The Wa. Academy of Eye Physicians and Surgeons wishes to comment on the Wa. Medical Commission's draft rule regarding "Standards for Professional Conduct", WAC 246-919-604. The comments below should be considered "initial comments" and the Academy may revise or re-address them in the future as the rule-making process moves forward. Our review is intended to reflect the Academy's understanding of the Legislature's intent as it passed SSB 5389 in 2023, as well as the Academy's strong and continuing advocacy for patients to receive high quality vision care. We appreciate the WMC's involvement in writing patient-centric rules concerning this issue. (1)a. We concur. (1(b). We concur. (1)c. We concur. (1)d. We suggest that the surface travel distance from an ophthalmologist's office to a surgical site be "30 minutes" rather than 20 minutes, especially given the rural nature of much of Washington. (2). We concur. (3). We suggest the word "advanced" be substituted for the word "expanded" because the word "advanced" is used in the regulating statute. (3)a. We concur. (3)b. We concur. (3)c. While we concur with the apparent intent of this proposal, we would like the sentence to begin with the phrase "Unless directed by a qualified physician", to assure that the most appropriate care under a given circumstance may be undertaken by the involved parties. In addition, we suggest that the word "advanced" be substituted for the word "expanded" because the word "advanced" is used in the regulating statute. (3)d. We concur. (3)e. It is our view that that the word "intervene" is not sufficiently clear, or defined. We suggest that the term "rapidly respond" be substituted, as that is the language used in the regulating statute. To be clear, the only procedures addressed in the statutorily-mandated agreements are those "advanced procedures" referenced in SSB 5389. (3)f. We concur. (3)g. We would again suggest that the term "emergent response" be replaced with "rapid response", reflecting the statute. (3)g)i. We concur. (3)(g)ii. We would again suggest the term "intervention" be replaced with the term "rapid response". (3)(g)iii. We concur that such reports should not specify patient information but would strongly suggest that this sentence be prefaced by "Pursuant to RCW 70.02 for added assurance about patient privacy. (3)(g)iv. We concur. Thank you for your attention to our comments. We intend to formally submit them at a future date. Please let us know of any questions you may have. Stephanie Cramer MD, WAEPS Legislative Chair and Former WAEPS President, submitted on her behalf by Susie Tracy.