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.