# Optical Forums > General Optics and Eyecare Discussion Forum >  This is serious.

## drk

http://www.visionmonday.com/vmail-he....YXcJHquB.dpuf

*Federal Trade Commission Seeks Comments About Eyeglass and Contact Lens Rule
*
_                          By Staff
            Friday, September 4, 2015 12:24 AM                 _ _

_


_ 				WASHINGTON, D.C.The Federal Trade Commission (FTC) is seeking comments on the efficiency, costs, benefits and impact of the Ophthalmic Practice Rule (Eyeglass Rule) and the Contact Lens Rule,  both of which require prescribing eyecare professionals to provide  prescriptions to patients. The request for comment is part of the FTCs  systematic review of all current FTC rules and regulations, according to  the agency.

Originally issued in 1978, the Eyeglass Rule  requires optometrists and ophthalmologists to provide an eyeglass  prescription to patients, at no extra cost, immediately after an eye  examination is completed. 

In addition to general questions about  whether the Eyeglass Rule should continue and if it should be modified,  other more specific issues related to the Eyeglass Rule for which the  FTC is requesting comment are: What modifications, if any, should be  made to the rule to account for changes in relevant technology or  economic conditions? Should the definition of prescription be modified  to include pupillary distance? Should the rule be extended to require  that prescribers provide a duplicate copy of a prescription to a patient  who does not currently have access to the original? And should the rule  be extended to require that a prescriber provide a copy to or verify a  prescription with third parties authorized by the patient?

The  Contact Lens Rule, effective since August 2004, requires eyecare  prescribers to provide a copy of a consumers prescription to the  consumer after a contact lens fitting is completed and verify with, or  provide prescriptions to, authorized contact lens sellers. It also  mandates that a contact lens seller may sell contact lenses only in  accordance with a prescription the seller has received from the patient  or prescriber, or has verified via direct communication with the  prescriber.

The questions the FTC seeks to answer in regards to  the Contact Lens Rule, in addition to whether it should continue and/or  be modified, include: What modifications, if any, should be made to the  rule to account for changes in relevant technology or economic  conditions? And What significant costs, if any, including costs of  compliance, has the rule imposed on businesses, including small  businesses?

Comments must be received by Oct. 26, 2015, and  instructions for filing comments appear in the Federal Register Notices  linked to above. All comments received will be posted on the FTCs Public Comments page.                     _

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## fjpod

Serious, yes....
I can think of several changes, and about the fragmentation of care this has caused....of course, some will present the other side.  It's hard for the professions to make recommendations without appearing to be self-serving.

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## drk

Hard, yes.  Impossible, no.  Historically, our record reeks.

I'm looking for "organized opticianry's" take on this, on this board.

From opticianry's standpoint, what Rx rules are in the public's best interests?

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## optical24/7

The biggest violation I see (consistently) is not handing a copy of the Rx to the patient after the exam. I will be writing the FTC to suggest an extremely costly fine for failure to do so. Also, Dr's offices need to stop hiding behind Hipaa on the release of said Rx's to 3rd party providers. ( Like making the patient physically come back to their office to sign a "release".)

I know some of you doc's here and out in the world feel fragmentation of care is not in the patients best interest. I will disagree to the extent that many Dr's offices have under qualified personnel they call "opticians" doing the fittings, lens recommendations, measurements and Rx verifications. ( not directed at doc's here, personally). That opticians work under their Dr's license is absurd. I know of no Dr that measures for lenses or verifies Rx's as they come in (unless there's a patient complaint, and even then, most doc's don't do the lens troubleshooting).

 Many outside patients I see are coming to me because of the "optician" at their doctors office. (Even though we don't take their insurance, that shows you how desperate some of these people are for qualified, experienced help with their optical needs.)

Oh yes...I will be putting my 2 cents in....

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## drk

Fragmentation of care is a reality.  Theoretically we'd be better without it, but sometimes there are special skill sets to take advantage of.  Plus there is the issue of economic freedom.

I don't think patients have felt intimidated to ask for a copy of their prescription for glasses or contacts in my career (over the past 25 yrs).  I think it is an unserious expectation to have Rxs given without request or a "large fine".  That's just punitive.  The FTC can let it go to the state boards instead.

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## optical24/7

> Fragmentation of care is a reality.  Theoretically we'd be better without it, but sometimes there are special skill sets to take advantage of.  Plus there is the issue of economic freedom.
> 
> I don't think patients have felt intimidated to ask for a copy of their prescription for glasses or contacts in my career (over the past 25 yrs).  I think it is an unserious expectation to have Rxs given without request or a "large fine".
> 
> ^ This is the reason the law was written to say:
> 
> _Originally issued in 1978, the Eyeglass Rule  requires optometrists and ophthalmologists to provide an eyeglass  prescription to patients, at no extra cost, immediately after an eye  examination is completed._ 
> 
> 
> ...


I never said that patients were intimidated to ask for their Rx. Many times they just don't think to ask for it (which once again, they shouldn't have to ask for it.) Or they assume the doc will simply provide it to another office with a simple phone request. That is exactly what is not happening way too often, at least in this corner of the world...

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## Barry Santini

> Hard, yes.  Impossible, no.  Historically, our record reeks.
> 
> I'm looking for "organized opticianry's" take on this, on this board.
> 
> From opticianry's standpoint, what Rx rules are in the public's best interests?


1. Strict conformance with the Rx release rule
2. Creation of a more wholistic Rx paradigm, with less "treatment discretion" information hidden from outside fulfillment.
3. Include PD on present Rx to allow fulfillment of the spirit of the Rx release rule 

Opticianry and optometry's skill sets are quite different, yet inherently complimentary. It's when one side decides the other has less value that all problems arise from, IMHO.

There's more. Enough for now. These are the main points.

Barry

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## drk

Which interpupillary distance?

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## MikeAurelius

Near and far, in right/left form.

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## DanLiv

Which optician here wants to accept a PD on a prescriber's Rx rather than take their own?

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## Dr. Bill Stacy

ditto for optometrists who sometimes fill outside Rxs.  I often have to correct p.d.s, and of course sometimes the Rx itself is screwy.  It's always awkward, but it does happen.

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## Dustin.B

Personally I'd like to see it made easier to get an Rx on behalf of a patient. I work at an optical center inside an army base and the often ridiculous hoops we get put through to get a patients outside Rx is staggering. The problem is often compounded even further when said Rx is a four hour time hop away.

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## Barry Santini

> Which interpupillary distance?


binocular. The only really valid one.

B

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## Dr. Bill Stacy

Some might argue that monocular pds are the only really valid one.

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## Barry Santini

Monocular objective PDs are an elusive fantasy.

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## Craig

> Monocular objective PDs are an elusive fantasy.


Explain please.

We just had a surgeon non-adapt to a progressive and his eyes did not agree with the monocular results.

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## Barry Santini

All objective PD measuring methodologies have a user/subject/basic assumption problem: it is thought that the corneal reflex represents the visual axis intersection with the corneal plane.

There are studies that have shown a portion of the population appreciably departs from this assumption.

Therefore, when true precision is necessary - and I am not saying it is - only a subjective measurement will do.

This is why surgical telescopes use empirically-derived pupillary/visual axis measurements.

PD matters. But what's interesting is that it matters both less than most think and more than most think.

B

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## Craig

> All objective PD measuring methodologies have a user/subject/basic assumption problem: it is thought that the corneal reflex represents the visual axis intersection with the corneal plane.
> 
> There are studies that have shown a portion of the population appreciably departs from this assumption.
> 
> Therefore, when true precision is necessary - and I am not saying it is - only a subjective measurement will do.
> 
> This is why surgical telescopes use empirically-derived pupillary/visual axis measurements.
> 
> PD matters. But what's interesting is that it matters both less than most think and more than most think.
> ...


Do you have a solution to solve this issues and provide the best usable PD for the % that need it?  We normally refer this type to our OD for a prism evaluation to see if that can help but the surgeon would not see our OD who went to a bifocal.  He did have a axis shift that we felt caused the progressive issue but he saw well out of the trial lenses and was happy in a ft.

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## Barry Santini

Dr. Tom Clark has a patent pending on a modified CRP that allows the patient to take their own subjective PD. we're using one in the office to good results. 

I think he is individually selling them now

B

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## Dr. Bill Stacy

This week I had a patient whose monoc p.d.s measured R 38 L 33.5.  He ordered PALs.  I'm trusting the pupillometer, although I had an assistant re-measure and I re-measured again just to be sure.  

That said, I don't trust the pupillometer at all in cases of amblyopia, squint, inability to follow instructions, etc.  and whenever in doubt I use the mm ruler, and sometimes even dot the lenses.  

And I am interested in the "subjective" system if its not too expensive.

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## Barry Santini

What's most important is that Dr Clark has a companion verification device that quantifies that amount if progressive centration error, if any. 

B

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## rbaker

Hey . . . what ever happened to the original theme of this post, the new FTC Comment Period. You pin heads can argue about PD's someplace else.

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## Barry Santini

Good point, Dick. Binocular PDs should be included on the Rx.

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## drk

> Near and far, in right/left form.


Would you like fries to go with that?

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## drk

> Dr. Tom Clark has a patent pending on a modified CRP that allows the patient to take their own subjective PD. we're using one in the office to good results. 
> 
> I think he is individually selling them now
> 
> B


Barry, there's a fine line between being a wizard and a witch doctor.  Be careful.

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## rbaker

> What's all this got to do with the FTC rules....or is it just a p*****g contest over who is more neurotic in their testing.


The latter of course. Now, all of you, back to work.

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## Dr. Bill Stacy

> What's all this got to do with the FTC rules....or is it just a p*****g contest over who is more neurotic in their testing.


Neurotic is a bit strong, but I get the sentiment and will take my discussions on this subject elsewhere.

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## MikeAurelius

> What's all this got to do with the FTC rules....or is it just a p*****g contest over who is more neurotic in their testing.


Wins the best post in this thread so far award!!

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## Uncle Fester

> What's all this got to do with the FTC rules....or is it just a p*****g contest over who is more neurotic in their testing.


But how are we going to get to 13 pages???

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## MikeAurelius

I've got a recipe for oatmeal raisin cookies...

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## mervinek

> I've got a recipe for oatmeal raisin cookies...


  Yum!  Warm cookies and a glass of milk.

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## fjpod

> Wins the best post in this thread so far award!!


 :Dance:

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## Lelarep

> My guess is "dating the optometrist".


  Nope. I'm an MD.

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## drk

> What's all this got to do with the FTC rules....or is it just a p*****g contest over who is more neurotic in their testing.


Pi$$ing contest.

Who won?

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## Paul Smith LDO

> Pi$$ing contest.
> 
> Who won?


The DIY businesses won.  The consumer will be the one's paying the price.  The FTC can be bought, at the very least we have a government agency that should be self sufficient and won't require further funding.

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## smallworld

> I would say 3 bites at the apple is being more than fair. What would your suggestion be, try yet another location and hope they can get the PD right? I'm happy to listen to any suggestion at this point. I thought I'd ask my OD because I couldn't come up with any better idea.


Do you have Nystagmus? Strabismus?  Tropias or phorias?

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## Tigerclaw

> The DIY businesses won.  The consumer will be the one's paying the price.  The FTC can be bought, at the very least we have a government agency that should be self sufficient and won't require further funding.


It's not a done deal. But yeah, one of the attorneys I consulted said we get to the point where the people in charge of regulating the industry are the same ones profiting off of it, or something to that effect.

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## MikeAurelius

> It's not a done deal. But yeah, one of the attorneys I consulted said we get to the point where the people in charge of regulating the industry are the same ones profiting off of it, or something to that effect.


That sounds like an attorney. Funny, though, I don't know of any OD/MD/Optician on the board of the FTC. Nor any that are on the board of the FDA for that matter. All that appears to be happening is that more power is being put into the hands of consumers, and less in the hands of OD/MD's.

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## MikeAurelius

And one further comment: remember that when you comment about rolling back the freedom to purchase eyewear that the original FTC ruling gave consumers, you would be directly affecting MANY, if not MOST of the opticians who frequent this board. Opticians who depend on those consumers who were given the freedom to buy eyewear anywhere they chose. All of them brick and mortar stores.

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## Tigerclaw

> And one further comment: remember that when you comment about rolling back the freedom to purchase eyewear that the original FTC ruling gave consumers, you would be directly affecting MANY, if not MOST of the opticians who frequent this board. Opticians who depend on those consumers who were given the freedom to buy eyewear anywhere they chose. All of them brick and mortar stores.


Well I guess you should have thought about that before you gave us the finger, guys like me who support and value opticians. It's not like your jobs go away, they just get moved. You want ours (and apparently yours) to go away to a few corporations as though THAT were better for the consumer. This is why I accuse you of being sadistic - you take pleasure from what hurts us, even if it hurts you as well. Don't pretend to champion the consumer - the consumer gets lower quality junk. You don't have to take my word for it - the AOA pres told the FTC as much and backed it up with several studies.

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## Tigerclaw

> That sounds like an attorney. Funny, though, I don't know of any OD/MD/Optician on the board of the FTC. Nor any that are on the board of the FDA for that matter. All that appears to be happening is that more power is being put into the hands of consumers, and less in the hands of OD/MD's*/opticians*.



Fixed.

And I meant "industry" in general, not specifically the eyewear industry.

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## Dr. Bill Stacy

This is a bit long and gets a bit political, so you have been warned to change channels now if that does not interest you. 

I don't know about other states, but having been on the "O.D." regulatory board in California for about 8 years, I can tell you that we didn't exactly "profit" from regulating activities, at least not directly.  One could argue that to the extent we could exert some control over the practice and practitioners, that might benefit us somehow individually.  I just recall that we got a pathetic per diem for attending meetings, as quasi State of Calif employees.  As I recall at that time our board consisted of 5 O.D.s and 4 public members, so "we" were always in control.  Well, until a couple of us maverick O.d.s decided to take the consumers' side on a couple of issues.  All in all, it was a good thing to have the consumers more or less in control for a while.  After we 2 wildcards left the board (term limits, don't you know), the professional association members took back full control.  Democracy at work.   But the only advantage we get as a profession is that certain protections are built into the law and the board enforces them.  I think the present FTC sees that kind of enforcement as the enemy and the consumer as the friend.  They will push hard for relaxation of any restriction of free trade, which I actually support politically.  Crazy liberal that I am I sometimes take positions that are against my own personal interests.

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## Tigerclaw

> This is a bit long and gets a bit political, so you have been warned to change channels now if that does not interest you. 
> 
> I don't know about other states, but having been on the "O.D." regulatory board in California for about 8 years, I can tell you that we didn't exactly "profit" from regulating activities, at least not directly.  One could argue that to the extent we could exert some control over the practice and practitioners, that might benefit us somehow individually.  I just recall that we got a pathetic per diem for attending meetings, as quasi State of Calif employees.  As I recall at that time our board consisted of 5 O.D.s and 4 public members, so "we" were always in control.  Well, until a couple of us maverick O.d.s decided to take the consumers' side on a couple of issues.  All in all, it was a good thing to have the consumers more or less in control for a while.  After we 2 wildcards left the board (term limits, don't you know), the professional association members took back full control.  Democracy at work.   But the only advantage we get as a profession is that certain protections are built into the law and the board enforces them.  I think the present FTC sees that kind of enforcement as the enemy and the consumer as the friend.  They will push hard for relaxation of any restriction of free trade, which I actually support politically.  Crazy liberal that I am I sometimes take positions that are against my own personal interests.


You aren't pro-consumer. You are "pro-consumer" in that you want them to think you're a swell guy. Being truly pro-consumer means you realize that what is good for them is not always saving a few bucks or being trendy or fancying oneself "clever" for figuring out how to order glasses online. It's a bad doctor that seeks to be his patient's friend and not his protector. There is no vast interest in protecting the consumer, otherwise the industry wouldn't have these oligarchs and bad actors dominating the arena and INHIBITING competition. You aren't saving the patient money, neither is the FTC or Congress so long as they enable this bad scenario. If you want to save the patient that money, more than the $5 they save going online instead of to a budget optical, then go after the monopolies. Go after the online retailers that sell junk that must be replaced. My health insurance premiums tripled in the past 3 years, and I'm a consumer 99% of the time. Where were you looking out for me? It's a joke that you guys pretend to be looking out for the little guy and their interests - health, vision, or financial. You may believe you are, but you're not. You're latching onto one thing you hope you can take credit for that in the end is worse for EVERYONE except these (mostly) foreign companies - the same ones your side likes to blame our side for.

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## Dr. Bill Stacy

Wow.  I feel like I'm back on the board and you are one of the association members.  I strongly believed then as I do now that our job was to protect consumers.  That's what I promised when I was sworn in. When I found some professional protectionism going on, I exposed it for the good of the consumers.  In California the Optometry board is in the DEPARTMENT OF CONSUMER AFFAIRS.  So I joined with the consumer members on a few votes, like the one that would have required periodic relicensure examinations.  I thought that would be far more effective than mandatory CE that doesn't even track if the doc was awake during the presentation.  Got shot down, but you get the idea.  The docs felt threatened.  Of course back then (the 80s) there was no internet shopping for anything.  Now you are claiming that if it's bought on line it must be bad for consumers.  I don't exactly get that.  Obviously there can be cheap glasses which may well serve some poor or remotely located people better than no glasses at all.  And being cheap doesn't always mean being healthier.  I've seen some terrible glasses that were also terribly expensive. and I ordered a pair of cheap ones to my Rx just to test the market. There was NOTHING WRONG WITH THEM, and I do know how to test for defects. 

One thing I do know, the internet sales are not all monopolies or foreign businesses.  Lot's of American O.D.s and opticians have internet stores. I don't yet, but I am planning to open one up soon for a niche optical product.  It will not be cheap, but I will price it lower than the same product in my brick and mortar office.  That is normal because the overhead for on line is almost zero.  I personally am buying more and more things on line out of convenience.  But everyone knows that you cannot sell everything on line.  You cannot sell a contact lens fitting on line, only contact lenses themselves.  You cannot sell an eyeglass fitting on line, but you can sell glasses.  People will mostly continue to get their glasses from local sources because it's way more predictable and convenient. On line sale of glasses will continue to increase over time,  but it will not annhilate the professions any more than on line sex will cause the birth rate to drop precipitously.  Indeed, one could argue that on line sex is lessening the incidence of STDs.

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## rbaker

> It's not a done deal. But yeah, one of the attorneys I consulted said we get to the point where the people in charge of regulating the industry are the same ones profiting off of it, or something to that effect.


They do not necessarily profit directly from it but remember:
Dogs bark.
Ducks quack.
Regulators regulate.
Five days a week, eight hours a day, they sit at their desk and regulate, think up new things to regulation and enforce existing regulations. And it's all for our own good and for the good of all the children.

And the sheep continue to happily graze.

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## Tigerclaw

> Wow.  I feel like I'm back on the board and you are one of the association members.  I strongly believed then as I do now that our job was to protect consumers.  That's what I promised when I was sworn in. When I found some professional protectionism going on, I exposed it for the good of the consumers.  In California the Optometry board is in the DEPARTMENT OF CONSUMER AFFAIRS.  So I joined with the consumer members on a few votes, like the one that would have required periodic relicensure examinations.  I thought that would be far more effective than mandatory CE that doesn't even track if the doc was awake during the presentation.  Got shot down, but you get the idea.  The docs felt threatened.  Of course back then (the 80s) there was no internet shopping for anything.  Now you are claiming that if it's bought on line it must be bad for consumers.  I don't exactly get that.  Obviously there can be cheap glasses which may well serve some poor or remotely located people better than no glasses at all.  And being cheap doesn't always mean being healthier.  I've seen some terrible glasses that were also terribly expensive. and I ordered a pair of cheap ones to my Rx just to test the market. There was NOTHING WRONG WITH THEM, and I do know how to test for defects. 
> 
> One thing I do know, the internet sales are not all monopolies or foreign businesses.  Lot's of American O.D.s and opticians have internet stores. I don't yet, but I am planning to open one up soon for a niche optical product.  It will not be cheap, but I will price it lower than the same product in my brick and mortar office.  That is normal because the overhead for on line is almost zero.  I personally am buying more and more things on line out of convenience.  But everyone knows that you cannot sell everything on line.  You cannot sell a contact lens fitting on line, only contact lenses themselves.  You cannot sell an eyeglass fitting on line, but you can sell glasses.  People will mostly continue to get their glasses from local sources because it's way more predictable and convenient. On line sale of glasses will continue to increase over time,  but it will not annhilate the professions any more than on line sex will cause the birth rate to drop precipitously.  Indeed, one could argue that on line sex is lessening the incidence of STDs.


Are you a member of the AOA? You should look at the stats of what is going on, many of them carefully laid out for the FTC by the AOA president this week. I don't mean this as negatively as it sounds, but I get the idea that you don't really know what is going on. You know enough to form an opinion, but you seem to not know who the players are and how they do business. It's not a matter of "all" of them being monopolies or foreign, but in contacts, 1800-CONTACTS has 75% of the market and is the epitome of the "bad actor" (vs. what, 1-2% of OD's being anti-competition?). The other companies like Essilor (French, Coastal.com being Canadian), Luxottica (Italian), Warby-Parker (100% Chinese frames), and Zenni (garbage and 100% Chinese finished product) - all foreign or effectively foreign, enough of it garbage, and all failing to provide the service that we are supposed to be FORCED to pick up their slack on. How is this good for the consumer?

"An AOA study published in 2011 with the Optical Laboratories Association and The Vision Council reinforces the drawbacks of online orders. The study concluded:

Of 200 glasses ordered online, only 154 pairs were received;44.8 percent had incorrect prescriptions or safety issues;29 percent had at least one lens fail to meet required prescription;19 percent of adult lenses failed impact resistance testing; and,25 percent of childrens lenses failed impact resistance testing."

So the argument that SOME online companies are good or that SOME of their glasses aren't potentially harmful is a very weak argument for saying they should ALL be allowed to operate, especially with minimal regulation. Look at Coastal.com's website for example - they only pretend to be interested in ensuring the prescription even exists. Any kid can go to that website, order anything they want, and get it. Whether or not you think that is fine, the FDA's opinion is that eyeglasses (even just frames without lenses) are MEDICAL DEVICES. And this is Essilor doing it, not some dude in China out of the reach of regulation.

It's nice you are on the verge of retiring and you see guys like me as the enemy to be gotten even with over them rejecting your bad ideas while you were on the board, but even if you don't care about the future for those of us with decades left to go, at least care about the patients and doing the right thing.

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## MikeAurelius

> Fixed.
> 
> And I meant "industry" in general, not specifically the eyewear industry.


That's really funny!! Actually trying to change the words I wrote. Sorry bud, doesn't work that way.

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## MikeAurelius

> Well I guess you should have thought about that before you gave us the finger, guys like me who support and value opticians. It's not like your jobs go away, they just get moved. You want ours (and apparently yours) to go away to a few corporations as though THAT were better for the consumer. This is why I accuse you of being sadistic - you take pleasure from what hurts us, even if it hurts you as well. Don't pretend to champion the consumer - the consumer gets lower quality junk. You don't have to take my word for it - the AOA pres told the FTC as much and backed it up with several studies.


It seems like the "you" in your comments are directed at me. I don't take offense though, as I've never given anyone in this industry the finger. Nor am I a sadist. Although perhaps you might want to lighten up your comments a tad, they might be taken by someone else as a personal attack.

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## MikeAurelius

> ...It will not be cheap, but I will price it lower than the same product in my brick and mortar office. That is normal because the overhead for on line is almost zero...


Just one comment...many people believe that on-line stores have no overhead, this is a common fallacy. An on-line store ALWAYS has overhead, in fact, it can be many times the overhead of a true brick and mortar operation. You always need a brick and mortar operation to backup the on-line store. The only thing an on-line store lacks is the one-to-one personal interaction between two people in a physical location. However, there are still four walls, electricity, heat, air conditioning, inventory costs, manufacturing costs, insurance, payroll, etc. etc. etc. It could be argued that an on-line presence is actually more expensive due to the costs of maintaining a website, paying for internet advertising, and of course, access to the internet itself. If you maintain your own internet hardware, of course you have the cost of servers and backup power supplies.

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## MikeAurelius

> The other companies like Essilor (French, Coastal.com being Canadian)...


Essilor may be a French company, however, it's US holdings are held by Essilor USA, not Essilor France. And a great many of the Rx's that are sold over its several consumer website are produced here in the United States in its own labs, those same labs that you may use if you order any Rx for your patients.

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## fjpod

> Just one comment...many people believe that on-line stores have no overhead, this is a common fallacy. An on-line store ALWAYS has overhead, in fact, it can be many times the overhead of a true brick and mortar operation. You always need a brick and mortar operation to backup the on-line store. The only thing an on-line store lacks is the one-to-one personal interaction between two people in a physical location. However, there are still four walls, electricity, heat, air conditioning, inventory costs, manufacturing costs, insurance, payroll, etc. etc. etc. It could be argued that an on-line presence is actually more expensive due to the costs of maintaining a website, paying for internet advertising, and of course, access to the internet itself. If you maintain your own internet hardware, of course you have the cost of servers and backup power supplies.


Mike is correct.

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## Dr. Bill Stacy

Yes, I've been a member of AOA for a long time.  That doesn't mean I can't disagree with some of their positions and techniques.  For example they set up that gotcha test of online glasses, but did they do a parallel or better yet a double blind of glasses ordered from private o.d.s, m.d.s and dispensers?  If they did, where are those numbers?  I may be retiring from face to face optometry soon, but not from optometry itself.  I've got a new online project to work on, and you or the AOA will be welcome to test my products for quality, accuracy, value and safety against that of any other provider or group in the world. 

One final note about "all from China".  A lot of good old American frame lines are going "all from China", including some of VSPs.  Just because something is fabricated in China doesn't make it bad.  Those comments remind me of the good old days when the line was, "if it's Japanese made, it's junk".  It was when they started out, but they rapidly became known for their quality and precision and have been at the top for quite a few years.  Some of the China made frames and lenses already seem pretty darned good to me.

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## optical24/7

> ...For example they set up that gotcha test of online glasses, but did they do a parallel or better yet a double blind of glasses ordered from private o.d.s, m.d.s and dispensers?  If they did, where are those numbers?  ....


Totally agree Doc S. I've done a ton of troubleshooting/verifying Rx for going on 41 years. The net can't be much worse than I've seen from some B&M's. PAL's 45 degrees turned, R's for L's, axis, PD, a PAL put in upside down....Granted, the last 10 years have been worse than the previous 31...

Are there more ways to screw up with an online order? Sure, absolutely. But I've had plenty of experience to see just because someone has a face to face is not a guarantee of quality.

To Dr. Claw; I know you feel like some of us here are anti-Optometry or anti-ECP industry. I can't speak for anyone but me, but I'll tell you I am a realist. You, nor any group, or agency, or association will get rid of internet sales of eyeglasses. It ain't gonna happen! So, just like every other change I've seen in this industry ( Soft CL's, IOL's, Radial K, the advent of 1 hour opticals, cheap chain opticals, Lasik, ect.) all of which by the way were going to "shut us" (little guys) down. I'll learn to deal with it. 

 I'll also tell you this: Internet glasses are not going to put ANY of us out of business. If you go out of business it sure won't be because of internet glasses. I've wrote this so many times here over the years that my fingers hurt, but I'll say it again... Eyewear sales will NEVER surpass, in percentages of sales, CL's over the net which is at best estimates 14-16%. And how long did it take 1-800 or whom ever to get to that 14-16%? A friggin' long time! About 30 years.

 If you're worried about harm to your patients, educate them! One by one. But keep in mind, you do not have control of them, their pocketbook nor where they wish to continue care! You're not going to end competition whether it be B&M or internet or space aliens that bring their own phoropters down to Earth. The internet is here and not going away, deal with it.

----------


## Tigerclaw

> Yes, I've been a member of AOA for a long time.  That doesn't mean I can't disagree with some of their positions and techniques.  For example they set up that gotcha test of online glasses, but did they do a parallel or better yet a double blind of glasses ordered from private o.d.s, m.d.s and dispensers?  If they did, where are those numbers?  I may be retiring from face to face optometry soon, but not from optometry itself.  I've got a new online project to work on, and you or the AOA will be welcome to test my products for quality, accuracy, value and safety against that of any other provider or group in the world. 
> 
> One final note about "all from China".  A lot of good old American frame lines are going "all from China", including some of VSPs.  Just because something is fabricated in China doesn't make it bad.  Those comments remind me of the good old days when the line was, "if it's Japanese made, it's junk".  It was when they started out, but they rapidly became known for their quality and precision and have been at the top for quite a few years.  Some of the China made frames and lenses already seem pretty darned good to me.


Not saying you have to agree. I disagree with them on things. I am just asking because AOA members have access to the letter that Dr. Loomis sent, and you should read it.

You are right - it would be good to do a similar study and include budget chains, middle-chains, and independent OD's, but do yo honestly think the results would be similar? Roughly 25% of the frames ordered online aren't even delivered, which in itself is virtually impossible with a B&M. Add to that the fact that you need a prescription to purchase at a B&M but not online, and that the vast majority of B&M's don't operate under the conditions that their first (and only) step in troubleshooting is "send it back and we'll try again or you get a refund (often reported to be 50% refund only, if anything)".

Also the Chinese products (and mindsets) and the Japanese are not the same, especially when it comes to quality. They are as different as night and day in many cases. We don't entrust our care to the slim possibility that the Chinese products will follow the same path that the Japanese ones did. If they do, then in 20 years we can discuss what IS and not what could possibly be. That's not to say that China produces NO quality products. Not all of their drywall was toxic and corrosive. Not all of their pet food  was fatal. Not all of their fast food beef was spoiled. The issue regarding safety is that we have no way of distinguishing one from the other, or controlling which retailers or factories are being used. And if you want to talk finance and economics, what message does it send out if we say that it's better to save a few bucks here and lose more manufacturing jobs? Not getting into all that since that's another issue and not one I feel particularly strong about, but your side of the aisle seems to want it both ways - save the patient money by sending them to the evil corporations who consolidate power and inhibit competition and send all our jobs overseas... This needs to at least needs to be thought out and have its inconsistencies resolved.

----------


## Tigerclaw

> If you're worried about harm to your patients, educate them! One by one. But keep in mind, you do not have control of them, their pocketbook nor where they wish to continue care! You're not going to end competition whether it be B&M or internet or space aliens that bring their own phoropters down to Earth. The internet is here and not going away, deal with it.


Sorry if I don't bow down to the almighty internet. There are lots of things you can't buy or sell on the internet. There is only so much "education" that some people can take, and the problem is that the people most resistant to it are typically the ones who need it the most. 
I am not worried about losing business to online or even budget opticals any more than Ruth's Chris worries about losing people to McDonald's. The issue isn't my financial losses or inability to compete, but rather the proposed PD mandate and the DIY healthcare mentality it facilitates, as well as the bad actors that take advantage of the gullible budget shoppers. We should ALL be concerned when any entity consolidates too much power, especially in foreign interests. My philosophy is that I believe in a government big enough to keep me from being bullied without becoming a bully itself. Telling doctors they must do extra work because some business needs that product of our work to successfully compete against us is absurd.

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## Golfnorth

[QUOTE=optical24/7;516020] I'll also tell you this: Internet glasses are not going to put ANY of us out of business. If you go out of business it sure won't be because of internet glasses. I've wrote this so many times here over the years that my fingers hurt, but I'll say it again... Eyewear sales will NEVER surpass, in percentages of sales, CL's over the net which is at best estimates 14-16%. And how long did it take 1-800 or whom ever to get to that 14-16%? A friggin' long time! About 30 years.

 Chris Ryser........please read the above and repeat.

----------


## Tigerclaw

> Mike is correct.


Partially correct. There is overhead, but it will never approach the sum totals of B&M's who would do a comparable number of orders.

If you compare an online company doing 1000 orders/month vs 10 B&M's doing 100 orders/month each, the online company could be a guy and his wife working out of their home, but let's assume in the interest of fairness that they must rent space and hire employees. Storage requirements aren't that high - it's not a showroom. Can store over 100 frames in 1 cubic ft of space, so 3000 can fit on a shelf 6 feet long stacked 5 feet high. How many man hours does it take to process 1000? I may be way off, but I would guess about 10 minutes/pr running 2 machines, so 166 man hours or less than 1 month at 40 hours/week, so you need one person theoretically, and he could probably do the paperwork while waiting. In China this would cost you about $500 in labor per month. What do you get for $500 in an American B&M? A week for one optician at about $10/hr once you figure in payroll taxes, etc. Hardly enough to cover 10 B&M's for a month.
If you want to compare A/C, equipment costs, etc., don't bother. They are all ridiculously cheaper in China.

----------


## optical24/7

> Sorry if I don't bow down to the almighty internet.  .


_“If you're a sailor, best not know how to swim. Swimming only prolongs the inevitable—if the sea wants you and your time has come.”   
_James Clavell

_“Healey’s First Law Of Holes: When in one, stop digging.”  _ 
Denis Healy

----------


## Tigerclaw

> _“If you're a sailor, best not know how to swim. Swimming only prolongs the inevitable—if the sea wants you and your time has come.”   
> _James Clavell
> 
> _“Healey’s First Law Of Holes: When in one, stop digging.”  _ 
> Denis Healy


So your implication is that we can also get, say, cocaine on the internet? It IS the internet, after all, and internet = future and future = unstoppable, so internet = unstoppable? Stop romanticizing the internet. There is PUH-LENTY of stuff that you cannot obtain from the internet.

----------


## optical24/7

_"The only constant is change".
_Heraclitus

My point is that our industry has gone through changes many times. We learn to adapt to those changes, or we don't. You can talk about the philosophy of why people shouldn't be able to get net glasses. Believe it or not, I agree! But, it's an argument of futility. If the gov'ment makes you take a PD, charge for it. Educate your patients that "need it the most", go home and sleep well knowing that you've done what you could to help each and every one of them avoid seeking mis-care. This PD issue is really almost a non-issue since it won't be long before there's an app that measures better than any of us can. Providing it or not will not stop folks from purchasing net glasses. Heck, I wish I could get a gov'ment mandate that said I had to provide a PD. What an easy peasy way to give myself a raise (as in higher fees charged!)

Since I'm enjoying quoting people today, I'll leave you with one of the most wise quotes ever made....

_"You've got to know when to hold em,
Know when to fold 'em.
Know when to walk away,
And know when to run."

_Kenny Rogers

----------


## Tigerclaw

My impression is that we will not be allowed to charge fees, at least under insurance, but I have been toying with the idea of adding a "$25 Warby Parker fee" in writing at the bottom, also considering a "Chuck Schumer" or "FTC Compliance" fee instead.

----------


## fjpod

> Partially correct. There is overhead, but it will never approach the sum totals of B&M's who would do a comparable number of orders.
> 
> If you compare an online company doing 1000 orders/month vs 10 B&M's doing 100 orders/month each, the online company could be a guy and his wife working out of their home, but let's assume in the interest of fairness that they must rent space and hire employees. Storage requirements aren't that high - it's not a showroom. Can store over 100 frames in 1 cubic ft of space, so 3000 can fit on a shelf 6 feet long stacked 5 feet high. How many man hours does it take to process 1000? I may be way off, but I would guess about 10 minutes/pr running 2 machines, so 166 man hours or less than 1 month at 40 hours/week, so you need one person theoretically, and he could probably do the paperwork while waiting. In China this would cost you about $500 in labor per month. What do you get for $500 in an American B&M? A week for one optician at about $10/hr once you figure in payroll taxes, etc. Hardly enough to cover 10 B&M's for a month.
> If you want to compare A/C, equipment costs, etc., don't bother. They are all ridiculously cheaper in China.


OK, I'll settle for mostly correct.

----------


## Uilleann

In order to purchase glasses and/or contact lenses, one is required to first see an eye doctor in the US.

This is a given.

There is ALWAYS a fee for this.

Why?

Often it is the doctor's time, and the cost of keeping a b&m business open from day to day cited as top costs required to recoup.

Why would PD's be any different?  (At least till they are generated my computer cameras and algorithms instead)

----------


## ml43

> OK, I'll settle for mostly correct.


I'd like to note that Japan/US/Europe's biggest market for manufacturing equipment is China. 

I don't believe they pay any less than we do for equipment, as they still have to pay for the install tech/engineer to do the initial install and calibration.  

The biggest difference IMO is QA, warranty, and delivery time.

----------


## MikeAurelius

> Partially correct. There is overhead, but it will never approach the sum totals of B&M's who would do a comparable number of orders.
> 
> If you compare an online company doing 1000 orders/month vs 10 B&M's doing 100 orders/month each, the online company could be a guy and his wife working out of their home, but let's assume in the interest of fairness that they must rent space and hire employees. Storage requirements aren't that high - it's not a showroom. Can store over 100 frames in 1 cubic ft of space, so 3000 can fit on a shelf 6 feet long stacked 5 feet high. How many man hours does it take to process 1000? I may be way off, but I would guess about 10 minutes/pr running 2 machines, so 166 man hours or less than 1 month at 40 hours/week, so you need one person theoretically, and he could probably do the paperwork while waiting. In China this would cost you about $500 in labor per month. What do you get for $500 in an American B&M? A week for one optician at about $10/hr once you figure in payroll taxes, etc. Hardly enough to cover 10 B&M's for a month.
> If you want to compare A/C, equipment costs, etc., don't bother. They are all ridiculously cheaper in China.


Who says they are in China? Why make that assumption at all?

Your numbers are "close" for surfacing (grinding/polishing) but leave out time required for order entry, layout/blocking, generating, surface inspection, edging layout/blocking, edging, coating, assembly, and final inspection.

You've also left out the financing cost of over $250K in machinery.

----------


## MikeAurelius

> So your implication is that we can also get, say, cocaine on the internet? It IS the internet, after all, and internet = future and future = unstoppable, so internet = unstoppable? Stop romanticizing the internet. There is PUH-LENTY of stuff that you cannot obtain from the internet.


Actually, you can, if you know how to navigate the dark 'net.

----------


## Chris Ryser

[QUOTE=Golfnorth;516023]


> *I'll also tell you this: Internet glasses are not going to put ANY of us out of business. If you go out of business it sure won't be because of internet glasses. I've wrote this so many times here over the years that my fingers hurt, but I'll say it again... Eyewear sales will NEVER surpass, in percentages of sales, CL's over the net which is at best estimates 14-16%. And how long did it take 1-800 or whom ever to get to that 14-16%? A friggin' long time! About 30 years.
> **Chris Ryser........please read the above and repeat.*



At 23 to 24 Millions pair of glasses sold on the web this year, and a forecast of 27 Millions or next year would be another increase of about 10%. It seems to increase  faster from one year to the next.

I was laughed at right here on OptiBoard when I warned about all this coming already 10 years ago.

Optical websites have sprung up by the double over the last 6 years, since I have kept track of them on my website.




> * Eyewear sales will NEVER surpass, in percentages of sales*


I never said they would, but we will find out in another little while, as the increase is racing on.

I am working hard to increase my own business into other industrial fields with some modest success, having one of my products is now being used in about 80% of all automotive brands worldwide and also by one of the world's largest aerospace and weapons manufacturers among others. 

It can never hurt to look for a solution to sell your products in another way than we used to be. Optical retailers could sell their products at a similar pricing than the ones on the web do, plus "service a la carte".

----------


## Dr. Bill Stacy

Yes, I believe that in 10 or 20 years the only independent B&M opticians and optometrists who survive will be those who have long established service based fee structures, anyone who does anything for free will be gone with the wind and into employment positions elsewhere or in the same field.  It has worked for me in contacts.  I always have had fitting and refitting fees, and for the last 2 years have matched my material charges to 800 contact prices.  Saves me a lot of time when I hand them their Rx and tell them, BTW our lens pricing is the same as 800 contacts, and we will have them for you to pick up in 2 week days max.  Those who prefer shipping to their door can stick with 800 contacts.  I still have my service fees.  I'm gradually instituting service fees for all the internet spectacle stuff, for the same exact reason.  After all, I want my successor to succeed too.  

Another BTW, I'm old enough to remember the Japanese entry into our frame market.  It was pathetic.  But it didn't take them more than about 10 years to go from the basement to the top floor and drive almost all the American frame makers out of business.  China may clean up their act faster than Japan did.  They are right now doubling their baby production.

----------


## Tigerclaw

> In order to purchase glasses and/or contact lenses, one is required to first see an eye doctor in the US.
> 
> This is a given.
> 
> There is ALWAYS a fee for this.
> 
> Why?
> 
> Often it is the doctor's time, and the cost of keeping a b&m business open from day to day cited as top costs required to recoup.
> ...


The issue is if the PD is considered part of the refraction for the purposes of the unlikely law changes or in the minds of insurance, then we cannot charge for it. For example, EyeMed lists the refraction as "$0".
If it's not, what if the patient refuses to pay for a PD? Can we then withhold it? What if they have no interest at all in obtaining the PD? 
This puts us in the position where we either agree to do them for free or we refuse to see patients who don't have any reason or desire to pay for the PD.

Welcome to government mandates, people.

----------


## Tigerclaw

> Who says they are in China? Why make that assumption at all?
> 
> Your numbers are "close" for surfacing (grinding/polishing) but leave out time required for order entry, layout/blocking, generating, surface inspection, edging layout/blocking, edging, coating, assembly, and final inspection.
> 
> You've also left out the financing cost of over $250K in machinery.


Well many of them ARE in China, so I am not assuming anything. We could also put them in Manhattan at the top of an expensive building, but we are talking what our realistic competition is. Also, why would it be $250k in machinery to run 2 sets of in-house labs?




> Actually, you can, if you know how to navigate the dark 'net.


But you can't do it in such volume (not even close). Yes, there will ALWAYS be a way to get a pair of eyeglasses online. I am not naive. The difference is if they make up 5% of sales or 0.05%.

----------


## Tigerclaw

> I'd like to note that Japan/US/Europe's biggest market for manufacturing equipment is China. 
> 
> I don't believe they pay any less than we do for equipment, as they still have to pay for the install tech/engineer to do the initial install and calibration.  
> 
> The biggest difference IMO is QA, warranty, and delivery time.


It's one thing for high-dollar contracts to outsource for equipment that they themselves will use and need to be top-notch, and you CAN get great stuff from China, but that's not the norm. Sending cheap medical devices to the patient with zero regulation is a different story.

----------


## MikeAurelius

> Also, why would it be $250k in machinery to run 2 sets of in-house labs?


Right now, a moderately priced LOH generator, well maintained, runs about $75K. You could get Gerber/Coburn genny's for about $50K used and well maintained. Edgers, though, damned expensive for a good integrated model with tracer and layout blocker.. You will use up $250K real fast. And if you put in an A/R lab, triple that. Then you have all the disposables, plus pay a licensing fee for the software for free-form progressives, unless you want to run it old-school and use front-only cast progressives.

----------


## MikeAurelius

> ...and you CAN get great stuff from China, but that's not the norm


You would be surprised. The Chinese have pretty much demolished the precision optics market in the US and Europe in the last 10 years. If they can make high quality precision optics, they can also make high quality ophthalmic eyewear. Especially when they have no in-country restrictions on copyright/patent infringement. They will get a machine from out of country, tear it apart, analyzed it, and have an exact copy at 1/4 the price ready in 6 months for use in China only.

Look at their automobiles. They take European and US cars, and make them there for sale in China for about half the price elsewhere in the world, and they are daggone good cars.

----------


## ml43

> You would be surprised. The Chinese have pretty much demolished the precision optics market in the US and Europe in the last 10 years. If they can make high quality precision optics, they can also make high quality ophthalmic eyewear. Especially when they have no in-country restrictions on copyright/patent infringement. They will get a machine from out of country, tear it apart, analyzed it, and have an exact copy at 1/4 the price ready in 6 months for use in China only.
> 
> Look at their automobiles. They take European and US cars, and make them there for sale in China for about half the price elsewhere in the world, and they are daggone good cars.


source?

I am unaware of any Chinese precision optics manufactures that have really caused a huge impact on the precision optical industry.  

All the top precision optical manufactures are still US based/owned companies.

If we are talking about premade components that are around 1/2 wave  in accuracy, then maybe, but lower than that, the US is still the place to have it made.

----------


## Tigerclaw

> The issue is if the PD is considered part of the refraction for the purposes of the unlikely law changes or in the minds of insurance, then we cannot charge for it. For example, EyeMed lists the refraction as "$0".
> If it's not, what if the patient refuses to pay for a PD? Can we then withhold it? What if they have no interest at all in obtaining the PD? 
> This puts us in the position where we either agree to do them for free or we refuse to see patients who don't have any reason or desire to pay for the PD.
> 
> Welcome to government mandates, people.


I would like to add, does anyone envision how, under the reasoning I provided above, that we can viably charge for PD? If we charge for PD, then every person being refracted MUST pay for the PD (which personally I don't see happening), but if it can be paid for, then it MUST be paid for, therefore increasing the cost of health care and offsetting any of this illusory "advantage" to having the PD provided by mandate. My current rate is $50 for the PD (done as a deterrent, not as a revenue generator). I would probably drop it to $25 in the unlikely scenario that we are not prohibited to charge for it.

----------


## Barry Santini

> source?
> 
> I am unaware of any Chinese precision optics manufactures that have really caused a huge impact on the precision optical industry.  
> 
> All the top precision optical manufactures are still US based/owned companies.
> 
> If we are talking about premade components that are around 1/2 wave  in accuracy, then maybe, but lower than that, the US is still the place to have it made.


i know a number of Chinese precision optics manufacturers that are making top tier, diffraction limited, Surface smooth telescopic optics.
B

----------


## rbaker

> My current rate is $50 for the PD (done as a deterrent, not as a revenue generator). I would probably drop it to $25 in the unlikely scenario that we are not prohibited to charge for it.


Out of curiosity, who prohibits you from charging for an optometric service?

----------


## Tigerclaw

> Out of curiosity, who prohibits you from charging for an optometric service?


Ostensibly the same people who prohibit me from making that service optional.

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## Dr. Bill Stacy

It would be helpful for me to understand a $25 P.D. charge if you'd share the following:  

What is your usual and customary charges for a comprehensive exam with refraction?

comprehensive exam without refraction?

refraction alone?

(if "comprehensive exam" doesn't work for you, how about "detailed E & M visit")

----------


## ml43

> i know a number of Chinese precision optics manufacturers that are making top tier, diffraction limited, Surface smooth telescopic optics.
> B


define top tier.

even ophthalmic optical labs can make decent telescopes, just like china can make decent laser pointers and OTC readers.

remember that precision optics exists beyond glass and lenses.

----------


## MikeAurelius

> source?
> 
> I am unaware of any Chinese precision optics manufactures that have really caused a huge impact on the precision optical industry.  
> 
> All the top precision optical manufactures are still US based/owned companies.
> 
> If we are talking about premade components that are around 1/2 wave  in accuracy, then maybe, but lower than that, the US is still the place to have it made.


Ophthalmic optics isn't the only thing my company does. There is a lot of outsourcing going on - direct from China for component optical lenses. I had the opportunity a month ago to see a 1/10th wave flat, master quality, traceable back to standards that came in from China. The price was 25% the cost of a similar flat from a US company.

If you look at the total number of companies in the US manufacturing optical components 15 years ago and compare that to the number today, you will see a significant drop, additionally, many of the companies have downsized, which results in the need for additional imported components.

----------


## MikeAurelius

> My current rate is $50 for the PD (done as a deterrent, not as a revenue generator). I would probably drop it to $25 in the unlikely scenario that we are not prohibited to charge for it.


Interesting...last week, I believe, you wrote: "I don't, I won't, I'll never" provide a PD.

----------


## Barry Santini

If you're gonna charge more than $20 to measure and provide a PD, then I submit you deserve the 'greedy middleman' comment.

B

----------


## MikeAurelius

> How spiteful must some of you be? You want us to provide PD's, why? So patients can go online? The word "stupid" gets tossed around so often that it loses its meaning. Thanks to some of you sour grapes sadists for reminding me of the true meaning of stupid. How does having the PD serve you, other than watching the OD's suffer? Wanna send your business online so you can point and laugh at us from your chair in the unemployment office?
> 
> *I DON'T measure PD, I WILL NOT measure PD, I WILL NOT* provide PD if "required". I may provide "a" PD but you can bet it will be off by a few millimeters. In the alternative, I will charge for it, even if it just means a price increase. I am NOT working harder to allow morons to go online to meet their vision needs based on some idiotic idea that online is safe, better, or even as good.


There it is, post #173 in this thread, recopied here in its unedited form from 10/16/2015. Emphasis mine on the original comment.

----------


## ml43

> Ophthalmic optics isn't the only thing my company does. There is a lot of outsourcing going on - direct from China for component optical lenses. I had the opportunity a month ago to see a 1/10th wave flat, master quality, traceable back to standards that came in from China. The price was 25% the cost of a similar flat from a US company.
> 
> If you look at the total number of companies in the US manufacturing optical components 15 years ago and compare that to the number today, you will see a significant drop, additionally, many of the companies have downsized, which results in the need for additional imported components.



I don't disagree with your assessment, but I believe we are talking about two different areas and markets for precision optics.  

While there may be companies that have closed or downsized.  However there are are still many others that have grown and are still growing.  Just depends what area/market you are talking about.  

Manufacturing as a whole in the US has gone down over the past few decades.  But, that was going to happen, with or without China.  Fact is, there just aren't enough skilled manufacturing technicians in the US.

----------


## Tigerclaw

> Interesting...last week, I believe, you wrote: "I don't, I won't, I'll never" provide a PD.


I would assume the part where I said "done as a deterrent, not as a revenue generator"  is giving you trouble? They have dictionaries online now.

And yeah, people ask for a PD, I tell them "Okay it's $50." That makes it cheaper to get them in a B&M. They get the message.

----------


## Tigerclaw

> If you're gonna charge more than $20 to measure and provide a PD, then I submit you deserve the 'greedy middleman' comment.
> 
> B


I say I'll charge $25 in the unlikely chance we can charge for PD if it is mandated, and you arbitrarily say $20 is good but $25 makes me a "greedy middleman"? What does that make you, when you mark your wholesale purchases up by 100-200% or more, hmm? Be careful with the term "greedy" because anyone who makes profit can be seen as "greedy". I find it greedy that large online retailers aren't happy with the tens of millions of pairs of glasses they already sell and want to get me to provide free labor by force of law to get them even more sales.

----------


## rbaker

> I would assume the part where I said "done as a deterrent, not as a revenue generator"  is giving you trouble? They have dictionaries online now.
> 
> And yeah, people ask for a PD, I tell them "Okay it's $50." That makes it cheaper to get them in a B&M. They get the message.


Ahh . . . after over 330 posts we have finally returned to the original issue of this post, RESTRAINT OF TRADE.

----------


## Tigerclaw

> Ahh . . . after over 330 posts we have finally returned to the original issue of this post, RESTRAINT OF TRADE.


Has nothing to do with restraint of trade since I do not currently sell eyeglasses. My sole purpose was to protect patients from faulty medical devices. Spin it however you want if you need to find a cheap "win", but I can hardly be accused of engaging in anti-competitive behavior when I don't compete.

BTW, I remember you as the *cough* libertarian. Can you please PM me a schedule of what days you support big government and which days you don't, in case I need to time my postings so as not to come into conflict with your beliefs du jour?

----------


## Chris Ryser

> *Yes, I believe that in 10 or 20 years the only independent B&M opticians and optometrists who survive will be those who have long established service based fee structures, anyone who does anything for free will be gone with the wind and into employment positions elsewhere or in the same field. ..............
> **
> ................Another BTW, I'm old enough to remember the Japanese entry into our frame market.  It was pathetic.  But it didn't take them more than about 10 years to go from the basement to the top floor and drive almost all the American frame makers out of business.  China may clean up their act faster than Japan did.  They are right now doubling their baby production.*


Yes China will, but there is another country as India waking up and they already have huge companies in the high tech field that are making high quality products at low cost and I can already see the market shifting, and our monster optical corporations are ready for it. They have learned in North America.

----------


## Barry Santini

> define top tier.
> 
> even ophthalmic optical labs can make decent telescopes, just like china can make decent laser pointers and OTC readers.
> 
> remember that precision optics exists beyond glass and lenses.


I did when I soecified diffraction limited, low point spread and high Strehl ratio

----------


## MikeAurelius

> I would assume the part where I said "done as a deterrent, not as a revenue generator"  is giving you trouble? They have dictionaries online now.


No, just the part where you wrote (quote above) "I don't, I will not". Sounds like an untruth to me. It's absolutely OK to admit you either typed incorrectly or you've changed your mind.

----------


## MikeAurelius

> Has nothing to do with restraint of trade since I do not currently sell eyeglasses. My sole purpose was to protect patients from faulty medical devices. Spin it however you want if you need to find a cheap "win", but I can hardly be accused of engaging in anti-competitive behavior when I don't compete.


Didn't you also write somewhere that you've got a retail store selling eyewear, and your son runs it?

But more to the point, restraint of trade takes many forms, and you don't necessarily have to be a competitor to engage in it. All you have to do is make it difficult or impossible for someone to buy something that is perfectly legal for them to purchase. It's not your place to decide what's faulty, your place is to diagnose a medical condition, write the prescription for all the corrective and fitting measurements and be done with it. The FTC places no burden on you (and never has) regarding so-called "faulty" eyewear. You can't advise them where to buy eyewear, you can't denigrate eyewear sellers (internet or brick and mortar), and you can't put any barriers in their way.

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## Tigerclaw

> No, just the part where you wrote (quote above) "I don't, I will not". Sounds like an untruth to me. It's absolutely OK to admit you either typed incorrectly or you've changed your mind.


That's how I get the message across and DO NOT give out PD's since I WILL NOT get someone to pay me $50 for their PD so they can go online and buy glasses when 4 doors down they can get 2 for $39. It all cheapens our service, cheapens our industry, and many of you cannot see it or don't have the ba...ckbone to fight it.

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## Tigerclaw

> Didn't you also write somewhere that you've got a retail store selling eyewear, and your son runs it?
> 
> But more to the point, restraint of trade takes many forms, and you don't necessarily have to be a competitor to engage in it. All you have to do is make it difficult or impossible for someone to buy something that is perfectly legal for them to purchase. It's not your place to decide what's faulty, your place is to diagnose a medical condition, write the prescription for all the corrective and fitting measurements and be done with it. The FTC places no burden on you (and never has) regarding so-called "faulty" eyewear. You can't advise them where to buy eyewear, you can't denigrate eyewear sellers (internet or brick and mortar), and you can't put any barriers in their way.


Well considering that I neither sell eyewear nor have a son...

"Restraint of trade" speaks to intent. You aren't restraining trade because you block someone's car in, thus preventing them from going to the store. My place is to protect my patients when it comes to what I am allowed to do. And yes I can denigrate eyewear sellers, even if I cannot specifically recommend them, and that is based on state law regarding maintaining separation from corporate interests. If I do denigrate a seller, they'd have to sue me for defamation and good luck with that because I tell the truth, which is an affirmative defense to all slander/libel suits. Maybe you need to stop worrying about telling me where my place is until you know mine and yours. Additionally, I am not putting barriers up by refusing to facilitate them going elsewhere. Do I have to hand them a card with an FTC-approved list of competitors? Well why not??

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## fjpod

I will not handle CL materials for no markup (ala Costco and 1800).  I don't think anyone should, and I wish those that did, would stop.

I charge a moderate CL fitting/refit fee...and guess what?  Patients don't want to pay that either.  

Sometimes you lose them over the cost of goods, sometimes over the service fees....but most of the time, I keep them for both.

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## MikeAurelius

> "Restraint of trade" speaks to intent. You aren't restraining trade because you block someone's car in, thus preventing them from going to the store. My place is to protect my patients when it comes to what I am allowed to do. And yes I can denigrate eyewear sellers, even if I cannot specifically recommend them, and that is based on state law regarding maintaining separation from corporate interests. If I do denigrate a seller, they'd have to sue me for defamation and good luck with that because I tell the truth, which is an affirmative defense to all slander/libel suits. Maybe you need to stop worrying about telling me where my place is until you know mine and yours. Additionally, I am not putting barriers up by refusing to facilitate them going elsewhere. Do I have to hand them a card with an FTC-approved list of competitors? Well why not??


You've stated your intentions quite clearly. You don't give out PD's and when you do, it will be "off". You've clearly stated that you will do almost anything to stop the public from buying eyewear on the internet.

A judge/jury would look at the sum of your statements here, and find you guilty of intent. You made those statements freely and without force. I'm surprised you cannot see that you've already buried yourself up to your neck.

But, at the end of the day, that's your business, and you are certainly free to do as you please. All any of us here can do is say "That really isn't a good idea", and most of us who care enough have done so.

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## Tigerclaw

> You've stated your intentions quite clearly. You don't give out PD's and when you do, it will be "off". You've clearly stated that you will do almost anything to stop the public from buying eyewear on the internet.
> 
> A judge/jury would look at the sum of your statements here, and find you guilty of intent. You made those statements freely and without force. I'm surprised you cannot see that you've already buried yourself up to your neck.
> 
> But, at the end of the day, that's your business, and you are certainly free to do as you please. All any of us here can do is say "That really isn't a good idea", and most of us who care enough have done so.


Oh please. First of all I don't practice under the name "Tigerclaw". Second of all, even if I did there is no proof that I am the same "Tigerclaw". Thirdly, my intent (for the hundredth time) is NOT to inhibit trade, it is to inhibit the trade of medical devices with what I believe to have a high likelihood of being deficient and/or harmful with the INTENT of protecting my patients. You keep repeating yourself instead of addressing the larger points. I wonder why?

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## MikeAurelius

> Oh please. First of all I don't practice under the name "Tigerclaw". Second of all, even if I did there is no proof that I am the same "Tigerclaw". Thirdly, my intent (for the hundredth time) is NOT to inhibit trade, it is to inhibit the trade of medical devices with what I believe to have a high likelihood of being deficient and/or harmful with the INTENT of protecting my patients. You keep repeating yourself instead of addressing the larger points. I wonder why?


Ah. Now you are hiding behind the internet. You do realize that the board admin can be subpoenaed to get your IP address and e-mail account, right? And once they have that...

You just admitted you actually *DO* plan on inhibiting and interfere with free trade. Good, I'm glad we've finally agreed on something.

Let's move on to your comment about "harmful medical devices"...I'm assuming of course you mean spectacles. What harm/injury do you perceive being done by a pair of spectacles that are off power?

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## Tigerclaw

> Ah. Now you are hiding behind the internet. You do realize that the board admin can be subpoenaed to get your IP address and e-mail account, right? And once they have that...
> 
> You just admitted you actually *DO* plan on inhibiting and interfere with free trade. Good, I'm glad we've finally agreed on something.
> 
> Let's move on to your comment about "harmful medical devices"...I'm assuming of course you mean spectacles. What harm/injury do you perceive being done by a pair of spectacles that are off power?


See this is you being out of your depth legally and optically. I am not laying all of my cards on the table, but I do find it odd that you seem to think a PD can provide harm, but a lens power cannot.

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## ml43

> I did when I soecified diffraction limited, low point spread and high Strehl ratio


Without going into too much detail, like Mike, I believe you and I are talking about two different areas of precision optics.


I will also note, the area you two are describing does not make up a significant part of the precision optics currently manufactured in the U.S.


It's kind of like when Chris says the sky is falling cause onliners are increasing sales and internet popularity,

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## ml43

> I will not handle CL materials for no markup (ala Costco and 1800).  I don't think anyone should, and I wish those that did, would stop.
> 
> I charge a moderate CL fitting/refit fee...and guess what?  Patients don't want to pay that either.  
> 
> Sometimes you lose them over the cost of goods, sometimes over the service fees....but most of the time, I keep them for both.


Both those companies actually have a decent markup, they just pay less than you.

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## Tigerclaw

> Both those companies actually have a decent markup, they just pay less than you.


Especially thanks to the UPP.

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## ml43

> Especially thanks to the UPP.


Both of them tried really hard to fight UPP, 
I think over the next few years, we will see a lot of private label contact brands.

Otherwise, like drk says, they will eventually go OTC.

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## Tigerclaw

> Both of them tried really hard to fight UPP, 
> I think over the next few years, we will see a lot of private label contact brands.
> 
> Otherwise, like drk says, they will eventually go OTC.


Was kinda funny, they banned UPP in Utah, appealed it up the chain in federal court during which 1800 used the same argument I make about the CL Rule - that it is not a federal issue and thus the courts have no jurisdiction to overrule Utah state law. They were wrong of course, but would be funny to use their words against them.

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## Dr. Bill Stacy

Most experts would agree that both a wrong p.d. and a wrong power can cause harm.  

Consider an Rx for a child with exophoria whose p.d. is 52 mm and Rx is +6.00 o.u. (not a particularly uncommon Rx)

If someone screws up and makes them -6.00 o.u. or gets the powers right but decenters them for a 66 p.d., harm will be done to that child on either scenario.  Child abuse, really.

Of course p.d.s are not significant when the powers of both lenses along the 180 meridian are close to zero.  
That's the only time they are "insignificant" to me.

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## Tigerclaw

> Most experts would agree that both a wrong p.d. and a wrong power can cause harm.  
> 
> Consider an Rx for a child with exophoria whose p.d. is 52 mm and Rx is +6.00 o.u. (not a particularly uncommon Rx)
> 
> If someone screws up and makes them -6.00 o.u. or gets the powers right but decenters them for a 66 p.d., harm will be done to that child on either scenario.  Child abuse, really.
> 
> Of course p.d.s are not significant when the powers of both lenses along the 180 meridian are close to zero.  
> That's the only time they are "insignificant" to me.


The wrong power can cause emmetropization and adaptation to higher minus lenses than the patient needs. This can lead to virtually any symptom you would get with the wrong PD AND can increase the risk for glaucoma and retinal instability. You over-minus a kid with -1.00 they won't complain 9 times out of 10.

Also, as the AOA notes in its letter to the FTC, the materials often come back the wrong material, 25% of the kids' lenses in their study. So when the airbag deploys or the baseball hits those CR-39's that were supposed to be poly in a kid or monocular patient.... Good luck suing China.

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## Dr. Bill Stacy

I would not be concerned about "emmetropization" in the case I mentioned. If the lenses were as stated, 12 diopters off o.u., the child would probably have an esotropia not to mention severe symptoms.  If the powers were correct but the p.d. were off as stated, causing over 8 prism diopters of base out prism, which for an exophore is bad medicine for sure.  But if you never measure P.D.s or don't care about P.D.s you'd miss that little bit of obvious malpractice.

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## Tigerclaw

> I would not be concerned about "emmetropization" in the case I mentioned. If the lenses were as stated, 12 diopters off o.u., the child would probably have an esotropia not to mention severe symptoms.  If the powers were correct but the p.d. were off as stated, causing over 8 prism diopters of base out prism, which for an exophore is bad medicine for sure.  But if you never measure P.D.s or don't care about P.D.s you'd miss that little bit of obvious malpractice.


Obviously your case wouldn't lead to emmetropization. I was talking about the ones I was talking about.

As for the "malpractice" quip, let's just say some people can draw straight lines, others need an edge to trace. You don't need a PD to measure phorias. Things have changed in optometry since JFK was in office. If I were inducing prism enough to be symptomatic, odds are I would have more remakes than the 1 or 2 I average a year. Hairstyles are different these days. Opticians do the PD's and now apparently even the Japanese are making quality products.

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## Dr. Bill Stacy

Well you quoted my example in your response and made no mention that you were referring to your other cases.  But your responses have made my point well.  Your passing P.D. errors off to the opticians is a great example.  So the poor kid is having his mild xop turn into a much larger one probably wouldn't be noticed by anyone including the child or his parents.  You would have no reason to follow up on this Rx unless there were a complaint from someone  (possibly the reason you have an unusually low "redo" rate), and the child would be needlessly harmed, possibly for a long time.  All for the want of an accurate P.D.

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## Tigerclaw

> Well you quoted my example in your response and made no mention that you were referring to your other cases.  But your responses have made my point well.  Your passing P.D. errors off to the opticians is a great example.  So the poor kid is having his mild xop turn into a much larger one probably wouldn't be noticed by anyone including the child or his parents.  You would have no reason to follow up on this Rx unless there were a complaint from someone  (possibly the reason you have an unusually low "redo" rate), and the child would be needlessly harmed, possibly for a long time.  All for the want of an accurate P.D.


So I provide a PD, then the optician measures their PD, then the lab does their "best" to get the PD matched... yeah, all my fault.

Your scenarios require a lot of assumptions, and my scenarios are extremely common and realistic. For all I know you over-minus 50 patients for every 1 whose mild xp I miss (although technically I am at a count of 0, making you INFINITY times worse).

----------


## drk

> Both of them tried really hard to fight UPP, 
> I think over the next few years, we will see a lot of private label contact brands.
> 
> Otherwise, like drk says, they will eventually go OTC.


Without UPP they were heading OTC because of shoddy onliners.

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## Chris Ryser

wrong section,  post deleted

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## fjpod

> Oh please. First of all I don't practice under the name "Tigerclaw". Second of all, even if I did there is no proof that I am the same "Tigerclaw". Thirdly, my intent (for the hundredth time) is NOT to inhibit trade, it is to inhibit the trade of medical devices with what I believe to have a high likelihood of being deficient and/or harmful with the INTENT of protecting my patients. You keep repeating yourself instead of addressing the larger points. I wonder why?


A little over the top,  no?   Do you have the authority to be the self-anointed protector of the public,  or do you just have a license to practice Optometry,  like me.  Are you on a state board?   Advisor to the Office of the Professions?

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## fjpod

> Both those companies actually have a decent markup, they just pay less than you.


I realize that.  What I object to are those of us in the dispensing professions who try to match their pricing when in reality our costs are higher.  It's suicide.  I (we) deserve a reasonable markup on our materials....,  CLs or glasses. 

I despise the concept of selling  CLs at cost just to get eyeglass sales,  or to collect service fees.  Every profession or business on the planet,  from plumbers to undertakers,  to physicians,  gets a markup on their materials.  Why do cl dispensers feel the need to compete in this manner?

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## Dr. Bill Stacy

I think it's suicide to put much markup on contact lens materials.  I match 800 contact lens prices for materials and that is not exactly pricing at my cost.  What 800 contacts can't do is charge for cl services.  That's the only thing different about us and them. For your future survival you need to shift from markup mentality to services plus a minimal markup on materials.   THAT is how undertakers, dentists, surgeons, and plumbers work.  That is how we all should work.

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## Tigerclaw

> A little over the top,  no?   Do you have the authority to be the self-anointed protector of the public,  or do you just have a license to practice Optometry,  like me.  Are you on a state board?   Advisor to the Office of the Professions?


I think you are reading far too much into my comment, which leads me to believe you, like many here, are reacting emotionally and not logically. If you are an OD and aren't concerned (or worse, not aware) of the risks of online eyewear sales or the cheapening of the entire B&M-based industry, then you probably need to open your eyes, and if necessary, get an eye exam from a qualified optometrist.

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## Chris Ryser

> *For your future survival you need to shift from markup mentality to services plus a minimal markup on materials.**   THAT is how undertakers, dentists, surgeons, and plumbers work.  That is how we all should work.*


Thank you, 

However it must be hard for some to imagine a change from giving free service but charging a large markup when not all people are going to need the free service, or might not need it.

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## Tigerclaw

> Thank you, 
> 
> However it must be hard for some to imagine a change from giving free service but charging a large markup when not all people are going to need the free service, or might not need it.


The only way to do this is to get rid of vision "insurance", which I think will probably happen regardless within 5-10 years. Also you can't go online to circumvent at least half of these people with the help of other bitter undertakers and their assistants cheering you on.

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## drk

Just a public service announcement, FJP sits on the NYS optometry board.

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## Dr. Bill Stacy

> Thank you, 
> 
> However it must be hard for some to imagine a change from giving free service but charging a large markup when not all people are going to need the free service, or might not need it.


Yes, it is a game changer that takes a lot of thought and a firm committment.  I remember the bad old days when I first instituted a contact lens fitting fee.  Unbelievable to me that there are still some O.D.s out there who still work on markup only.  I'm betting they don't fit really tough cases (keratoconus, irregular astigmatism, etc) where the big medical fitting fees are really very nice.  The only thing that separates us from 800 contacts is our knowledge and skill.  Those are needed for every single fitting/refit, IMO.  

The ones that are predicting no insurance in a few years make that prediction on the assumption that none of us can make a living doing contact lens fitting if the contacts are free.  They are wrong again, unless they can figure a way to markup a zero cost item.  It is the very insurance companies that will be happy to provide contacts directly at whatever their cost is.  When that happens, it's service fees or pound sand.

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## Tigerclaw

> The ones that are predicting no insurance in a few years make that prediction on the assumption that none of us can make a living doing contact lens fitting if the contacts are free.  They are wrong again, unless they can figure a way to markup a zero cost item.  It is the very insurance companies that will be happy to provide contacts directly at whatever their cost is.  When that happens, it's service fees or pound sand.


Not all doctors sell materials. Unless you are in a "nominal" rent scenario, how can you stay open trying to increase service fees to make up for lack of profit on materials when you can't raise your service fees? If you are stuck seeing patients for $35-45/pop plus any CL fees that some of them may add that may or may not be capped by their plans, how will you pay the rent and your staff? 
My theory is that there are a few trends: One is that consumers see less and less value in their vision "insurance" as we see them fail to keep up with inflation. Who benefits from this? ONLY the vision plans. Just the other day I had a patient who has a medical insurance plan we've all heard of that mandates a discount even if a patient has no vision "insurance". In this patient's case, she was only entitled to that discount, only entitled to it once per year, and she had to pay extra for it. So basically she paid extra to get less. 
There is also, if not a movement, then a brewing revolution aimed at getting rid of plans like VSP who are basically the pet tigers we took in and raised and now they are stalking us ready to pounce and devour us. Vision plans are not popular with patients and not popular with doctors who don't sell materials, which would effectively be all of us if we can no longer profit from selling materials.
Thirdly, there is the likelihood that as premiums increase for medical insurance and/or people drop out of 0bamacare (seeing as it is really starting to fail), patients and employers will start to budget their insurance dollars and realize that vision insurance is not really insurance, but a discount plan. Alternatively, it could mix in with medical insurance and be absorbed, which is already a trend based on what little admittedly I have seen - "wellness visits", etc.

So yeah, I think there is a very real possibility that vision plans could disappear sooner rather than later.

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## Dr. Bill Stacy

[QUOTE=Tigerclaw;516140]Not all doctors sell materials. Unless you are in a "nominal" rent scenario, how can you stay open trying to increase service fees to make up for lack of profit on materials when you can't raise your service fees? If you are stuck seeing patients for $35-45/pop plus any CL fees that some of them may add that may or may not be capped by their plans, how will you pay the rent and your staff? 

*To see my "nominal rent" scenario, click on www.drstacy.com.  As for capped fees, that's mostly because of non-California lowball providers.  I can't believe it when I hear of docs pricing their fees to "match" insurance schedules.   
*

My theory is that there are a few trends: One is that consumers see less and less value in their vision "insurance" as we see them fail to keep up with inflation. Who benefits from this? ONLY the vision plans. Just the other day I had a patient who has a medical insurance plan we've all heard of that mandates a discount even if a patient has no vision "insurance". In this patient's case, she was only entitled to that discount, only entitled to it once per year, and she had to pay extra for it. So basically she paid extra to get less. 
There is also, if not a movement, then a brewing revolution aimed at getting rid of plans like VSP who are basically the pet tigers we took in and raised and now they are stalking us ready to pounce and devour us. Vision plans are not popular with patients and not popular with doctors who don't sell materials, which would effectively be all of us if we can no longer profit from selling materials.

*I don't get it.  If you don't provide materials and their associated services, why not?  Are you thinking of doing it?  If not, why not?  Are you working for an hyper-professional O.D. or O.M.D.?  Or has somebody like me got the whole property sewed up and nobody else can come in?*

Thirdly, there is the likelihood that as premiums increase for medical insurance and/or people drop out of 0bamacare (seeing as it is really starting to fail), patients and employers will start to budget their insurance dollars and realize that vision insurance is not really insurance, but a discount plan. Alternatively, it could mix in with medical insurance and be absorbed, which is already a trend based on what little admittedly I have seen - "wellness visits", etc.

*The 3 vision plans I take mostly have funded benefits, meaning the insurance companies actually pay me for what I do, in addition to the non-covered or discounted items for which the patient must pay if they want them.  These patients usually love their plans because they can often get $1000 of goods and services from me for less than half of that, for example, sometimes for a zero or $10 copay. 
*
So yeah, I think there is a very real possibility that vision plans could disappear sooner rather than later.[/QUOTE ] 

*Possible but not probable.  I just got an offering to join Mr. Kim's new plan.  He's the guy who started AVP years ago and sold it to Luxottica a few years ago who renamed it EyeMed.  His new plan is offering much better reimbursements for exams, etc.  than Eyemed.  My present thoughts are to dump EyeMed and join Mr. Kim's plan. * *Just remember, all insurance companies will reimburse you the LESSER of their scheduled amount OR YOUR Usual and Customary, and if YOUR UCR is zero, that's EXACTLY what you will get.  And trust me, they will shop your fees using stealth techniques, and if they find you are quoting free to anyone, they will retroactively reimburse themselves for your overcharging them, from your checkbook.  At about Christmas time...*

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## Dr. Bill Stacy

> Thank you, 
> 
> However it must be hard for some to imagine a change from giving free service but charging a large markup when not all people are going to need the free service, or might not need it.


Well, if they need the materials, they must have the service. One of my favorite quotes is "that was then, this is now".  And for the completely gutless, "the insurance companies made me do it".

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## fjpod

> I think you are reading far too much into my comment, which leads me to believe you, like many here, are reacting emotionally and not logically. If you are an OD and aren't concerned (or worse, not aware) of the risks of online eyewear sales or the cheapening of the entire B&M-based industry, then you probably need to open your eyes, and if necessary, get an eye exam from a qualified optometrist.


You like baiting people,  huh?  I will not call your character into the discussion. 

How many bodies are in the street from Internet glasses?  How about from drinking sugared beverages?

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## Tigerclaw

I am next to an optical, so my rent is nominal. I DO plan to open and sell, but as I was saying, patients are happy with your goods and services until your "goods and services" becomes just "services".  Not saying they'll be Unhappy, but they just won't see the benefit of vision plans. That's largely because vision plans are a joke unless you are someone who sees your eye doctor annually AND buys materials annually AND couldn't get at least part of that covered under medical insurance. As for vision plans, the only reason we take them anyway is for steerage. My U&C fees are significantly higher, so I don't ever get reimbursed less than what their plans allow, but let's just say you average $80/pt including oop, CL, vcp's, med. If my rent is $4000/mo +$1000 for utilities, EMR, etc. (not my current set-up), I'd have to see more than 63 patients each month just to keep the lights on. Every $12/hr employee costs me roughly $15/h, so let's just say I have 1 working 40h/week. That's another $2600/month or another 33 patients. If I pay myself the same as my employee, that's another 33. That's 126 patients/month just to get by. Sure that may be low relative to the numbers you see if you've been in the business for awhile, but the average number of new patients to a practice is 16, and about half of those will return by24 months, so you are looking at roughly 3 years to reach those numbers IF YOU DON'T SELL. That's assuming you would see that many patients if you have to send them out to another location to buy. Just to retain those numbers you would likely have to hire another employee and since we aren't marking up materials, there foes your salary. Give it to your new employee.

So that leaves us with very few options - the same way corporations are slowly using their pincer attack to force us into following the pharmacy model.

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## Tigerclaw

> You like baiting people,  huh?  I will not call your character into the discussion. 
> 
> How many bodies are in the street from Internet glasses?  How about from drinking sugared beverages?


Well you implied I have some hero complex, which was uncalled for, given my statements, and I spoke more to the emotional reaction than to your character, but w/e.
Is that the measure of quality eyewear? Hyperbolic body counts? Come on. If you are on the board and have been in practice that long, you need to take a long hard look at what you are describing instead of just be annoyed with me. Is your position that eyewear (my words, you said "glasses") is not potentially harmful to patients? I laid out my argument. Your argument was essentially "If it doesn't kill them then it's fine". Is that really where you want to go on the record here? You can do better.

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## fjpod

> Just a public service announcement, FJP sits on the NYS optometry board.


Thanks,  but I am not policing anything or anybody here.   Mainly, because I do not have the authority.  If I did,  I would let everybody know first. 
Just trying to figure out how and why some come to the conclusions that they do.

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## fjpod

For the record,  I would never knowingly give out an incorrect P D.

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## Tigerclaw

> For the record,  I would never knowingly give out an incorrect P D.


The undertakers will not be happy to hear that.

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## fjpod

So,  answer the question.   Which do you think it's a bigger issue to public health officials?   Internet eyeglasses or sugared beverages?

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## Tigerclaw

> So,  answer the question.   Which do you think it's a bigger issue to public health officials?   Internet eyeglasses or sugared beverages?


False choice, and quite obviously a pathetic attempt to downplay the importance of proper eyewear. Do you think they should all go OTC, like sugared soda? You a Bloomberg guy?

----------


## fjpod

Oh,  and every plumber,  undertaker,  dentist,  and physician,  that I know,  at least doubles their cost of goods.   Not saying that we should automatically use double as the benchmark,  but we are certainly allowed a profit margin for ordering,  stocking,  distributing, and the B and M costs that go along with it.  etc.  

Charging professional fees doesn't make you a professional.

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## fjpod

> False choice, and quite obviously a pathetic attempt to downplay the importance of proper eyewear. Do you think they should all go OTC, like sugared soda? You a Bloomberg guy?


Well then,  we will just have to leave it that you think I am pathetic.

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## Dr. Bill Stacy

> I am next to an optical, so my rent is nominal. I DO plan to open and sell, but as I was saying, patients are happy with your goods and services until your "goods and services" becomes just "services".  Not saying they'll be Unhappy, but they just won't see the benefit of vision plans. That's largely because vision plans are a joke unless you are someone who sees your eye doctor annually AND buys materials annually AND couldn't get at least part of that covered under medical insurance. As for vision plans, the only reason we take them anyway is for steerage. My U&C fees are significantly higher, so I don't ever get reimbursed less than what their plans allow, but let's just say you average $80/pt including oop, CL, vcp's, med. If my rent is $4000/mo +$1000 for utilities, EMR, etc. (not my current set-up), I'd have to see more than 63 patients each month just to keep the lights on. Every $12/hr employee costs me roughly $15/h, so let's just say I have 1 working 40h/week. That's another $2600/month or another 33 patients. If I pay myself the same as my employee, that's another 33. That's 126 patients/month just to get by. Sure that may be low relative to the numbers you see if you've been in the business for awhile, but the average number of new patients to a practice is 16, and about half of those will return by24 months, so you are looking at roughly 3 years to reach those numbers IF YOU DON'T SELL. That's assuming you would see that many patients if you have to send them out to another location to buy. Just to retain those numbers you would likely have to hire another employee and since we aren't marking up materials, there foes your salary. Give it to your new employee.
> 
> So that leaves us with very few options - the same way corporations are slowly using their pincer attack to force us into following the pharmacy model.


Well I never said I don't have a markup on materials.  I mark up CLs to whatever 800 is charging for the same lens.  For glasses I have dispensing fees and markups included in my fee structure, and it isn't anywhere near zero. Your math looks plausible and is the reason most O.D.s and now many M.D.s dispense materials.  Just remember if you join any plans they will want to know your pricing structure, and if you put down zero for dispensing glasses or fitting CLs you will get zero on those items.  And they will laugh all the way to the bank.  Good luck in opening up. With your math and accounting skills you should do fine. My average VSP patient visit grossed me $352 last year, not counting things not billed to VSP like uncovered 2nd pairs, uncovered CLs, etc.

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## Tigerclaw

> Charging professional fees doesn't make you a professional.


And sitting on an optometry board doesn't make you a good optometrist. Not sure why you have a bone to pick with me, but I'd say your logic and debating skills don't reflect a good optometrist or a good policy-maker/enforcer. I have been told you are not a bad guy, so I will just assume you have some axe to grind. Instead of attacking me while "not attacking", why not just simply engage in the discussion: Yes or no, is there any risk to vision, health, and/or the wallet when a patient goes online to purchase eyewear?

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## fjpod

> And sitting on an optometry board doesn't make you a good optometrist. Not sure why you have a bone to pick with me, but I'd say your logic and debating skills don't reflect a good optometrist or a good policy-maker/enforcer. I have been told you are not a bad guy, so I will just assume you have some axe to grind. Instead of attacking me while "not attacking", why not just simply engage in the discussion: Yes or no, is there any risk to vision, health, and/or the wallet when a patient goes online to purchase eyewear?


Wait. ... you vow to give out false p ds, and I am a bad optometrist?

You my friend are a bully.   Plain and simple.

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## Tigerclaw

> Well I never said I don't have a markup on materials.  I mark up CLs to whatever 800 is charging for the same lens.  For glasses I have dispensing fees and markups included in my fee structure, and it isn't anywhere near zero. Your math looks plausible and is the reason most O.D.s and now many M.D.s dispense materials.  Just remember if you join any plans they will want to know your pricing structure, and if you put down zero for dispensing glasses or fitting CLs you will get zero on those items.  And they will laugh all the way to the bank.  Good luck in opening up. With your math and accounting skills you should do fine. My average VSP patient visit grossed me $352 last year, not counting things not billed to VSP like uncovered 2nd pairs, uncovered CLs, etc.


I think you and I are on the same page, actually. It just sounds like some people are ready to have us wash our hands of materials in general. My original intent (prior to the UPP) was, upon opening, to undercut them just so my patients would be sure to get authentic products and to just take that tiny fraction of a percentage of money away from those unethical b******s.

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## Tigerclaw

> You my friend are a bully.   Plain and simple.


You started with me. Don't be angry with me for pointing out your glaringly flawed logic. In fact, everything you have said to me has been a personal attack, despite you denying it. I asked you to defend your position. Can you?

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## Dr. Bill Stacy

> I think you and I are on the same page, actually. It just sounds like some people are ready to have us wash our hands of materials in general. My original intent (prior to the UPP) was, upon opening, to undercut them just so my patients would be sure to get authentic products and to just take that tiny fraction of a percentage of money away from those unethical b******s.


I think that is a fallacy.  I actually love the UPP because there is no ambiguity and it kind of levels the playing field.  Of course you can charge more than the UPP, but don't charge less, as that can cost you your account.  And don't assume all internet sellers sell non-authentic products.  I plan on opening up a store on line soon and would hate to have my "customers" think I was a b*.  As to your question to FJP, I'll answer that one.  _Yes or no, is there any risk to vision, health, and/or the wallet when a patient goes online to purchase eyewear?  _ _
_
There is always risk to vision, health and/or wallet when a patient purchases eyewear anywhere.  The risk has not been adequately quantified to draw any hard and fast conclusions to health and vision risks, but to wallet, it's pretty well accepted that the risk to wallet is somewhat higher when purchasing off line.   My patients know I'm higher than the internet for glasses, but they also know that if they come to me for adjusting/fixing an internet purchase, they have to pay for my services, or find a free guy to do it.

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## Barry Santini

> I actually love the UPP because there is no ambiguity and it kind of levels the playing field.


That was the same intent behind the 'fair-trade' laws enacted in the me 1930s. And the early discounters, like EJ Korvettes, and the later warehouse buying clubs like Price Club, Sam's Club and now Costco punched a whole right through the whole concept of structure pricing.

B

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## Tigerclaw

> I think that is a fallacy.  I actually love the UPP because there is no ambiguity and it kind of levels the playing field.  Of course you can charge more than the UPP, but don't charge less, as that can cost you your account.  And don't assume all internet sellers sell non-authentic products.  I plan on opening up a store on line soon and would hate to have my "customers" think I was a b*.


I love the UPP too. I just mean that it changed my original plan to undercut.

People can buy glasses from a B&M for less than many online retailers, so I don't count that as being in favor of online eyewear - at most a wash. Also, it's not about all of the CL sellers selling counterfeit products, but there are some, and there is no monitoring. Otherwise some of the nation's largest *cough* CL sellers wouldn't be "cutting" their authentic products with a healthy dose of counterfeit ones to boost their profit margin. 

It's the same argument I've been making all along: 100% of online sellers don't have to be unethical - turning the keys of what is essentially your intellectual property over to the wide-open market exposes patients to good and bad actors, and there is no regulation. Our beloved Essilor doesn't even care if you EVER had a glasses Rx, if you're 13, if you're monocular, if you're just guessing, etc. That's ESSILOR, not some renegade Chinese black marketeer.

Online CL-ordering patients are 5-10x more likely to develop an eye infection. Now we can agree that correlation does not imply causation, but the same personality types who order online are more likely to abuse the CL wearing schedule, and in either case they need to have annual exams even more than the compliant patients do. Yet 80% (est.) of my verification requests are invalid or non-patients, and ALWAYS when we are closed. Now walgreens.com is aware of our schedule, gives us 48h verification windows, and uses live people. I would trust them, but am prohibited from endorsing them.

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## fjpod

> I think that is a fallacy.  I actually love the UPP because there is no ambiguity and it kind of levels the playing field.  Of course you can charge more than the UPP, but don't charge less, as that can cost you your account.  And don't assume all internet sellers sell non-authentic products.  I plan on opening up a store on line soon and would hate to have my "customers" think I was a b*.  As to your question to FJP, I'll answer that one.  _Yes or no, is there any risk to vision, health, and/or the wallet when a patient goes online to purchase eyewear?  _ _
> _
> There is always risk to vision, health and/or wallet when a patient purchases eyewear anywhere.  The risk has not been adequately quantified to draw any hard and fast conclusions to health and vision risks, but to wallet, it's pretty well accepted that the risk to wallet is somewhat higher when purchasing off line.   My patients know I'm higher than the internet for glasses, but they also know that if they come to me for adjusting/fixing an internet purchase, they have to pay for my services, or find a free guy to do it.


You asked the question nicely.   I'll do my best to answer.   But to all who read,  remember,  I asked the question first,  "what do you think is more important to public health officials?... "

Of course I think there is some public health risk from eyewear prescriptions being filled incorrectly and will continue to do my part to move this cause forward.   I also think it is important to have an eye health exam as part of writing a prescription.  I think the fact that people can get OTC readers is more damaging to public safety than Internet glasses with a valid Rx... At least they had an exam. 

Knowing public health officials the way I do,  I would say THEY think things like sugared beverages,  tobacco,  and heroin are much bigger concerns.  I don't think the way to get their attention is to give them the impression that we will knowingly give wrong information in response to their mandates.  We need to speak their language.  We need to know what is important to them. 

You may turn out to be the proof of the pudding that not all Internet eyeglasses sellers are hucksters.  As Chris and others have said,  "the Internet is not going away."  If government is going to regulate it,  I want to be at the table.   We need to learn to deal with it,  regulate it, shape it, not bury or heads in the sand,  or sabotage it.

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## Tigerclaw

I apologize, I read it as "Which do you think it's a bigger issue to public health?   Internet eyeglasses or sugared beverages?"

The "officials" part changed the tone of the question, so I hope you can see my error and understand why I reacted the way I did.

And the PD thing was, as I said pages ago, venting. Knowing me I would plan on giving out the wrong PD until the pen came to paper. Same little voice in my head that says, "This guy was 15 minutes late and didn't apologize, so I'll tack on a $15 late fee" that never materializes.

The bottom line is that the government needs to decide if it is going to be involved or not be involved, and at the state or federal level. Do I agree with the classifying of frames as medical devices? No. Do I agree with the classifying of CL and finished eyeglasses or lenses as medical devices? Yes. The inconsistency is that that only hurts the independent practitioner. I can't get a frame supplier from Japan to allow me to sell their frames because they don't have an agent and can't justify spending $4k for the fee. Meanwhile a company that does HEAVY business in the US (and is essentially an American company, as someone said) can send finished eyewear to anyone with a credit card. Our largest online CL retailer (with 75% of the market) makes it PATENTLY OBVIOUS that they will do the very minimum in order to get the sale, and have violated the CL Rule we must adhere to for fear of being ruined. I am glad these things are being addressed, but forgive me if I don't like the government telling me that I've got to do extra work at my expense for what will end up being at no additional charge to the patient because those online retailers don't have it easy enough!

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## Dr. Bill Stacy

One last shot at this question before my next patient, I don't buy the horror stories of 5x or 10x more infections, etc.  If anything I've seen the opposite.  There are lots of sellers of CLs who actually encourage wearers to go longer between disposal than the manufacturer recommends.  And at the prices some mark them up, I'm not surprised that the patients tend to follow that advice.  Not so with online, where even bigger discounts are given for "year's supply" purchases.  Another reason to love UPP which encourages the same thing. I know cl verifications are a pain, but I've seen pretty good compliance when I call an Rx wrong or expired.  Finally, mercifully, I only had one marginal corneal ulcer come in today.  My patient, wearing my Rx'd daily disposables, denies using them ever more than 1 day at a time and never any chemicals.  Too much fun on hallowe'en staying up way too late sitting around the fire pit.  Come to think of it, I haven't seen an online buyer lately with any ulcers...  So beware the exaggerated claims.

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## Tigerclaw

> One last shot at this question before my next patient, I don't buy the horror stories of 5x or 10x more infections, etc.  If anything I've seen the opposite.  There are lots of sellers of CLs who actually encourage wearers to go longer between disposal than the manufacturer recommends.  And at the prices some mark them up, I'm not surprised that the patients tend to follow that advice.  Not so with online, where even bigger discounts are given for "year's supply" purchases.  Another reason to love UPP which encourages the same thing. I know cl verifications are a pain, but I've seen pretty good compliance when I call an Rx wrong or expired.  Finally, mercifully, I only had one marginal corneal ulcer come in today.  My patient, wearing my Rx'd daily disposables, denies using them ever more than 1 day at a time and never any chemicals.  Too much fun on hallowe'en staying up way too late sitting around the fire pit.  Come to think of it, I haven't seen an online buyer lately with any ulcers...  So beware the exaggerated claims.


Maybe you are open M-F, so they have no choice but to call you when you are open? Not the case here. I've had kids with central corneal scarring that makes them effectively blind in that eye, seen contact lenses with REALLY odd defects (like fingerprint-looking patterns that were scalloped like the surface of the brain), lenses without coatings, etc.
I've had patients with CLs that came without their coating (same company) and they wouldn't allow the patient to return them. I had to get involved because the manufacturer offered the patient a replacement annual supply and I had to verify her Rx with them.
When 1800-Contacts was affiliated with Walmart and I miraculously managed to cut a bad verification off before they could send it out, they contacted my patient, lying to her that I no longer took her insurance, and set her up with an appointment with Walmart.
Make no mistake - these companies are evil. I have dozens of stories, and have heard dozens more from colleagues. And I don't question one bit that these online CL purchasers have higher rates of infection.

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## Dr. Bill Stacy

Sorry I threw in that little testimonial.  Didn't mean to encourage more of the same.  And I'll listen to first hand ones, one time, like your CL without the coating?  What coating?  How did you know it had no coating?   But the dozens from other practitioners?  No thanks.  Stories change dramatically when they get passed around.  But hey, if  onliners are that bad, somebody would have been sued out of business by now.  I know of a few private O.D.s and M.D.s who have been sued out of business or had their licenses yanked.  I even participated in the yanking a few years ago here in rainy California.

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## Tigerclaw

Air Optix Night & Day has a coating. I am assuming it was determined with Ciba (at the time) that the coating was missing, I was at this point only involved for the verification of the replacement pair. Do you really think dozens of stories can't be heard from most practitioners regarding online verifications? I haven't heard any as the bad ones I've experienced first-hand, but I will say it was funny when I've heard people tell the most audacious stories and I just keep nodding because it as though they were reading my own mental list of horrors from 1800.

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## fjpod

> That was the same intent behind the 'fair-trade' laws enacted in the me 1930s. And the early discounters, like EJ Korvettes, and the later warehouse buying clubs like Price Club, Sam's Club and now Costco punched a whole right through the whole concept of structure pricing.
> 
> B


But remember,  contacts are a loss-leader item for Costco, just like roasted chickens.  I don't like the concept.   Maybe that's the way of the world,  but the public suffers by such trade tactics. .. Unless you really love salty chicken. ... and contacts.  Most of their other stuff is "well priced".

Upp may seem like a good thing for us in the short term,  but it will give us a black eye in the eyes of the public eventually.   Doesn't matter that other products use this tactic. ...

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## Tigerclaw

Hasn't hurt Apple, or it least it seems like a safe assumption. Bose, too, has prospered under such price floor setting.
Also I doubt patients will see us as the ones responsible. There is another word for selling things at a loss to gain a competitive advantage - "price dumping".

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## Chris Ryser

> *You like baiting people,  huh?  I will not call your character into the discussion. 
> 
> **How many bodies are in the street from Internet glasses?**  How about from drinking sugared beverages?
> *


I have not seen any, and the complaint websites about it are slowing down. In the worst scenario, there could have been  23 to 24 millions of them this year alone.

And all of the optical retailers are now pushed to sell the newest inventions by the largest corporation, and others, as blue light protection,  for lots more money, while they barely touch that subject on their websites.

Blue light protection has been around for exactly 32 years and was included in every *UV 400* treatment (yellowish tinge) as it is now in the latest AR coatings to make them more expensive for all. 

Anybody that has a service lab on the premises and is equipped to tint, either the dyepot or a microwave could add it to to a lens, for very little money.

The same idea also applies for sun glasses where most posters on OptiBoard are talking about only selling, polarized lenses while a blue blocker sunglass lens gives a much better protection and much higher contrast vision and also can be tinted on your own premises in a few minutes.

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## Quantrill

I just wanted to bring back the PD discussion and legal action from FTC.

My personal belief is that when the patient's rx has an incorrect PD listed, that the prescribing doctor be immediately stripped of any ability to ever work in the optical field again.

Hopefully, that would get them to either learn how to take PDs themselves, or hire people that actually know how to do it (which does not mean your entry level OD tech).  The PD thing is a joke.  Why should it be on an RX when there are things (like OCs) that need to be measured when the patient is trying on the frame?

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## fjpod

Where are you coming from with a statement like that?  I've seen opticians make glasses with wrong PDs, and incorrect lenses.  Why is this PD thing all of a sudden the doctors fault?  You want to yank a doctors license over PDs and OC measurements when it is the dispensers ultimate responsibility?

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## mervinek

> My personal belief is that when the patient's rx has an incorrect PD listed, that the prescribing doctor be immediately stripped of any ability to ever work in the optical field again.
> 
> Hopefully, that would get them to either learn how to take PDs themselves, or hire people that actually know how to do it (which does not mean your entry level OD tech).


Would this also apply if the wrong Rx is written?  What about Dr's changes?  I had an awsome OD who wrote the incorrect axis the other day.  We are human...where do you draw the line and have someone never work in the field again?

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## newguyaroundhere

> I just wanted to bring back the PD discussion and legal action from FTC.
> 
> My personal belief is that when the patient's rx has an incorrect PD listed, that the prescribing doctor be immediately stripped of any ability to ever work in the optical field again.
> 
> Hopefully, that would get them to either learn how to take PDs themselves, or hire people that actually know how to do it (which does not mean your entry level OD tech).  The PD thing is a joke.  Why should it be on an RX when there are things (like OCs) that need to be measured when the patient is trying on the frame?


So based on your logic here, if you screw up a patient's order, we could ban you from ever working in the field again? Seems legit

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## Quantrill

Just trying to rile up the ODs. Have you read some of the responses on this thread?

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## fjpod

Oh, you're trolling.  That makes it ok.

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## mervinek

> Just trying to rile up the ODs. Have you read some of the responses on this thread?


What the.....

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## drk

Great, Quantril.  

I had a BP of 165 after reading your post, and a HR of 100.  My hair began to fall out.  I spit my coffee out on the computer screen.

Are you happy?

Weirdo.

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## newguyaroundhere

> Just trying to rile up the ODs. Have you read some of the responses on this thread?



I have. But I'm not going to bring up a thread that was dead for nearly 9 months just to merely rustle the jimmies of the ODs on here.

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## Chris Ryser

> *Comments must be received by Oct. 26, 2015, and instructions for filing comments appear in the Federal Register Notices linked to above. All comments received will be posted on the FTCs Public Comments page
> *


I believe we are 12 month late to discuss this matter. There must be a decision put out by now.

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## Hayde

> We are the "slap back" lol
> 
> I don't coddle. I provide excellent customer service, but we're not hired or licensed to coddle. "Doctor is God" may be an offensive notion to patients, but "Customer is King" is for mattress salesmen and leads to us ending up holding the bag. The trick is balancing so yes, needs are met, but that we don't become the commodified doormats to a population increasingly confused to the meaning of the word "deserve" and their entitlement mentalities. Those aren't the people petitioning Congress for changes - it's the corporations that we took in like Mogwais and now the Gremlins have taken over. THAT is where we need to fight.


May have been a dead thread, but it's not a dead issue.  There's a certain [soon-to-be] Senate Minority Leader with strong opinions on this subject whose prospects of another friendly administration next year aren't insignificant.  Both major presidential candidates have strong ties to his home state, and fools in both major political parties may be plentiful enough to grease something like a 'Rx-PD mandate' through.

So the debate is 'minimal health care standards' versus the retort of 'Optometry is insincerely overstating the public health risks of DIY specs.'

Will Optometry win that debate in the arena that matters?

The NIH was mentioned early in the thread.  Is there some way to engineer clinical studies proving our point?  Can docs at least document the anecdotes of DIYs they end up treating?  I wonder if the AOA can mobilize some persuasive science to cut through popular default economic skepticism and Win The Argument.

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## newguyaroundhere

> I believe we are 12 month late to discuss this matter. There must be a decision put out by now.


my remark was in response that the last comment made on this thread was back in November. Well aware the window for comments to the FTC has passed by

And expecting an answer almost a year later from the FTC and government is foolish. Have you seen the people running things? Not exactly ones to get things done in a timely manner

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