As a member of the Virginia Society of Eye Physicians and Surgeons, I am writing this letter to express my concern regarding a 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.

No type of training can truly replicate a procedure in a live patient. Live patients often have difficulty remaining still during a laser eye surgery. Some patients may have tremors, anxiety, or labored breathing which causes movement of their eyes. The eye is a small organ, and the smallest movement of the patient’s eye, even a fraction of a centimeter, can result in dangerous and detrimental outcomes for the patient because laser eye surgery treatment is measured in the sphere of microns.

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.

Jason Huang