30 November 2021

We respond to DVLA's proposals to allow optometrists to complete DVLA medical questionnaires

The College responds to DVLA's consultation on amending the Road Traffic Act 1988 to allow registered healthcare professionals to complete DVLA medical questionnaires.

Summary

The College has submitted a consultation response to the DVLA on its proposals to allow optometrists (and other healthcare professionals) to complete DVLA medical questionnaires for their patients. We believe that this proposal is a very positive step forward in acknowledging the expertise of optometrists, and will reduce the burden on GPs and secondary care doctors, as well as benefiting patients in their administrative dealings with the DVLA.

Our response

Q5. To what extent do you agree or disagree with the principal intention of the proposal?

Strongly agree

Q5a. If you agree with the principal intention of amending the existing legislation, please explain your reasons why:

Optometrists are health professionals who are qualified to examine the eyes to detect defects in vision, signs of injury, ocular diseases or abnormality and problems with general health, such as high blood pressure or diabetes. They work across both primary and secondary care, in community and domiciliary settings, and in academia and research.

Within primary care, optometrists make a health assessment, offer clinical advice and treatment recommendations, prescribe spectacles or contact lenses and refer patients for further treatment, when necessary. Optometrists can treat a range of eye conditions, and can manage and provide care for cataract patients (pre and post treatment) as well as managing conditions such as glaucoma in the community. Some optometrists also have further qualifications enabling them to prescribe medicines for eye conditions and provide an advanced level of eye care.

In addition, many optometrists work within secondary care alongside ophthalmologists and other healthcare professionals as part of large teams of eye specialists. Optometrists in these settings will be involved in more specialised areas of optometry, such as treating and managing patients with glaucoma and macular degeneration.

As such, optometrists are key healthcare professionals for identifying vision defects and assessing if a person meets the DVLA standards of vision for driving.

We believe that this proposal is a very positive step forward in acknowledging the expertise of optometrists and other healthcare professionals. Widening the scope of healthcare professionals who can complete these questionnaires will recognise the important role of all practitioners in clinical care, and will reduce the burden on GPs and secondary care doctors. Furthermore, it is likely to benefit patients in their administrative dealings with the DVLA.

Q6. To what extent do you agree or disagree:

Q6a. That the proposal meets the preconditions for use of a Legislative Reform Order as set out in Section 7 - The Legislative Reform Order Process

See below response to Q6c

Q6b. That if the proposal is implemented, the impact of that would provide greater flexibility and opportunity to General Practice Surgeries and hospital teams completing medical questionnaires. This would allow the GP surgery or hospital team to determine who would be the most appropriate healthcare professional to provide the DVLA with medical information and allow quicker licensing decisions for some customers.  

Agree.

Q6c. If you agree that the proposal meets the preconditions for use of a Legislative Reform Order, please explain your reasons why:

As stated in Section 7.2 and 7.3 of the consultation document: 

An LRO is a statutory instrument which can be used to amend primary legislation to remove or reduce a burden to which any person is subject because of any legislation and/or ensure regulatory functions comply with better regulation principles. This consultation is being conducted in accordance with the provisions of section 13 of the LRRA.

Whilst The College of Optometrists is not in a position to comment on the formal administrative process for amending the legislation, we cannot see any reason why the proposed suggestion is not appropriate in this case.

Q6e. If you agree that this would provide greater flexibility and opportunity to General Practice Surgeries/hospital teams completing medical questionnaires, please explain your reasons why:

We are encouraged that the DVLA and the Department of Health and Social Care acknowledge a shift in perception around provision of medical evidence for certifications, and that there is growing recognition that in some cases the most appropriate professional for this work might not always be the GP or another medical doctor. Indeed, in some instances, a patient’s GP may not actually have any involvement in the individual patient’s eye care. 

It is therefore welcome that GP surgeries/hospital teams will have the opportunity to refer the medical questionnaires on to other healthcare professionals (see Q7 response).

Q7. How else might this proposal impact on GP business practices/hospital team practices and efficiency?

In many cases, optometrists will be best-placed – alongside ophthalmologists - to complete a patient’s medical questionnaire with respect to the vision standards. We would like to see specific guidance developed on how an optometrist should be involved in the process; particularly with regards to procedures for GP surgeries and hospital teams making a referral to an optometrist in primary or secondary care.

We note that the language used in the consultation document and questions refers to “increasing the scope of those within surgeries and hospitals who can provide the information”. 

It is important to note that the majority of optometrists are based in primary care settings, and it is these optometrists who are directly involved in the day-to-day care of patients with eye conditions. It is therefore important that GP practices and hospital teams are able to refer the questionnaires to primary care optometrists or specialist optometrists working within the Hospital Eye Service, as appropriate.

Q8. To what extent do you agree or disagree that the proposal will help reduce bureaucracy in the NHS Service and GP Surgeries?

Agree.

Q8a. If you agree that the proposal will help reduce bureaucracy in the NHS Service and GP Surgeries, please explain your reasons why:

Although we agree that this proposal would reduce bureaucracy in the NHS Service and GP surgeries, there is a risk that it will simply move the bureaucratic burden to other parts of the healthcare system e.g. optometrists.

This change is likely to lead to an increased administrative burden on optometrists in completing the questionnaires. More clarity is needed on the process for appropriately reimbursing for optometrists’ time and expertise. 

It would also be useful to understand if the DVLA will adopt a system whereby health professionals have the option of opting-in or opting-out of the new proposals, i.e. whether a health professional could decline to fill out the questionnaire, if for example their time was not being reimbursed (or not reimbursed sufficiently).

Furthermore, we think it is important that an optometrist is only requested to complete and sign the medical questionnaires if they are directly involved in that particular patient’s care.

Q9. To what extent do you agree or disagree with the following statements:

Q9a. The proposal will improve efficiency for and GP Surgeries and hospital teams

Strongly agree.

Q9b. The proposal will improve efficiency for the DVLA

Strongly agree.

Q9c. If you agree that the proposal will improve efficiency for GP Surgeries/hospital teams, please explain your reasons why:

Widening the scope of healthcare professionals who can complete these questionnaires will recognise the important role of all practitioners in clinical care, and will reduce the burden on secondary care doctors and GPs, freeing them up to focus on other duties. In many cases, GPs already currently need to request the required information from another healthcare practitioner (e.g. the patient’s optometrist), and so it makes sense for the healthcare professional who has direct knowledge of the patient’s circumstances to complete the forms. 

However, it should be noted (as in question 8a), that any administrative burden may simply be passed on to optometrists and other healthcare professionals.

Q9e. If you agree that the proposal will improve the efficiency for the DVLA please explain your reasons why:

We would anticipate that the medical questionnaire forms would be completed more quickly and submitted to the DVLA more promptly, if other healthcare professionals who have direct knowledge of a patient’s care are permitted to complete them. This would therefore allow the DVLA to process questionnaires faster. It would also allow the DVLA to contact the patient’s optometrist directly, should there be any additional or follow-up questions or advice needed – saving time for the DVLA, and possibly reducing an administrative burden on a GP surgery who would otherwise act as a “go-between”.

Q10. If you are aware of any benefits or costs to businesses that have not been identified, please provide details below:

As per question 8a: This change is likely to lead to an increased administrative burden on optometrists in completing the questionnaires, and so we would like to understand more about the process for appropriately reimbursing for time and expertise.

Q12. If you are aware of, or you believe that there will be any unintended consequences as a result of this proposal, please provide details below:

As per question 8a: Although we agree that this proposal will reduce bureaucracy in GP surgeries and Hospital Eye Services, there is a risk that it will simply move the burden to other parts of the healthcare system. Optometrists, along with other healthcare professionals, are also managing the backlog of patients resulting from the pandemic and, as noted in question 8a, it may be necessary to clarify whether optometrists can ‘opt-out’ of having to complete questionnaires should they be unable to take on the responsibility at that time.

Q22. Based on the cost of doctor's time when completing DVLA medical questionnaires, would there be any indirect cost benefit to practises/hospital teams if other healthcare professionals were able to complete the questionnaires?

Yes.

Q22a. If Yes, please state the role of the person who will be completing the questionnaire and the reason for the cost benefit:

The indirect cost benefit would be to free up capacity in GP practices and hospitals to provide direct care for their patients rather than completing forms. However, this resource benefit would have to be balanced against the resource costs required for optometrists and other health professionals to complete the questionnaires.

Related further reading

Guidance on current visual acuity standards for driving in the UK and advising patients on their fitness to drive.

Given that optometrists have a key role in ensuring their patients drive with their glasses, it is important to understand why patients choose not to drive with their best vision. This article provides a summary of a study addressing this key issue.

This article describes a retrospective study examining factors associated with vision and health that contribute to road injury collisions.