As a member of the Virginia Society of Eye Physicians and Surgeons, I write to express my deep concern for patient safety regarding the particular section in the draft regulations regarding proctoring for those individuals seeking certification for laser eye surgery.

As the Board of Optometry finalizes the regulations for laser surgery certification, I strongly recommend amending the draft regulations to reflect a proctoring process that requires both didactic and live proctored cases, whether or not a plastic model is involved. Currently, the draft regulations are written so that proctoring can be done on a model eye or on a live patient, and in some cases proctoring is not even required.

Many factors can lead to challenges in performing a laser surgery procedures.  A patient may be unable to stay still enough due to medical conditions or even poor positioning by the laser operator.  If the laser application is even a millimeter off target, permanent and irreversible damage may develop in the patient’s eye.  Live proctoring of cases is a MINIMUM to develop the skills required to safely perform these laser procedures - it is NOT automated by the machines.  

This request comes with patient safety as the top priority and ensuring quality, safe care is provided throughout the Commonwealth. I strongly hope you will consider this change to the draft regulations to ensure optometrists across the state are trained to the highest standard.