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.