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