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schools, and $825 for private schools. When we compare tuition and fees in schools of medicine, dentistry, and optometry in the same university, the difference in costs is in about the same order of magnitude.

When we look at the length of training, we find training for optometry usually consists of 3 years at a school of optometry after 2 years of undergraduate college education—or 5 years in all. All schools are on this program except the University of Houston, where there is a 4-year program in the school of optometry, and it has been indicated that Ohio State University plans to initiate such a 4year program in the fall of 1964. Although there are a few schools of dentistry and medicine that will accept students with less than a baccalaureate degree, the competition for places in medical and dental schools makes 4 years of college work a practical requirement for admission. The professional academic course of dentistry and medicine requires 4 years, and an internship is required in medicine and recommended in denistry. This is a total of at least 8 or 9 years, compared with the 5 for optometry. Furthermore, most physicians serve a residency of from 2 to 4 years after completion of their intern

Therefore, both in the annual costs of education and in the number of years required to complete the training, medicine and dentistry have substantially greater requirements than optometry.

Furthermore, both the average annual loan to students of optometry under National Defense Education Act in 1963, which was $628, and the total estimated need of such students are well below the maximum allowances of $1,000 per year and $5,000 total authorized under the National Defense Education Act.

The Health Professions Educational Assistance Act, as you know, provides that a loan does not become repayable until 3 years after the student ceases to pursue a full-time course of study. This provision was included, of course, because of the requirements of internship and residency. The National Defense Education Act loans become repayable in the year following the completion of the course of study, and we believe this is a more appropriate requirement for optometry which has no internship or residency.

We might also call to your attention that at the present time the interest rates under the National Defense Education Act are more favorable than those under the Health Professions Educational Assistance Act. As you know, the National Defense Education Act interest rate is 3 perecnt. The Health Professions Educational Assistance Act interest rate is 3 percent or the going Federal rate, whichever is higher; and at the present time is ranging between 37 percent and 414 percent. Since the Health Professions Educational Assistance Act specifically provides that as long as an eligible institution has an agreement to participate in its loan program no medical or dental student can receive a loan under the National Defense Education Act, therefore there would be no opportunity for a student to choose the lower interest rate if his school has embarked on a loan program under the Health Professions Educational Assistance Act.

In summary then, our recommendation against enactment of these bills rests upon the following factors:

1. There has been no clear and documented evidence of a critical shortage of optometrists, such as to jeopardize the health of our citizens.

2. Adequate assistance is available to students of optometry under the loan provisions of the National Defense Education Act, and is likely to increase.

3. The loan provisions of the Health Professions Educational Assistance Act were tailored to meet requirements of longer and more expensive professional training than that of optometry.

Thank you, Mr. Chairman. I would be happy to answer any questions. Mr. ROBERTS. Thank you, Dr. Peterson.

. This position of the Department is a little bit confusing to me in that this question of shortage in this particular field has been before the Congress, particularly since the debates in the Senate on this bill in the last session.

Now, if I am correct, there was an amendment offered in the Senate to include optometry for loans under H.R. 12. That is to include not loans but construction.

Dr. PETERSON. That is correct.
Mr. ROBERTS. And that was accepted. That is correct; is it not ?

Now, it would seem to me that if the Congress as a matter of policy found it wise to include construction money in a major piece of legislation such as this bill, then the Department might have anticipated that this question of wanting to—that is, this desire of this committee and a similar committee in the Senate would have been desirous of getting some facts and figures together as to whether or not the students hoping to pursue this profession should have some additional consideration. Does that appear to be a reasonable thought to you?

Dr. PETERSON. Yes, sir. I think, as a matter of fact, it is a very reasonable expectation on the part of the committee. I can only say that the Department has not undertaken such studies at the present time. We felt that we had problems that were presented to us with reference to some of the other professional categories in which there were existing data that could be used for presentation of materials to Congress such as in the health professions, the public health training programs, and nursing. However, we have not undertaken studies in optometry, and I would want to say also, Mr. Chairman, that even if a year ago we had initiated such studies to try to gather information in depth equivalent to that in some of the other health professions, we would not have been able to complete them in this period of time.

However, I offer this as no excuse to the committee for not having such data available for your consideration at this time.

Mr. ROBERTS. The position, then, of the Department at this point is that since we do not have the facts and figures which do or do not establish a shortage, that the Department simply recommends against the bill. Is that a fair statement of the Department's position?

Dr. PETERSON. With one other addition, Mr. Chairman, and that being the fact that, as we have indicated, it would appear from our study of the financial needs of optometry students, at least as reflected by their use of the National Defense Education Act student loan program, that this financial assistance provided in the National Defense Education Act is meeting their fiscal needs insofar as we are able to determine, plus the fact that, as we indicated, it is a more favorable loan program than that provided under the Health Professions Assistance Act. So it appears to us that, at this point in time, we do have

a Federal program to assist in meeting the need, and in the absence of, as you point out, specific data indicating the levels of professional personnel in optometry that might be desirable, we feel that this is meeting their financial requirements.

Mr. ROBERTS. Well, of course, I think that is subject to some-in fact, a good bit of argument because in an exchange between you and Mr. Nelsen-I won't refer to it as an exchange but the testimony appears on page 56 of the record, and Mr. Nelsen was restating the position of the Department when he said 174 students are now getting loans, and I believe that elsewhere in the testimony, we are now graduating around, what, 500 a year over the country which

Dr. PETERSON. I think at the present time enrollment is 1,000 or, at least in 1962–63, Mr. Chairman, it appeared that the enrollment was 1,319. It probably is up some over that in the present year.

Mr. ROBERTS. Well, this indicates, then, about roughly 14 percent?

Dr. PETERSON. That is correct.

Mr. ROBERTS. Do you know if the Department has any plans for making a study in this direction?

Dr. PETERSON. It is my understanding that the Public Health Service has been approched about, and is in negotiation with the Optometric Association with reference to the possibility of a study and what its character might be, and the respective elements of it that would be assumed by the profession and by the Department. However, I am not familiar with the exact status of those negotiations at the present time.

Mr. ROBERTS. Well, it would seem to me, and I am not saying this critically of the Department, but it just seems to be a fair situation, it would be fair, for the Department to make an honest effort to come up with some facts and figures. We have done it all along the line. We had no less than three or four long-range studies of the need for doctors and dentists and osteopaths. We have had many studies on the subject of nursing. And it would seem to me that this could be a very—is a very vital matter, and in fairness to the people who are interested on this side and on the other side, and the general public, and the people in this profession, the Department ought to have already had, in my opinion, some studies made in this field.

Mr. Rogers?
Mr. ROGERS of Florida. Thank you, Mr. Chairman.

I am somewhat concerned still, Dr. Peterson, on the attitude of the Department not knowing the needs. Of course, I understand your second reason for taking the position you do, that you would be opposed to the bill, the Department would be opposed to the bill because there are some funds now being made to the students. Is that your second position?

Dr. PETERSON. That is
Mr. ROGERS of Florida. National Defense Education Act.
Dr. PETERSON. That is correct, sir.

Mr. ROGERS of Florida. How was it that they were included in the National Defense Education Act?

Dr. PETERSON. They are one of the categories of students eligible for financial assistance under the National Defense Education Act program, and, as I have indicated, although this is an Office of Edu

cation matter, we are advised that they would anticipate greater resources to be available, so that even if the three schools that are not now participating in the program, decided that they desired to participate in student loans for their attendance, this would be possible.

Mr. ROGERS of Florida. Well, now, I believe it is your reasoning, too, that since there are 14 percent of the students of optometry receiving the loans, therefore, it means they have no need for special loans, even though you do not know what the need is; is that true!

Dr. PETERSON. No. I am sorry, sir. The point that we were making there is the fact that students of optometry are now participating to a greater extent apparently in the student loan programs under National Defense Education Act than are the general students in college.

Mr. Rogers of Florida. Yes. I realize that, but I thought the conclusion you draw from that was therefore this decreased the need for any special help in this regard.

Dr. PETERSON. Well, it would from this point of view to show that it is possible for the National Defense Education Act program to meet even larger needs on the part of optometry students than for the general student body in collegiate attendance. And, therefore, we would expect in light of the fact that there are greater resources being made available for students loans under this program, that the numbers participating under the National Defense Education Act could be increased in order to meet even greater fiscal requirements that they might have that are presently not being respected.

Mr. ROGERS of Florida. Doesn't it show you there is some extraordinary need, then, for students of optometry to have this help if already they are using present programs more than any other category?

Dr. PETERSON. Yes. And if there were evidence that the program did not have adequate funds to meet that substantially greater need, then we would obviously not be able to take this position with reference to it.

Mr. ROGERS of Florida. Well, how do you know? You have not made any study.

Dr. PETERSON. The only evidence that we have, Mr. Congressman, is that at the present time the average loan is wel below the annual ceiling and well below the total authorized loan under the National Defense Education Act.

Mr. ROGERS of Florida. Well, I was thinking of numbers, not necessarily of the amount of the individual loan. I was thinking of students.

Now, have you gone over the testimony that the optometry people have presented to the committee?

Dr. PETERSON. Yes, sir. We were present when they presented their testimony.

Mr. ROGERS of Florida. Have you seen the figures that some of the schools of optometry are now turning away students? Instead of one in three being accepted, they are now having to reject three out of four. Does this cause you any concern?

Dr. PETERSON. Well, this is a cause for concern. On the other hand, there was published in the Journal of the Optometric Association for the year 1962–63 a study by Morgret-34: 795, May 1963—on optometric education in the United States which indicated that enrollment in 1962–63 was below that possible for the schools to handle with their present faculty. So it would appear that even though there are increases at the present time in the applications for places in the classes, and some of the schools have substantial numbers of applicants that they are unable to accept, in aggregate in the schools of optometry, at least in the 1962–63 academic year, there were additional places available for substantially larger numbers of students.

Mr. ROGERS of Florida. Well, perhaps an added incentive to get these people into these schools, this might be possible, too, I do not know. It would indicate that.

Now, have you gone over the chart where it shows where many of the areas of the country have no optometrists and some very high ratio, 1 to 21,000, 1 to 20,000! Have you gone over these charts?

Dr. PETERSON. Yes, sir.

Mr. ROGERS of Florida. In the various States? Does the Department have no concern about this?

Dr. PETERSON. The Department does have concern, sir. On the other hand, at the present time we think of the problems of refractive errors and of eye muscle disturbances, these do not represent emergencies. They can be taken care of without the need for, perhaps, the immediate attendance of a specialist within the community. This does not solve an overall problem as you have pointed out. On the other hand, during the period when we are trying to assess the questions of professional need, it is not apparent to us even though there are substantial areas where the ratio of optometrists to population is less than the national average, that people are going without refractive correction, and that those who would need to have optic attention have not been able to be referred for such attention when it was determined desirable by their professional attendant.

Mr. ROGERS of Florida. Well, now, you make this determination, that all of these people do not need any optometric care.

You have not done any study on it. How do you

Dr. PETERSON. No.
Mr. ROGERS of Florida. How do you come to this conclusion?

Dr. PETERSON. The conclusion that we have come to is that we do not have at the present time evidence that would indicate that there are substantial numbers of individuals, even in these shortage geographic areas, who are going without refractive correstion of other treatment. We have not made a professional judgment in terms of whether there is adequate or inadequate or improper distribution of members of the profession to serve the total and optimal eye disease requirements of the population. We admit that there are undoubtedly areas of the country where this is inadequately provided.

Mr. ROGERS of Florida. Well, can't you take figures that were presented to you, even though it may be the professional people themselves who are involved? Can't you go over those and make some determination whether there is validity in these or not without any vast 2-year study where they have already got facts for you?

Dr. PETERSON. We would be able, yes, sir, to do some work in that regard.

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