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.