In regard to 22VAC45-51-10. Definitions., I support the clarification. I agree that both optometrists and ophthalmologists should be included.  I believe that optometrists are actually more likely to have the training to be specialized in low vision and vision rehabilitation services.  These corrections more aptly acknowledge the abilities and scope of practice of optometrists. 

Patient access to such services (low vision/vision rehab) will be increased if optometrists are included. For this reason, I feel that 22VAC45-51-40 Eligibility for vocational rehabilitation services (section D.1.b.) should be changed to include optometrists.  Our optometric training certainly includes examination, diagnosis, monitoring, and management of many eye conditions that may lead to progressive vision loss.  Optometrists are readily accessible across Virginia.  Revision of this proposed regulation to include optometrists is necessary to insure that patients who need these services can access them easily.