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.