As the Secretary of the Northern Virginia Academy of Ophthalmology and 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. A plastic model is not enough. 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 method of training is simply inadequate for anyone wishing to perform lasers and obviously threatens the safety of patients. As someone who is closely involved in the training of ophthalmology residents and vitreoretinal surgery fellows, I know the nuances of teaching procedural skills such as laser treatment to trainees. I would not allow my trainees to perform laser procedures unless they have been appropriately trained because I know the risks involved with laser treatment, especially by improperly trained individuals. I would not allow an optometrist with the minimum level of training included here to perform laser treatment on any of my patients or  my family members because it is clearly inadequate. No patient should accept this and no regulatory body should find it acceptable to have such a low standard for patient safety.

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 change to the draft regulations to ensure optometrists across the state are trained to appropriately high standards.

Mohsin Ali, MD

Co-Director of Vitreoretinal Surgery Fellowship Program

Retina Group of Washington

Secretary, Northern Virginia Academy of Ophthalmology