Greetings,
The Tennessee Dispensing Optician Associations would like to express our concerns over the changes recently implemented in rule 1045-02-09. Specifically section (3) h, i, and j. As a group of over five hundred licensed eye care professionals practicing and fulfilling prescriptions in the state of Tennessee, we feel these requirements to be both unnecessary and restrictive in protecting the health and welfare of the general public. Opticians are considered professionals trained and knowledgeable in the interpretation of an rx prescribed by an optometrist to design a pair of eyeglasses to fit the patient’s daily needs. By requiring the Optometrist to include the type of multifocal, tint and inter pupillary distance, the rule restricts the Optician from utilizing information gathered from the rx and the input from the patient, to fill the written prescription with a device that both fulfills their daily needs and budgetary concerns. As a licensed professional, an optician is also trained and knowledgeable of the manufacturing requirements in regards to measurements necessary to provide the patient with the best visual outcome of a device designed to best fulfill the patients needs. For decades, the Optometrist has relied on the expertise of the Optician to assist the patient in the selection of the best materials and design as well as placement and care of a device to aid the patient in satisfying their daily needs. This relationship has allowed the Optometrist to remain unencumbered in focusing on the health and welfare of the patient’s eyes without having to take up their valuable time in the design of devices. By mandating the requirement of the aforementioned information to now be placed on the rx, the rule inadvertently restricts the optician’s ability to fulfill patient needs without encroaching on the Optometrist time to alter the original rx. As professional licensed health and welfare representatives, we feel this restriction to cause harm to the public by restricting them to only limited solutions for aid. We feel that this information is unnecessary in a state that has numerous licensed health and wellness professionals, Dispensing Opticians, to assist in this process. Furthermore, by mandating the inclusion of inter pupillary distance, the rule inadvertently opens the door for the layperson to incorrectly use this information to fill their prescription in an online experience that may or may not provide the best solution for their needs until certain determinations in design are achieved.
We respectfully ask that the Optometry Board consider rescinding this rule with an emergency rule to further discuss solutions that will best meet the protection of the general public without causing harm.
Sincerely
TDOA Officers