Scope of Practice Expansion

AB 407, COA’s scope of practice legislation, has been signed into law. It took effect January 1, 2022. Below is a summary:

Scope Expansion

  • Eliminates the lists of allowed drugs and conditions in statute and instead authorizes treatment of all non-cancerous anterior segment conditions, with some limitations. New conditions that could be treated with medication include ametropia, presbyopia, ptosis, cataract, etc.

  • Before AB 407, optometrists could only treat four kinds of inflammation for those over 18: inflammation resulting from traumatic iritis, peripheral corneal inflammatory keratitis, episcleritis, and unilateral nonrecurrent nongranulomatous idiopathic iritis. Optometrists could not treat inflammation in children under the prior law.

  • AB 407 allows treatment of all kinds of inflammation in adults. It prohibits treatment of anterior segment inflammation in children, except for treatment of the conjunctiva, non-malignant ocular surface disease, including dry eye syndrome, contact lens related inflammation of the cornea, or an infection of the cornea.

  • It also allows all antiviral medication. Under the prior law, there are only six conditions for which optometrists can use antiviral medication: herpes simplex viral keratitis, herpes simplex viral conjunctivitis, periocular herpes simplex viral dermatitis, varicella zoster viral keratitis, varicella zoster viral conjunctivitis, and periocular varicella zoster viral dermatitis.

  • Allows optometrists to use antifungals. Optometrists were prohibited from using antifungals under the prior law.

  • Eliminates the referral requirement after 21 days for antiallergy agents. Specifically, it deletes the following sentence: “In using topical steroid medication for the treatment of ocular allergies, an optometrist shall consult with an ophthalmologist if the patient's condition worsens 21 days after diagnosis.”

  • Eliminates the restriction on treatment of the lacrimal system, and replaces it with a restriction prohibiting treatment of the lacrimal gland. Treatment of dacryocystitis and canaliculitis would therefore be allowed.

  • Allows optometrists to order more tests. Right now, optometrist are limited to ordering of smears, cultures, sensitivities, complete blood count, mycobacterial culture, acid fast stain, urinalysis, tear fluid analysis. This bill gets rid of this list.

  • Allows CLIA waived testing for systemic conditions you need to rule out – not just conditions of the eye. Also allows optometrists to perform CLIA waived COVID-19 testing.

  • Allows certified optometrists to administer COVID-19 immunizations.

  • Removes the restriction on use of a scalpel to remove a foreign body.

  • Allows intense pulsed light (IPL) and low-level light therapy.

  • Allows use of intranasal stimulator and intracanalicular stents.

  • There will be a new medication on the market soon (iVeena) that optometrists will be allowed to use to do “medication only” corneal crosslinking.


  • Optometrists that prescribe a nonantibiotic oral prescription medication for a patient under five years of age must get documented, prior consultation with an appropriate physician and surgeon.

  • The following classes of agents are excluded from the practice of optometry unless they have an explicit United States Food and Drug Administration-approved indication for treatment of a condition or disease authorized under this section: Antiamoebics; Antineoplastics; Coagulation modulators; Hormone modulators; Immunomodulators.

  • Performing surgery is excluded from the practice of optometry. “Surgery” means any act in which human tissue is cut, altered, or otherwise infiltrated by any means. It does not mean an act that solely involves the administration or prescribing of a topical or oral therapeutic pharmaceutical. (Allowed procedures are exempted from this definition.)

Ophthalmic/Optometric Assistants

  • Current law that applies to both medical and optometric assistants and prohibits them from performing subjective refraction. We know that many ODs and most OMDs are allowing assistants to do this and violating the law.

  • This bill allows assistants to perform subjective refraction procedures but not write prescriptions. We included this in AB 407 to better regulate what medical assistants are doing, especially in some retail clinics.

  • AB 407 adds a requirement for training – 45 hours of documented training is required for assistants seeking to perform subjective refraction.

  • AB 407 requires direct supervision: the optometrist or ophthalmologist to be physically present and immediately available in the facility or office in which the preliminary subjective refraction procedures are performed. It would prevent assistants performing subjective refraction by telemedicine.

  • AB 407 adds a supervisory ratio of no more than three assistants per supervising ophthalmologist or optometrist during the supervisor’s work shift.

  • These provisions will be problematic for certain retail chains but good for patients. This would prevent chain optometry stores from hiring one OMD to supervise 20 medical assistants in remote locations doing subjective refraction.

Future Legislation

  • Lasers, lesion removal, and injections are vital for the future of the profession. We plan to introduce this authority in another bill in the future.

  • We also plan to seek legislation in the future to expand the types of immunizations that certified optometrists can administer.

Please contact Kristine Shultz, COA’s executive director at if you have any questions.