Proposal 1: remove medicines that have been discontinued
The following medicines have been discontinued and are no longer available to be sold or supplied in the UK:
- emedastine
- levocabastine
- nedocromil sodium
- polymyxin B/bacitracin
- polymyxin B/trimethoprim
- sulphacetamide sodium
- thymoxamine hydrochloride
Do you agree or disagree with the proposal to remove these medicines from the HMRs on the basis that they have been discontinued and are no longer available to be sold or supplied in the UK?
Agree
We support the removal of these medicines as they have either been discontinued or are no longer manufactured for sale or supply in the UK market. They have been replaced with alternative medicines within the same or similar pharmacological mode of action and licensed indication. In many cases, the alternative medicines are shown to be more effective with good safety profiles meaning they have developed into first line therapeutic agents for a range of minor and self-limiting eye conditions.
Proposal 2: allow all optometrists to supply POMs currently restricted to AS optometrists
The following questions are about enabling optometrists to sell and supply specific POMs so that they can manage patients in the community and eliminate the need for unnecessary onward referral to other healthcare professionals.
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply acetylcysteine in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply atropine sulphate in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply homatropine hydrobromide in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply azelastine hydrocholoride in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply ketotifen in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply olopatadine in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply lodoxamide in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply sodium cromoglycate in preparations that are larger than 10ml in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply pilocarpine hydrochloride in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply pilocarpine nitrate in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply diclofenac sodium in an emergency?
Agree
We strongly support the inclusion of these medicines in the exemptions for all optometrists. They are used to manage many common, non-sight-threatening eye conditions such as dry eye, allergic eye disease and mild ocular trauma or infections – which can be safely and effectively treated in primary care. These are typically self-limiting and carry a low risk of complications. All optometrists are trained to understand pharmacology, indications, contraindications, interactions and cautions associated with therapeutic treatment with the existing exemptions, which are within the same or similar drug class as the proposed exemptions – but this restricted range limits flexibility and often necessitates unnecessary referral to obtain a suitable medicine. By extending the range of exempted medicines, patients benefit in terms of convenience, prevents unnecessary referral, enables efficient and optimal use of the optometrist workforce and increases capacity in GP and secondary care.
Proposal 3: allow CLOs to supply POMs currently restricted to AS optometrists
The following questions are about enabling CLOs to sell and supply specific POMs so that they can manage patients with allergic eye disease in the community and eliminate the need for unnecessary onward referral to other healthcare professionals.
Do you agree or disagree with the proposal to allow all CLOs to provide a signed order for, or directly sell and supply azelastine hydrocholoride in an emergency?
Agree
Do you agree or disagree with the proposal to allow all CLOs to provide a signed order for, or directly sell and supply ketotifen in an emergency?
Agree
Do you agree or disagree with the proposal to allow all CLOs to provide a signed order for, or directly sell and supply olopatadine in an emergency?
Agree
Proposal 4: allow optometrists to supply new POMs to treat conjunctivitis
The following questions are about enabling optometrists to sell and supply specific POMs so that they can manage patients in the community with forms of conjunctivitis and eliminate the need for unnecessary onward referral to other healthcare professionals.
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply azithromycin in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply gentamicin in an emergency?
Agree
Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply epinastine in an emergency?
Agree
Currently, only chloramphenicol is used rather than fusidic acid for bacterial infections. Both antibiotics have a small spectrum of activity against Gram positive species and the latter is considerably more expensive. This means those who are contraindicated for chloramphenicol (e.g. pregnant and breastfeeding women) or are contact lens wearers (typically Gram negative species implicated) are not able to access appropriate treatment without referral. This is particularly the case with contact lens wearers (3.6 million across the UK), where delay in treatment could lead to complications and increased risk of ocular morbidity (e.g. keratitis). Evidence indicates the need for an antibiotic from the aminoglycoside or fluoroquinolone drug classes. Thus, adding azithromycin provides a more cost-effective alternative to fusidic acid. Gentamicin is a more appropriate medicine for treating infections associated with Gram negative species (broad spectrum aminoglycoside). Epinastine provides an additional alternative where other anti-allergy medications are not suitable.
Proposal 5: allow CLOs to supply new POMs to treat conjunctivitis
The following questions are about enabling CLOs to sell and supply specific POMs so that they can manage patients in the community with forms of conjunctivitis and eliminate the need for unnecessary onward referral to other healthcare professionals.
Do you agree or disagree with the proposal that CLOs should be able to provide a signed order for or directly sell and supply gentamicin in an emergency?
Agree
Do you agree or disagree with the proposal that CLOs should be able to provide a signed order for or directly sell and supply epinastine in an emergency?
Agree
Proposal 6: allow wholesalers to supply specified topical anaesthetics to CLOs
This question is about enabling wholesalers to supply the following 3 topical anaesthetics to CLOs for use during the course of their professional practice:
- lidocaine hydrochloride
- oxybuprocaine hydrochloride
- proxymetacaine hydrochloride
Do you agree or disagree with the proposal to allow wholesale suppliers to supply CLOs with these 3 topical anaesthetics for use during the course of their professional practice?
Agree
Legal considerations
In considering the amendments to the HMRs, ministers must comply with the public sector equality duties. In Northern Ireland, new policies must also be screened under section 75 of the Northern Ireland Act 1998. In addition, new or revised policies must be rural proofed in line with the Rural Needs Act (Northern Ireland) 2016.
Protected characteristics under the Equality Act 2010 are:
- age
- disability
- gender reassignment
- marriage and civil partnership
- pregnancy and maternity
- race
- religion and belief
- sex
- sexual orientation
The Department of Health and Social Care (DHSC) and the Department of Health in Northern Ireland (DoH (NI)) do not consider that these policy proposals will create inequalities or adversely impact individuals with protected characteristics.
Do you agree or disagree with the view of DHSC and DoH (NI) on the impact these policy proposals will have on individuals with protected characteristics?
Disagree
We disagree with the DHSC and DoH (NI) that these proposals will not create inequalities or affect individuals with protected characteristics. While the proposed changes offer benefits such as improved access and reduced delays to care, without funding for signed orders the costs would fall on patients, disproportionately affecting those less able to pay, particularly lower socio-economic and minority groups, including those individuals with protected characteristics. Wales has started to address this through its signed-order proposal, which we recently responded to, but NHS coverage in the rest of the UK remains inconsistent. Where coverage exists, it is limited to existing exemptions, leaving many patients at a disadvantage. We therefore call for extended NHS coverage to include the newly exempt medicines and for this to be implemented consistently across the UK. This would ensure all patients can access these treatments fairly and equitably, regardless of location or ability to pay.
Question for respondents who live or work in Northern Ireland
DoH (NI) does not consider that these policy proposals will impact people differently with regard to where they live geographically in Northern Ireland.
Do you agree or disagree with the view of DoH (NI) about the impact these policy proposals will have on where people live geographically in Northern Ireland?
Disagree
Please see our response above.