Dear Ms. Moss:
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.
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. The smallest movement of the patient’s eye, even 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.

As a retina surgeon and a professor at a teaching institution, I know very well the amount of training required to competently and safely perform lasers.  Using an eye model is completely ridiculous and endangers our patients.  I have seen enough misdiagnoses and mismanaged patients from optometrists, that I truly fear for our patients with these legislative changes.  Please protect our patients! 

Sincerely,

Retina Specialist