9 March 2021

All Wales Therapeutics and Toxicology Centre consultation

The College responded to a consultation from the All Wales Therapeutics and Toxicology Centre.

The All Wales Therapeutics and Toxicology Centre (AWTTC) is consulting on their “Medicines Optimisation Framework” aimed at providing increased clarity of their processes behind the development of medicines optimisation resources. The College responded as follows: 

General comment

We are supportive of this document which we believe is very sound, proportionate and well structured, but it should be inclusive of all prescribing professions, including the optometric profession.

Page 10/section 2.1/line 293

Some resources may be required at a local level to help improve local patient or specific population outcomes, particularly for patients living in remote locations with limited access to healthcare; and thus may not apply at national “All Wales” level.

For example, resources designed to help Independent Prescribing Optometrists may need to be tailored to support optimisation of medicines remotely, via video/telephone review – this is pertinent in light of the changes brought about by the pandemic. Otherwise, a local solution/resource which would benefit such patients at local but not national level may be overlooked by the AWTCC.

Page 11/section 2.1/line 295

We would suggest to include the criteria of what constitutes a robust and current evidence base; and what standard or framework is or should be applied to critically appraise the evidence.

Page 13/section 3.3/line 380

The framework for non-medical prescribing differs with respect to each healthcare profession, and whether or not a medicine can be prescribed off label varies accordingly (Human Medicines Regulations 2012).

In optometry, off label prescribing is possible but is limited – controlled drugs, unlicensed and those for parenteral administration are not currently allowed to be prescribed.

Therefore, we would recommend including optometry representatives (IP optometrists) to the consultation process for developing new medicines optimisation resources.

Page 17/section 5.1.3/line 546

In optometry, practitioners will have differing skill-sets with respect to qualifications and the range of medicines they are able to prescribe – it is important to target and consult with relevant groups within a profession.

Independent Prescribers are able to prescribe a wider range of medicines and develop complete management plan independent of other healthcare professionals and thus be in better position to provide insight on the optimisation of medicines.

Therefore, we would recommend including optometry representatives (IP optometrists) to the consultation process for developing new medicines optimisation resources.

Page 32/Appendix 3list/line 1013

We suggest including optometry as a prescribing professions to the list of AWPAG voting members.

Other comments related to AWTTC’s and AWMSG’s medicines optimisation work

There is a growing number of independent prescribing (IP) optometrists that are providing a significant amount of high quality and effective eye care at primary care level that not only reduces referrals and opens hospital eye service capacity; but allows faster and improved patient access to medicines to treat their eye condition, particularly for remote populations, and reducing the administrative burden required to arrange appointments with other healthcare professionals (i.e. GP to obtain prescription). Recent evidence includes: Optometry scheme leads to reduction in hospital referrals - Cwm Taf Morgannwg University Health Board. We envisage such schemes to become more widespread and as such IP optometrists specifically should be consulted on resources to optimise medicine usage within optometry and eye care in general.


Submitted: March 2021

Related further reading

Jane Veys MCOptom on reducing the tears and fears of our patients

It has been over 15 years since prescribing rights were granted to optometrists, writes Dr Paramdeep Bilkhu MCOptom, Clinical Adviser for the College. How has this affected clinical practice and patient outcomes?