Virginia Regulatory Town Hall
Agency
Department for the Blind and Vision Impaired
 
Board
Department for the Blind and Vision Impaired
 
chapter
Regulations Governing Provisions of Services in Vocational Rehabilitation [22 VAC 45 ‑ 51]
Action Amend regulations for clarity and update
Stage Proposed
Comment Period Ended on 3/11/2016
spacer
Previous Comment     Next Comment     Back to List of Comments
2/17/16  1:22 am
Commenter: Dr. Robert M. Allen, President-Elect - Virginia Optometric Association

Clarification of Eye Doctor Services
 

I support the corrected and clarifying inclusion of both optometrists and ophthalmologists in 22VAC45-51-10. Definitions.  They reflect and properly recognize the scope of practice of optometrists, who by clinical training are more likely to be specialized in low vision and vision rehabilitation services.

To be accurate and necessarily improve access for patients, 22VAC45-51-40 (Eligibility for vocational rehabilitation services), section D. 1. b. needs to be revised to include optometrists.  Evaluating, diagnosing and monitoring rapidly progressive eye conditions are a basic part of optometry's clinical training and their authorized scope of practice.  Further, this reflects services offered by optometrists throughout Virginia.  Patient access will clearly be improved by inclusion of this language as optometrists are far mor geographically distributed than their ophthalmology colleagues.  Thank you.

CommentID: 49625