I am Judth M. Canty (lic. 1101000891), a licensed Optician in Virginia since 1978. I have been endorsed to fit and dispense contact lenses since 1979.

I believe that the current Optician Regulations under Title 54.1, Chapter 15 and updated October 25, 2022 should remain in effect with the following changes:

1. 54.1-1507, Practice of opticians restricted. The Commonwealth has been unable or unwilling to address the use of the protected title of Optician by businesses both large and small. These bussinesses hold their employees out to the general public as being qualified by virtue of the use of a title restricted to those who hold a license issued by the Commonwealth of Virginia. Therefore, the very citizens the regulations are designed to protect are unable to determine if they are being cared for by a properly trained and licensed individual. While many may argue that holding a certificate issued by the American Board of Opticians is sufficient, it is only part of the process for licensure in Virginia and therefore does not meet the standards of the regluations.
2. This lack of oversight raises the cost of prescription eyewear to the citizens of the Commonwealth. For the past 15 years, I have been the Territory Manager in Virginia for Luzerne Optical Labs and have had the opportunity to interact with Ophthalmologists, Optometrists and Opticians through in-person and in-office visits. In those 15 years, I have found that there is a marked difference between the quality and service our citizens have a right to expect when there is an absence of licensed and regulated Opticians.
3. While errors are bound to occur, the remake percentage in my territory of Virginia is between 8.5 and 13.0 percent. Remakes are orders placed to correct an initial order either through improper communication or through a lack of professional knowledge, skills and abilities. Remakes are the leading cause of higher prices to the public. While some businesses may argue that those remakes are sometimes done at no charge to the patient or practitioner, the harsh reality is that those costs just don't disappear. They are reflected in higher costs to lens and frame manufacturers and to the wholesale laboratories, such as Luzerne Optical, my employer who supply finished eyewear to the practitioners. These increases are felt through the entire chain of transactions. There is no "free lunch" here. Every error bears a cost that is ultimately borne by the consumer in the form of higher prices.
4. I have 2 recommendations to be considered by the Department of Professional and Occupational Regulation:
   1. Institute an effective mechanism for addressing the use of the protected title of Optician by businesses and other entities in willful violation of 54.1-1507.
   2.  Institute a requirement for continuing education for all regulants covered by 18 VAC 80-30 in the same manner that is required by other professions under the control and oversight of DPOR. Citizens of the Commonwealth have the right to competent and well-regulated professional services.

Respectfully ,

Judith Canty

judy.canty@gmail.com

757-803-4987