The Virginia Optometric Association (VOA) thanks the Regulatory Advisory Panel (RAP) for drafting the proposed regulations and the members of the Board of Optometry for their continued work. We believe these draft regulations present a consensus amongst all stakeholders, including the Optometrists and Ophthalmologists who both served on the RAP. As proven, we know that Virginia’s Optometrists are properly and highly trained to perform these laser procedures. The draft regulations provide the appropriate measures needed to regulate Virginia licensed Optometrist who wish to perform these Ophthalmic laser procedures while protecting the interest of the public. We believe the draft regulations related to initial certification are more than adequate to qualify a provider. We support the educational attestation from a dean or designee of a school of optometry or an instructor of a laser surgery certification course approved by the board to be sufficient evidence of obtaining the appropriate didactic and clinical laser surgery training. We support the quality assurance review process as presented. We support the language that "Proctored session" means any surgery on a live patient or procedure performed on a model eye. We support no more than two proctored sessions for each of the laser procedures. In the end, we thank for board for their work and encourage you to proceed with the draft regulations exactly as presented with no modifications or changes.