Dear Ms. Moss: 

As an ophthalmologist, 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.

There is a wide spread list of physiological issues that can affect individuals’ ability to remain still during a laser eye surgery procedure. Some examples of these varying factors can include, but are not limited to, tremors, anxiety, or breathing movements particularly for obese patients, positioning of the patient, etc. Furthermore, different implant materials respond differently to laser and merit different techniques. Multifocal implants, as an example, can very easily lose their refractive properties with YAG laser defects. Without proper live patient experience and proctoring in this area, providers will be learning on the job at the patient’s expense. A plastic model in isolation cannot possibly be sufficient to teach any provider safe and effective laser technique. 

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.