I think the central discussion point that divides the sides is:
1. Docs see eyewear as eyecare...need-based
2. Opticians/retail eyewear brands and corps see eyewear as want based.
Unless you can fulfill all eyeglass wearers wants today, you HAVE to accept your "care" will be fragmented.
B
Moot point in Massachusetts...
http://massoptom.org/news/newsView.asp?NewsId=194
On a side note- Our office got tired of having to produce copies of rx's that sometimes are only days old. We created a stamp that we imprint on the patients and file copy.
In red: "PLEASE SAVE THIS PRESCRIPTION REPLACEMENT COPIES $5.00".
It comes with a recommendation they take a picture with their smartphone so they can file it and make a copy if needed. It's cut way down on requests for copies.
We did have a shop down the street insisting under the Eyeglass Rule we had to provide him with a copy, which we did. I felt technically, however, we could have denied it until the fee was paid under HIPAA regs allowing a reasonable fee- But that's another thread.
In my opinion P.D.s on Rxs are just there for convenience and is not really a legal part of the Rx. Of course that may change.
As for dates of expiration, the rule is 2 years, unless there's a medical reason to shorten it. I think it's required, but could be wrong on that. I have no idea why OMDs usually omit it. I bet they don't omit it on Rxs for narcotics.
I haven't formalized a written response to the FTC yet, but it seems likely that I'll ask that the rule, while noting that their ability to stop those who wish to be DIYers is limited, include a strong recommendation that prescriptions for eyeglasses be filled, fitted and dispensed by ophthalmic professionals face to face, instead of mail-order, minimizing the frequency of diplopia and blurred vision that would increase the likelihood of vehicular accidents and falls, especially with the elderly.Originally Posted by drk
I'll probably note that the material cost savings to the consumer by using mail order fabricators will be offset by charges incurred by inspecting, fitting and aligning the medical device by opticians at brick and mortar locations, costs that are historically included in the cost of eyeglasses, while others will refuse to align the eyeglasses due to the risk of breakage, and the inability to replace or repair the eyeglasses. Shifting the responsibilty of the above to the prescriber is not an option for obvious reasons...historically, prescribers hire opticians with less education and training to perform these tasks.
The CL rule should mostly stay the same, except for non-off the shelf products (RGPs, etc.), which should be excluded from the rules, and that the responsibility for supplying a non-expired Rx, after obtaining such from the prescriber, should lie with the patient, and not the prescriber.
IV. Instructions for SubmittingComments
You can file a comment online or onpaper. For the Commission to consider your comment, we must receive it on orbefore October 26, 2015. Write‘‘Eyeglass Rule, 16 CFR part 456, ProjectNo. R511996’’ on the comment. Yourcomment, including your name and your state, will be placed on the public record of this proceeding, including, to the extent practicable, on the publicCommission Web site, at http://www.ftc.gov/os/publiccomments.shtm.https://www.ftc.gov/system/files/doc...assrulefrn.pdfPostal mail addressed to theCommission is subject to delay due toheightened security screening. As aresult, we encourage you to submit yourcomment online. To make sure that theCommission considers your onlinecomment, you must file it at https://ftcpublic.commentworks.com/f...almicruleanprm by following theinstructions on the web-based form. Ifthis document appears at http://www.regulations.gov/#!home, you alsomay file a comment through that Website.
If you file your comment on paper,write ‘‘Eyeglass Rule, 16 CFR part 456,Project No. R511996’’ on your commentand on the envelope, and mail yourcomment to the following address:Federal Trade Commission, Office of theSecretary, 600 Pennsylvania AvenueNW., Suite CC–5610 (Annex B),Washington, DC 20580, or deliver yourcomment to the following address:Federal Trade Commission, Office of theSecretary, Constitution Center, 400 7thStreet SW., 5th Floor, Suite 5610(Annex B), Washington, DC 20024.
Science is a way of trying not to fool yourself. - Richard P. Feynman
Experience is the hardest teacher. She gives the test before the lesson.
just some general comments...not in response to anybody's statements...
...but if a patient is given a copy in the first place, why do we have to "stop our day of appointed patients...because they need it now"...and there probably be a charge for multiple copies.
I agree that spectacle Rxs should not have expiration dates. They should simply have an exam date, and perhaps a note on the back that advises yearly or semi-annual exams...but whether to fill it or not is between the dispenser and the consumer. On CLs, however, I feel differently.
The PD?? That's between the fitter and the patient...unless there is some extenuating circumstance which the prescriber wants to point out.
I still think being forced to hand over an Rx to someone that doesn't want it at the moment is ridiculous.
Oh well, we do what we gotta do...
While I agree with virtually all you said, I have a feeling that the FTC won't even consider online eyeglass sales in this discussion.
If there is going to be any rulings on online (impersonal) sales, it is likely to come in another form...but I commend you for trying.
Thanks. I'm pretty sure that the following is in response to DIYers bypassing opticians and buying medical devices (eyeglasses) online, directly from mostly Chinese fabricators.
https://www.ftc.gov/system/files/doc...assrulefrn.pdfB. Specific Issues
1. Should the definition of‘‘prescription’’ be modified to include pupillary distance? Why or why not?
(a) What evidence supports such a modification?
(b) How would this modification affect the costs the Rule imposes on businesses, including small businesses?
(c) How would this modification affect the benefits to consumers?
Science is a way of trying not to fool yourself. - Richard P. Feynman
Experience is the hardest teacher. She gives the test before the lesson.
Abso-freaking-lutely.
1. You NEVER NEED a p.d. release because you're an optician.
2. I NEVER NEED to release a p.d. because my Rxs are going to be filled by an optician.
3. The only people that need p.d.s are DIY opticians/optometrists. Get you own damned p.d., Mr. Smarty.
4. The whole p.d. issue is a farce. We release everything needed to have another professional do their job, but now this "p.d." thing becomes some new tinfoil hat conspiracy theory as to ODs "denying consumers". Again. As always.
5. I'm not the bad guy. No OD is.
Spot on, sir.
Robert, I doff my cap to you for making it plain that the issue is "D-I-Y"ers.
For the life of me, I can't get it through the thick skulls of some of my colleagues that this is a situation of "D-I-Y".
Hey, God Bless America. Do unregulated internet junk until you're happier than a pig in shiite. But please, leave me out of it.
Based on all the inputs on this thread, I just removed the P.D. fields from the patient copy report of my software.
No more Dr. Nice Guy.
Yea! Good show old chap.
Personally, I have no issue with fragmented care. As an LDO who works at a clinic I have an issue with mine or any Dr whose responsibility increases for work done outside of their clinic. If John and Joan Q Public want to take their Rx's and go elsewhere, that is their prerogative. I just don't need to increase my work load with any more problem solving of other peoples work. Releasing an Rx with an IPD and telling the patient that this is all you need, is wrong. We all know that properly made Rx lenses require a lot more. DIY/on line glasses, should not require co-management from the prescribing Dr. Whats next, fitting heights, POW measurements, fitting instructions for frames. Removing the responsibility from the DIY seller is not going to make things easier for the public.
,
I didn't attend the funeral, but I sent a nice letter saying I approved of it. Mark Twain
Yes, agree that optimally (a word I prefer to properly) made glasses requires more than a PD.
But, the Rx and a PD really is sufficient for adequately made glasses, particularly if the buyer is willing to entertain trade offs and set their expectations accordingly. Further, some brands and types of eyewear are simply not available through B&M offices. And I think the public should have the opportunity to avail themselves of these choices.
They don't call it a free market for nothing.
B
BTW,I made my comment on the FTC website regarding spectacles. Ido have opinions on CLs, but since I am not a Player in that market, I'll leave it to others.
i think my comment was assigned #11.
B
It's not a free market, Barry. Is there a free market for Celexa? (No, but there's a black market.)
We are supposed to have licensed professionals serving the public's health care needs. And professionals have "professional standards" that greatly exceed "sub-optimal" or "barely passing".
I suppose "mostly adequate" heart surgery is a great thing, too.
Oh sure, we aren't heart surgeons. We're only doing something 27.6% as important, so we should have about 27.6% as high professional standards as heart surgeons. That seems about right. Hey, we can't all be good at our jobs, right?
I'm sure that you could go to your family doctor, right now, and ask for a "fair enough" prostate exam. "Fifty-one percent likelilhood of giving a good answer is fine with me, doc. Beats a coin flip!"
"Hey, this online blood pressure med is mostly adequate in many situations!"
Surely we don't have to hold family MDs to the same ridiculous standards as we would cardiologists. I'd say only 71% as high. They have 29% suck leeway.
What's worse is that the p.d. thing really isn't the issue. The issue is people doing it themselves. Is that "adequate"?
I mean, if YOU had an Rx and a p.d. in your hands as an optician making glasses, maybe it could be "adequate enough". But for James Public UberDriver? Is HE going to do an adequate job pimpin' himself out some specs?
"Nah, I can see MOST of the road signs. I got 20% off, so I'm 20% blurry. I'm good with that."
"Hey, I only get double vision when I open both eyes...no problems. I did save about half off."
"Sorry teacher, I don't like math class, anyway, so I don't need to see what you're writing down, there."
"Well, it's either these $29 glasses, or my macular degeneration acting up. Who knows? Is that Bob Barker or Pat Sajak?!"
Always room at the bottom. Crappy work, crappy standards, but hey...you got a deal.
Last edited by drk; 09-08-2015 at 08:24 PM.
I can't tell you the number of people (hyperopes) I see per day, that come in for professional care, see a lousy 20/50 uncorrected at distance, and say, "I see good enough. I don't need to see signs all the time. " so I Muse to myself, "if you don't want to take my advice, why are you here in the first place?"
People are willing to accept mediocre. Licensing is not about mediocre.
And to spin off from what fjpod said.
My line of thinking.........So you just handed me $800. and a new Rx for a new pair of glasses. You put them on and start exclaiming that things "look different". I am thinking, well ya. What did you expect?
If you wanted to see the same out of the new pair the same way you see out of your old pair why did you hand me a new Rx and money for a new pair of glasses. SMH!
If that trade off is acceptable to that person for that pair, who are you (we) to argue?
Now, 20/50 uncorrected means: You need corrective lenses on your driver's license.
B
Never fails, start talking about PD's and there is blood on the floor and walls. Who is going to clean up this mess?
+1!!
The FTC
Again, the blood red on the p.d. issue is because the issue is a big, fat, greek red herring.
In reality this does not turn on silly p.d.s.
It has to do with regulation of health care...OR NOT.
Put me in the camp that says:
1. spectacle and contact lens dispensing is vision care
2. vision care is health care
3. health care needs regulation.
Put Barry in the camp that says:
1. spectacle dispensing is retail
2. retail needs significantly less regulation.
He's right, from his (wrong) perspective.
Yeah, vision is definitely both health care and retail in the US and around the world. It's this very curious melding of platforms that give vision its charm. I love both areas and live both.
What says a lot to me about this is that it is being brought up by the Federal Trade Commission. Not the NIH or any medically related government agency.
To my eye (pardon the pun) the fix is in by heavyweights who outweigh anything the OD's lobbying arm can bring to the fight.
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