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costs that were in the proposed regulation.

Types of early intervention services--vision services (new

§303.13(b)(17)) (proposed §303.13(b)(14))

Comment: Some commenters requested that the Department

clarify the definition of vision services in new §303.13(b)

(17)(iii) (proposed §303.13(b)(14)(iii)). A few commenters

noted that the definition focused on older children and did not include the full scope of instruction available to young children and their families. One commenter expressed concern that the definition of vision services in new

§303.13(b)(17) (proposed §303.13(b)(14)) described an

outdated medical model that promotes skills training, rather than developmental adjustments that accommodate vision loss. A few commenters recommended that we add to this definition training and services in the following areas: tactile awareness, sensory utilization and preferences, emergent literacy, precane skills, environmental orientation, environmental adaptations, and modifications and conceptual understanding where visual impairment (including blindness) precludes typical access to early intervention.

One commenter suggested that the services listed could be included instead in the definition of special

instruction in new §303.13(b)(14) (proposed §303.13(b)(11))