure of employees of ODs or MDs because our statutes do not supercede theirs. But the optometry statutes from best I can tell does prohibit this. Perhaps the complaint should have been made to the optometry board. Although I am not sure if their advisor would have ever let it go before that board either. Maybe if we can get opticians to quit complaining about not being able to perform vision screenings and complain about people performing their entire job description without license, then opticians could get some beneficial things accomplished. And by the way, as all can see, my question referring to vision screenings was not about whether we could perform them, but whether we were allowed to solicit business for independent ODs with screenings and other means. The answer, as you know, was "NO", the answer was not at any time given as "No opticians can not perform vision screenings." The question was asked by counsel as written in the petition, then answered with the voted response of "NO". The Final order you posted here, was the Board attorney's final rendition of the proceedings. It was also requested that the supervisor order should read "dispensary managers and the next level of supervisors should be licensed" so that the psosition title could not just be changed, the board attorney rejected that as well. So much for state employees huh. Let me know if you have any more insight on the OD licensed coverage question, it is most interesting and perplexing.

[wabmorgan]

Bump

[BoardPetitioner]

This "umbrella" you reference is exactly the way it has been defined in the past.... and now why what the board has "defined" as law will cause so many vast problems.

The way who defined it, your employer? To my knowledge, this is the first declaratory order issued by the Optician Board clarifying misinterpreted satutes. You're right though, plenty of people who did not know what they were talking about have said that anyone with any amount of experience could sell and dispense as long as a license was "somewhere in a 5 mile radius" etc. Keep in mind we are governed by the same health division as pediatricians and other doctors. Would you want your children who were ill to have an appointment with a pediatrician, only to be seen by some person who (unknown to you) used to work in shoe sales a month before? What would you do if this "fill-in" gave your children the wrong prescription for their illness and they got sicker? How is it any different if we let people with no experience fill prescriptions that we are supposed to fill? The only "vast problems" I see enforcing the statutes that have ALWAYS been there is problems for the corporate retail chains who have knowingly and purposely violated them in the past, and for the non-licensed people encroaching on our profession who either have never bothered to get licensed because they did not want the responsibilty or were not intelligent or disciplined enough to pass the tests.

I think you will find few complaining about this part of what the board "defined" What the final order did fail to do was to define that associates of the dispensary may not advertise in any way, form or fashion for the optometrist.

I have already seen several complaints about screenings. As I said and Roy can confirm, the board answered "NO" to solicitation for ODs in question #4 of the petition. The final order was the Board Attorney's draft of it, however it was signed and approved by the Chairman of the Optician Board.

Should does not equal MUST. He would have done the chains a favor with the wording of "should be". Frankly, I doubt the board can regulate the management structure of a corporation regardless of what it may have "defined" as law.

This was my typing error, counsel DID submit the word "must" in his draft. If the law was followed the way it was written which says even stockholders and officers must be licensed (63-14-103 same as other health profession statutes) then it would be a simple process of regulation to pull a stockholders license if they directed lower employees to violate state health codes. You see, if you are required to be licensed to be a stockholder, and if your license is revoked, you would lose stockholder/officer status or district/regional mng. status for that matter, then I believe those officers, stockholders, regional and district managers would be a lot more careful of how they "interpret" regulations and what they direct opticians to do in order to make another buck! That is the way the statute reads and the intelligence behind including it in most health care profession statutes. Why do you think three powerful attorneys from the NAOO were sent to oppose me at the declaratory hearing? They knew the ramifications if board interpreted that statute correctly. They knew they were not compliant. And in your response above you said we would have done them a favor if we used the word "should", Roy also stated that they would just "change titles or eliminate positions" both of you are stating that you know the retail chains will try to circumvent even a declaratory order, let alone the state code for their benefit and our detriment. And yet both of you have done absolutely nothing but point out what I or the Board or the TDOA has done wrong or failed to do. Or to point out they may try to take our licenses, isn't that what they are doing now by sending attorneys to oppose an order that says you have to be licensed to sell glasses? What good is the license if everybody else can perform your job anyway?

Why are you so confused on what people have the best interests of opticians in mind?

[wabmorgan]

Bump

[Barry Santini]

What I am argueing is that the best way to have dispensary coverage is by qualified personell.

Here! Here! I say it DOESN"T matter whether someone is licensed...or not. As long as the skill set is there, and business is held accountable through licensure of the BUSINESS.

Or, perhps, we need give the lay public an "exam" of competancy at the cash register when they're purchasing OTC *anything* optical...

????

Barry

[Roy R. Ferguson]

Hi All:

I hate to beat this very dead horse, but it is necessary to point out an obvious point one more time. We are attempting to breathe life into a very malfunctioning apprenticeship system that has never provided the enrolled person a proper background and continues to do a disservice to the consumer. This is a highly technical field requiring knowledge with breadth and depth impossible to present, or retain, in an on-the-job situation. This can only be accomplished in a formal educational setting. The heart of our current problems in Tennessee can be traced directly to the archaic, nonfunctioning, apprenticeship program.

We had the opportunity to enrich the Tennessee apprenticeship program with a formal educational component in the early 1990’s. The plan was to first provide the apprentices with a college-level certificate program taught on-demand by adjunct faculty. In this way we would have been able to track where the demand existed, allowing us to open one or two more opticianry schools in the state. Eventually, the apprenticeship program could have been replaced. This program was strongly opposed by the TDOA and went down in defeat. Actually, “strongly opposed” is an understatement. Words such as “poisonous,” “venomous,” “malevolent,” “caustic,” and “acrimonious,” are perhaps more accurate. If you have any questions regarding this ask my former students or the current vice-president of the TDOA.

We should not be arguing about whether an optician is qualified to supervise and teach two opticians. In my opinion most are not and this is why no other health related field clings to this method of imparting knowledge. This must be done in a formal setting. Teaching is a difficult task that requires preparation, dedication, and involves a large number of skill sets that must be mastered. We are here today discussing these issues because in the 1990’s the TDOA chose to embrace ignorance and mediocrity rather than knowledge and excellence.

I will now apologize to all for my rant. While I predicted these problems many years ago, I take no pleasure in having to witness the outcomes.

Roy

[HarryChiling]

Hi All:

I hate to beat this very dead horse, but it is necessary to point out an obvious point one more time. We are attempting to breathe life into a very malfunctioning apprenticeship system that has never provided the enrolled person a proper background and continues to do a disservice to the consumer. This is a highly technical field requiring knowledge with breadth and depth impossible to present, or retain, in an on-the-job situation. This can only be accomplished in a formal educational setting. The heart of our current problems in Tennessee can be traced directly to the archaic, nonfunctioning, apprenticeship program.

We had the opportunity to enrich the Tennessee apprenticeship program with a formal educational component in the early 1990’s. The plan was to first provide the apprentices with a college-level certificate program taught on-demand by adjunct faculty. In this way we would have been able to track where the demand existed, allowing us to open one or two more opticianry schools in the state. Eventually, the apprenticeship program could have been replaced. This program was strongly opposed by the TDOA and went down in defeat. Actually, “strongly opposed” is an understatement. Words such as “poisonous,” “venomous,” “malevolent,” “caustic,” and “acrimonious,” are perhaps more accurate. If you have any questions regarding this ask my former students or the current vice-president of the TDOA.

We should not be arguing about whether an optician is qualified to supervise and teach two opticians. In my opinion most are not and this is why no other health related field clings to this method of imparting knowledge. This must be done in a formal setting. Teaching is a difficult task that requires preparation, dedication, and involves a large number of skill sets that must be mastered. We are here today discussing these issues because in the 1990’s the TDOA chose to embrace ignorance and mediocrity rather than knowledge and excellence.

I will now apologize to all for my rant. While I predicted these problems many years ago, I take no pleasure in having to witness the outcomes.

Roy

Roy,
Well said, I was one that dd embrace the OJT because I was taught that way, but when I thin more and more about it the desire to learn was there which made me seek knowledge mroe than my employer was willing to take the time and teach. I have family that teaches and I see the dedication and the numerous hours that go into putting together lesson plans and plotting a course that ultimately leads to the student comprehending a skill. I would agree that opticians shoud embrace education and that our jbs when performed competently requires knowledge and technical skills that require more than just OJT. Sam Johnson of ROATx has beenpuching a campaign for states that don't have licensure to educate, they have partnered with NAIT in CA to provide education to opticians in the US. I am currently part of the first class at NAIT for US students and actually just finished my mid term, whihc I though was a good test overall. So far a few states have embraced it and theri are a few opticiasn that have embraced it. I got to tell you I was an optician hard pressed to avoid the education that I have anyway trough my own learning, but I find that the education isn't necessarily for me, but for my profession. If I take the opportunity to "Raise the Bar" then I stand a better chance of convincing others to do the same and after a while there shoudl be no reason that OJT will need to exist.

I can say that in all the enviornments I have worked that their has never been a structured program or a set amount of time alotted to learning on the job. OJT has just become a vehicle for cheap labor and it is being utilized by both corporate chains and independent opticals with very real consequences that are being seen across the country. I look forward to the day when OJT is gone.

[Roy R. Ferguson]

Hi All:

OJT has just become a vehicle for cheap labor and it is being utilized by both corporate chains and independent opticals with very real consequences that are being seen across the country. I look forward to the day when OJT is gone.

The NAIT program is a huge step forward for opticians in those states lacking an opticianry program or do not have access to a distance learning program. Those states using this educational vehicle have made a bold move in the right direction and are to be congratulated for this huge step forward.

My surprise when I advocated a formal education program for apprentices in Tennessee was that the opposition did not come from corporate folks or Optometry; it was orchestrated by the state society. After making a presentation regarding the program the only question was from the TDOA president who asked, “All I want to know is how much are you going to get out of this?” As a salaried faculty member, the state paid me the same if I instructed 10 students or 100. This he could not understand. The famous quote the president and vice-president of the college liked to toss my direction each time I was called in to discuss the latest TDOA complaint was from that individual. It was, “Roy ain’t teaching those students nothing.”

So, almost 20 years later, we find the same organization supporting the loss of vision screening by opticians while attempting to patch a non-existent apprenticeship program through a declaratory order. In my opinion, our problems in Tennessee are not based in the “evil corporations” or Optometry. Our difficulties were spawned and nurtured over the years by a few individuals who lurked in the shadows resisting any positive change for opticianry. Fortunately, the leadership in many other states is not as regressive.

Roy