6.  Developmental Delay.  [8 VAC 20-81-80, pg. 121]
I oppose limiting the developmental delay category only to the ages of 2 to 5 and recommend retaining the current Virginia definition of developmental delay which includes the ages of 2 through 8.  The developmental delay label is especially important for children who exhibit delays and benefit from early intervention, but who may not be easily identified. 
 
7.  Definition of Autism  [8 VAC 20-81-10, pgs. 12-13]
I recommend that the proposed Virginia regulation defining autism reflect that of federal regulation, which states, "A child who manifests the characteristics of autism after age three could be identified as having autism if the criteria in this definition are satisfied". 
 
8.  Eligibility Criteria  [8 VAC 20-81-80, pg. 119-120]
I oppose including any eligibility criteria for disability categories in the regulations that exceed those specifically defined in the federal regulations.  Such overreaching provisions may work to the disadvantage of children who would otherwise qualify for services as a child with a disability.

 
9.  Definitional Terms for Disabilities  [8 VAC 20-81-10, pgs. 36, 24-25]
I recommend the regulations use the term "intellectual disability" in place of "mental retardation".  Similarly, I recommend use of the term "emotional disability" rather than "emotional disturbance".  Both current terms convey negative stigma on the child, are outdated and offensive to many.