Comment from Deibler, Doug, PA Disability Determination Services (DDS)

The Pennsylvania DDS has reviewed the NPRM on Visual Disorders and feel the additions in the NPRM will help adjudicators make timely and accurate decisions by providing guidance in a central location. We support including the Octopus 32 perimeter test as an acceptable test and adding proposed listing 2.04A. While we support the additions in the NPRM, we suggest expanding the introductory section on scotomas. This section should describe the overall effect of a scotoma on visual fields, as well as provide guidance on which test instrument is best for measuring and evaluating the limitations imposed by scotomas.