This regulatory change is unnecessary and duplicative in that a patient's Pupillary Distance ("PD"), if measured, is automatically a part of their medical record. As such a patient has a right under the Code of Virginia and Board Regulations to their own medical record, including their PD. Furthermore current practice allows other licensed individuals other than an Optometrist to measure a patient's PD. The proposed regulation would require an Optometrist to measure the patients PD rather than authorizing them to delegate this duty to a licensed Optician or entity. Thus the practice of requiring an Optometrist to measure a patient's PD rather than allowing other licensed individuals, such as an Optician or an Ophthalmologists, would be discriminatory in nature.

I am opposed to the proposal to require the release of the pupillary distance measurement as part of an  eyeglass prescription.  Although this is thought to be part of an eyeglass prescription, which is obtained as part of a comprehensive eye examination, it is in fact not the case.  This measurement is obtained by the optician while measuring the patient for the proper fitment of eyeglasses.  It has never been a part of the clinical aspect of an eye examination.  It is not required for any other reason but to fit eyeglasses, which is a separate service and requires time and attention to provide accuracy.  We never collect this data in the exam room or during ancillary testing.  If the patient is seen in a venue that does not provide eyeglass services, does not employ an optician, etc such as a hospital based environment, many ophthalmologist's offices and many specialty optometric practices, these providers will immediately be in non-compliance with the rule.  The need to obtain this measurement on every patient will cost time and therefore legitimately add to the cost of an examination.  It should remain where it belongs: in the purview of the optical for the specific purpose of selling eyeglasses.  There is no need to add to the economic burden of the general population seeking eyecare for the benefit of a select and small group of people who choose to purchase their eyewear online.

Measuring the pupillary distance has never been a requirement during an ocular examination by an optometrist or ophthalmologist but rather the optician responsible for measuring and fitting the eye wear itself. This is not a medical procedure and is not related to the patient's health. This mandatory regulatory change would add an undue burden on these professionals.  Additionally, there are many pupillary distances that would be required to be measured accurately to ensure proper vision including distance binocular PD, near binocular PD, left eye monocular PD, and right eye monocular PD.  A true measurement of all these requires a skilled optician, a monocular digital pupillometer, and a patient sitting at a desk with their heads perfectly level with the optician.  Lastly, only the fitting optician would understand an actual patient's requirements including frame and lens choices as these are only finalized during an eye wear purchase. Forcing optometrists or ophthalmologists to do this inaccurately in an examination room setting is unfair to these professionals, unfair to the patients, and also unfair to the skilled opticians that offer this service.

In our practice, PD measurement is performed by our opticians using digital devices and provided for a fee to the patient.  This is not a medical procedure but is a critical measurement for proper fitting and manufacture of prescription eyeglasses. There can be several different "PD" measurements depending on what the particular eyeglasses are prescribed for, eg Progressive Multifocals, Computer glasses, Reading glasses, Driving glasses, Shooting glasses, etc..  I am very strongly against this proposed requirement.

Optometrists do not typically measure Pupillary Distances (PD) as part of the ocular health examination.  This is typically performed by an optician who is measuring patients for glasses.  They use equipment specifically designed for this activity, which most optometrists do not use as part of an eye examination.  If one is recorded in the record it typically is included in measurements taken by a computerized pre-testing device. These measurements are approximations and typically not accurate enough by which to prescrib or fit glasses.  The proposed regulation would require an Optometrist to measure the patients PD rather than authorizing them to delegate this duty to a licensed Optician or entity. Thus the practice of requiring an Optometrist to measure a patient's PD rather than allowing other licensed individuals, such as an Optician or an Ophthalmologists, would be discriminatory in nature. Additionally, if the glasses are not purchased from the same establishement who would be required to perform the PD Measurement, there would need to be a charge to the patient for such measurement, as it is not part of the ocular health examination.  Please do note place this discriminatory language into action. 

The pupillary distance is not part of a eye examination to check ocular health and a spectacle prescription.  It is not a medical procedure, and is not a required part of a medical record.  The pupillary distance or "PD" should be measured by the person or persons responsible for making the spectacle prescription, such as opticians, as this is their expertise and is associated with the fitting of the frame and lenses to the patient.  The PD can vary based upon the use of the spectacle prescription, and there for it is far more appropriate for the fitter of the glasses to produce this measurement as a part of that process.  Additionally, this is discriminatory in that it would be a requirement of optometrists, and trained professionals such as licensed opticans or ophthalmologists.  This requirement is unnecessary and would only create undue burden, please do not change the current rule.

The pupillary distance is a measurement that helps the optician manufacture glasses with the lenses centered on the eyes of the patient. As such, this measurement should be obtained by the optician that the patient (consumer) has chosen to manufacture their glasses, not the optometrist that provided the eye examination. As a practical matter the state licensed opticians in our offices have been responsible for these measurements for over 20 years. I oppose this requirement because it would usurp the optician’s role of measuring pupillary distance and incorrectly assign it to the optometrist.

.Optometrists do not typically measure Pupillary Distances (PD) as part of the ocular health examination.  This is typically performed by an optician who is measuring patients for glasses.  They use equipment specifically designed for this activity, which most optometrists do not use as part of an eye examination.  If one is recorded in the record it typically is included in measurements taken by a computerized pre-testing device. These measurements are approximations and typically not accurate enough by which to prescrib or fit glasses.  The proposed regulation would require an Optometrist to measure the patients PD rather than authorizing them to delegate this duty to a licensed Optician or entity. Thus the practice of requiring an Optometrist to measure a patient's PD rather than allowing other licensed individuals, such as an Optician or an Ophthalmologists, would be discriminatory in nature. Additionally, if the glasses are not purchased from the same establishement who would be required to perform the PD Measurement, there would need to be a charge to the patient for such measurement, as it is not part of the ocular health examination.  Please do note place this discriminatory language into action. 

The pupillary distance (PD) is a measurement that should be assessed at the time of frame selection as this is a variable number depending on the frame style, lens type and intended use.  Requiring the optometrist to measure the PD after the patient has picked out a frame and lens type would cause an undo burden to the patient in both incurred fees from the optometrist performing this service and time spent from the patient making an appointment to measure the PD.  Pupillary distance measurements taken during the examination by the optometrist are used for binocular instrument purposes and does not always translate to spectacle frame use.  This proposal is also descriminating against opticians in that they are very capable of taking this measurement.  

The accurate measurement of pupillary distance, optical center, and seg height are all determined during the selection and fitting of eyeglasses, not during an eye examination. A PD measurement has never been a part of the clinical portion of an eye examination.  My colleagues who work in a hospital or medically based setting and do not perform refractions would be in non-compliance with this requirement.  In Virginia, we have licensed opticians who are trained and skilled for the proper fitting, measuring, manufacturing and dispensing of eyeglasses and a PD falls under their scope of training.   Requiring an optometrist to provide a PD while not requiring an optician or ophthalmologist to provide one is discriminatory in nature.  

The PD measurement is not part of an eye exam and should not be required by optometrists.  The proposed regulation would require an Optometrist to measure the patients PD rather than authorizing them to delegate this duty to a licensed Optician or entity. Thus the practice of requiring an Optometrist to measure a patient's PD rather than allowing other licensed individuals, such as an Optician or an Ophthalmologists, would be discriminatory in nature.

Measuring a patient's pupillary distance (PD) is not done during an eye examination. It is not part of an eye glass prescription and not part of an ocular health examination.  This measurement is specifically done when a patient is being fitted for eyeglasses.  Usually, an optician takes this important measurement.  The ability to accurately measure a PD takes skill and the understanding of the frame size and shape and how it relates to the patient's prescription, the patient's needs, and the lens design that will best serve those needs.  To regulate that an optometrist or ophthalmologist is required to take this measurement would be an undue burden to those professionals, discriminatory to opticians, and most of all, it would not be in the best interest of the patient.

I am opposed to this new petition!  Please do not change the current rule.

Pupillary distance (PD) is a measurement only used in the fabrication of glasses. It is not part of the eye health and vision examination performed by the optometrist. Therefore, the responsibility lies with the professional fitting the patient’s glasses frame and lenses. Additionally, requiring optometrists to measure the PD in the exam room using inadequate and outdated methods is not in the best interest of the patient.

It is not the standard of care for the eyecare provider to preform the PD procedure.  The PD is usually tested by the Optician when ordering glasses.  

This regulatory change is totally unnecessary and duplicative.  The patient's Pupillary Distance ("PD"), if measured, is automatically a part of their medical record. As such, a patient has a right under the Code of Virginia and Board Regulations to their own medical record, including their PD.

Furthermore, the current practice is such that other licensed individuals (other than an Optometrist) are allowed to measure a patient's PD. The proposed regulation would require an Optometrist t o measure the patients PD rather than authorizing them to delegate this duty to a licensed Optician or entity - this would be unnecessary and discriminatory in nature.

This requirement is uneccessary and redundant and discriminatory.  Ophthalmologists, optometrists, optometric and ophthalmic technicians, and other staff members can all measure and/or be trained to measure Pupillary distances.  This petition is asking to require optometrists only to measure and provide PDs to all patients and take more of the optometrists time away from more critical patient care.  Also, when a PD is measured it is part of the patient's record and thus the patient has access to it.  It is unclear as to what the purpose of this petition truly is, again is appears to be unnecessary overregulation.

Requiring that an Optometrist provide a pupillary distance measurement as part of the glasses prescription is not appropriate.  Most times, a PD measurement is taken upon selection of glasses by an optician, not necessarily as a part of the eye examination.  The PD measurement can usually be measured accurately by many trained members of an Optometrist's office staff, so to specifically state that an Optometrist is required to take this measurement is not a wise use of resources.

Additionally, my specific practice does not have an optical.  While I am mostly preparing and care for patients that have had eye surgery, on rare occasion I will prescribe glasses.  I do not have digital pupillometers in my office to accurately measure these different parameters.  To require me to provide a PD measurement would either prevent me from writing glasses prescriptions (assuming that I want to take the measurement accurately).

Thank you for allowing comments.

Jen Weigel, OD, FAAO

Virginia Optometric Association