Opposition to the adoption of New Proposed Florida Standard of Practice Rule requiring a Pharmacologic Dilated Fundus exam for the initial patient encounter in Florida.
Florida Board of Optometry Meeting – January 17, 2020
Proposed Changes to Rule 64B13-3.010 Standards of Practice
Comments on Behalf of DigitalOptometrics LLC
Thank you for the opportunity to be heard today on the Proposed Florida Board of Optometry Rule
Amendment to the standard of practice for optometry. The change would require a “pharmacologic
dilated fundus examination during the patient’s initial presentation.”. If adopted the Rule Amendment
will require an in-person on-site Optometrist to perform an optical exam on a patient before an optical
exam can be performed by remote technology.
As a quick background introduction, my name is Howard Fried. I am a graduate of The Johns Hopkins
University and The State University of New York, College of Optometry; have been a practicing
Optometrist for over 15 years, and owned and operated a wholesale optical laboratory which I sold in
2010 and operated as its President until 2016.
In 2016 I formed DigitalOptometrics and hired software developers with optical experience, under my
direction, to create a comprehensive eye exam to be performed remotely for DigitalOptometrics – a
company system that replicates an “on-site in-person” exam by facilitating remote comprehensive eye
health and vision exams, performed by licensed Optometrists who communicate live via hi-definition
video conference with each and every optical patient.
DigitalOptometrics system has not performed a single refractive only solution in more than
50,000 remote exams performed to-date. We are firm believers that ocular health and refraction
should not be separated. Every patient not only receives a full subjective refraction, but also has a non-mydriatic retinal image taken for posterior seg evaluation, an anterior segment exam performed and recorded with the use of a video slit lamp and a Non-contact tonometer takes a pressure reading. In addition, we integrate with visual fields and OCT’s. Entrance test exams can be recorded as well – such as Pupil testing, EOM’s CVF’s, color vision and stereopsis.
Net Promoter Score Surveys are provided to each patient following the exam. After thousands of
completed surveys, our NPS results are in the mid to upper 80’s. Our redo rates are a fraction of 1
percent. Optometrists are far and above the best gatekeepers in the health care industry.
Optometrists utilizing the DigitalOptometrics technology have found countless cases of diabetic
retinopathy, retinal tears and holes, glaucoma, cataracts and other ocular diseases which have been
referred to onsite Optometrists or Ophthalmologists for further care and treatment. A recent research
study was performed at a college of Optometry utilizing the DigitalOptometrics technology and found
that the results mirror the results of an on-site in-person exam.
In June 2019, I was asked to speak at the 100th anniversary national meeting of ARBO (Association of
Regulatory Boards of Optometry). The President of ARBO was clear that “the Tele-Optometry train has
left the station and that we cannot over-regulate our way out of this or we will be left behind”.
The technologies of today in medicine allow us all to live longer healthier lives. Practitioners have
embraced technology as advocates of patient care. Optometry is no different. Wide-field retinal
imaging has provided a recordable 200 degree image of the posterior segment that has improved our
diagnosis and early detection. So has OCT’s and many other technological advances. To mandate that
every Florida patient receive a dilated fundus exam is archaic, not in the best interests of patient
care, and now for the first time made a requirement will prevent increased access to eye care through
telehealth to the underserved. That requirement undermines the legislative intent of the Florida
Telehealth Law and the enactment of the legislation signed by the Governor and would prevent optical
patients in the State of Florida greater opportunity for eye health and vision analysis exams for early
detection of disease and corrective vision.
There are ways to keep irresponsible technologies out of the State of Florida while permitting Doctors
of Optometry to utilize responsible technologies in their clinical decision making. There is a large
number of Optometrists in the State of Florida who seek the ability to offer remote comprehensive
care to underserved areas and provide patients better access to quality eye care which this technology
allows. Please do not utilize a “wide brush” to deny Florida patients access to responsible tele-
optometry technologies, such as DigitalOptometrics, and force all technologies to utilize
Ophthalmologists, who would not be bound by this Rule Amendment, instead of licensed Optometrists.
To do so would not be in any of our interests, nor in the interests of the patients that we all are here to serve. Thank you.
We request that our comment be made a part of the Rule record. Any questions for DigitalOptometrics can be directed to Howard S. Fried, O.D., President at email@example.com or 516-243-8575.