As a member of the Virginia Society of Eye Physicians and Surgeons, I write to you today to express my deep concern 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.

This request comes with patient safety as the top priority and ensuring quality, safe care is provided throughout the Commonwealth.