I support this new language and clarification of this code is needed.  The correction that is needed within 22VAC45-51-40 is in section D.1.b.  This needs to be revised to include optometrists.  Evaluating, diagnosing, and monitoring rapidly progrssive eye conditions are part of optometry's clinical training , authorized scope, and reflects services offered by optometrists all over Virginia.  Again, 22VAC45-51-40 section D.1.b needs to state :"The individual has a rapidly progressive eye condition that, in the opinion of a qualified optometrist or ophthalmologist, will cause the individual to require a specialized service available through DBVI, or"

Virginia Optometric Association (VOA) strongly supports updating the definitions found in 22VAC45-51-10.  Not only do they reflect Virginia statute, but reflect the current scope and clinical training of doctors of optometry.  Such is critically important in that low vision services are largely provided by optometrists.

In the eligibility for vocational rehabilitation services, specifically 22VAC45-51-40 D.1. subsection b. needs to be corrected by including optometry, indicating "in the opinion of a qualified optometrist or ophthalmologist."  Doing so complies with the definition section, reflects optometrists' scope of practice and clinical training to evaluate, diagnose, monitor and when applicable treat "rapidly progressive eye conditions."  With optometrists having much wider geographic distribution in Virginia and that approximatel 70% of the public relies on optometrists for their eye and vision care, this correction will clearly improve patient access and result in greater availability of DBVI services to those eligible and in need.

I'd like to add my support to the corrected clarifying inclusion of both optometrists and ophthalmologists in 22VAC45-51-10 definitions.

In order to be accurate and improve access for patients 22VAC45-51-40, (Eligibility for vocational rehabilitation services) section D.1.b. needs to be revised to include optometrists, who by clinical training are more likely to be specialized in low vision and vision rehabilitation services.

Evaluating, diagnosing, and monitoring rapidly progressive eye conditions are part of the optometry's clinical training, their authorized scope, and reflects services offered by optometrists throughout Virginia. With much greater geographic distribution of optometrists, this revision will clearly improve patient access.

Thank you for your time,

Dr. Adamopoulos

I support the correctied inclusion of both ODs and MDs 22vac45-51-10 definitions.  They reflect recognize the scope of practice of ODs who are clinical trained in low vision and rehab services.  

22vac45-51-40, section D.1.b. needs to be revised to include Optometrist.  

I support inclusion of Optometrists in section D.1.b. of bill 22VAC45-55-40.  Optometrists as well as Opthalmologists are trained to be specialized in low vision. This will greatly enhance patient access to a qualified eye care practictioner. 

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.

I support the corrected clarifying inclusion of optometrists and ophthalmologists in 22VAC45-51-10 definitions. 

To improve patient access, 22VAC45-51-40 should include optometrists. (ie. “… in the opinion of a qualified optometrist or ophthalmologist.”) Optometrists have a greater geographic distribution than ophthalmologists and are clinically trained in evaluating, diagnosing, and monitoring rapidly progressive eye conditions. 

I'm a practicing optometrists from Virginia Beach and I would like to add a comment.  

I support the corrected clarifying inclusion of both optometrists and ophthalmologists in 22VAC45-51-40 (Eligibility for vocational rehabilitation services), section D. 1. B. which needs to be revised and include optometrists.  Optometrists are licensed to evaluate, diagnose, and monitor rapidly progressive eye conditions which is a part of our clinical training and scope of practice.  

I am a practicing optometrist in the state of Virginia. Two of the four optometrists in our group practice currently provide specialized services through the Virginia Department for the Blind and Visually Impaired (DBVI). We see firsthand how this program benefits the citizens of the Commonwealth. Optometry should be included in the determination of eligibility for these same vocational rehabilitation services that we currently provide.

Section 22VAC45-51-10. Definitions should include Optometrists practicing the profession as defined by 54.1-3200 Code of Virginia and as regulated by the Board of Optometry 18VAC105-20.

Section 22VAC45-51-40 D1b should revised to include optometrists.

These clarifications are consistent with our training and with the professional services we currently provide. The large geographic footprint of optometry throughout the State of Virginia will insure better access for patients. Thank you the opportunity to share these comments and please contact me if I can help in any way.

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.

I am in favor of  22VAC45-51-40 as long as a change is made to include "Optometrists" in D. subset b.  

I believe it should read:

b. The individual has a rapidly progressive eye condition that, in the opinion of a qualifed optometrist or ophthalmologist, will cause the individual to experience functional limitations related to obtaining, regaining, or maintaining employment and causes the individual to require the specialized services available through DBVI or,

Doctors of optometry are trained in the diagnonsis and treatment of eye disease, and are trained in handling patients with visual diabilites or low vision.  It is therefore appropriate for this inclusion.

Thank you,

Dr. Jenny Alsop, Optometrist

The wording should be amended to include optometrists.  We are trained to diagnose and manage eye diseases and visual impairments, and with regard to assessing a patient's needs a outfitting him with devices to aid those with low vision, we are more uniquely qualified than our ophthalmological colleagues.  Including Optometry also expands access to services for Virginians.  Please consider amending the language.  Thank you.

The wording should be amended to include optometrists.  We are trained to diagnose and manage eye diseases and visual impairments, including rapidly progressing conditions.  With regard to assessing a patient's needs and outfitting him with low vision devices, we are more uniquely qualified than our ophthalmological colleagues to provide these services.  Including Optometry also expands access to services for Virginians.  Please consider amending the language.  Thank you.

Thank you for taking comments regarding 22VAC45-51-40.  Eligibility for Vocational Rehabilitation Services.  Section D1b of this document says that a patient should be diagnosed with an eye disease by a qualified ophthalmologist.  To be more correct, Section D1b should state that the eye disease should be diagnosed by a qualified ophthalmologist AND/OR OPTOMETRIST.  Optometrists are the leading eye care providers, serving a much wider proportion of the people living in the Commonwealth of Virginia compared to ophthalmologists, and our profession is fully capable of diagnosing most all diseases that would qualify a patient for vocational rehabilitation services.  Sincerely, Jen Weigel, OD, FAAO

Optometrists should be included.  Optometrists diagnose and treat eye disease and quite frankly are now the primary gatekeeper for eyecare and treatment.  Please reconsider and add Optometrists.

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.

This proposal should include verbage that states that a licensed optometrist and/or ophthalmologist can diagnose eye disease(s) that would confirm eligibility for Vocational Rehabilitation Services.  Both professions are adequately qualified to make sure diagnoses.  At times optometrists are more accessible than ophthalmologists (especially in rural areas) and therefore it would benefit the public/patients to have the flexibility to visit either profession.  Thank you for your consideration on this matter.

I support the needed inclusion of both optometrist and ophthalmologist in 22VAC45-51-10 Definition. Optometrist are clinically train and more likely to specialize in low vision and vision rehab services. Section D.1.b needs to be revised to include optometrist