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.