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.