Comment is related to this guidance/document: https://www.townhall.virginia.gov/L/GetFile.cfm?File=C%3A%5CTownHall%5Cdocroot%5CGuidanceDocs_Proposed%5C201%5CGDoc_DOE_4900_20210726.pdf&fbclid=IwAR1QsnfKeliUYnne6LjfeGNwDAvuZYEzdGXjxsuTsC7t5VL-kYBj1BCPHd0
For Visual Impairments – consider specifically clarifying how Virginia’s definition on functional impairments correspond to IDEA and the U.S. Department of Education Office of Special Education. For example, IDEA Part C Subpart A Section 303.13(b)(17) Vision services mean “referral for evaluation and assessment of visual functioning, referral for medical or other professional services necessary for the habilitation or rehabilitation of visual functioning disorders, and orientation and mobility training for all environments, visual training and additional training necessary to activate visual motor abilities. This would include convergence insufficiency and other functional eye impairments. Note that visual impairment for IEP includes if there is an adverse effect on child’s educational performance to include “a functional vision loss where field and acuity deficits alone may not meet the aforementioned criteria” (convergence insufficiency: https://www.nei.nih.gov/learn-about-eye-health/eye-conditions-and-diseases/convergence-insufficiency The US Education Department's Office of Special Education Programs 2017 policy memo: https://sites.ed.gov/idea/idea-files/policy-memo-eligibility-determinations-for-children-suspected-of-having-a-visual-impairment-under-idea/ Further information: https://sites.ed.gov/idea/idea-files/policy-letter-november-12-2014-to-michelle-kotler/