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.