I support updating the definitions in 22VAC45-51-10.  These definitions reflect the current scope and training of doctors of optometry.  It is critically important that low vision services are provided by optometrists.

To improve patient access and greater availability of DBVI services, 22VAC45-51-40 D.1. subsection b. needs to change to include optometry.  Specifically it need to indicate "in the opinion of a qualified optometrist or ophthalmologist."  This change will be more in line with the aforementioned definition section, thus reflecting optometrists' scope of practice and clinical training.  Optometrists are trained to evaluate, diagnose, monitor and when applicable treat "rapidly progressive eye conditions." 

Thank you.