Consultation responses

The College regularly responds to consultations from both sector and government organisations.

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We take the lead on influencing the agenda of policy makers to ensure that optometrists' skills are valued and used in designing eye care services, and we regularly contribute and comment on policy relevant to our members. Here are our most recent consultation responses:

 

All-Party Parliamentary Group on Eye Health and Visual Impairment - Inquiry into capacity problems in NHS eye care services and avoidable sight loss in England

The inquiry will look at how the commissioning and planning of eye health services, from the national to local level, can be improved to ensure that capacity will meet demand for eye health services to prevent avoidable sight loss. The APPG will consider the evidence to produce a report with a clear set of practical recommendations, and showcase best practice from eye health and other areas of healthcare for those with responsibility for eye health commissioning and planning both nationally and locally, on how to ensure there is strategic and joined-up service delivery, and that can deliver capacity to meet existing and projected future increases in demand to prevent avoidable sight loss at national and local level.

 

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Department for Business, Energy and Industrial Strategy – Call for evidence: Laser pointers

The Department for Business, Energy and Industrial Strategy seeks evidence on the market for laser pointers, and how they are used, to fully understand what impact any measures might have on businesses, enforcement bodies and the general public. The Government is concerned that, in recent years, there have been an increased number of reported incidents of the deliberate misuse of laser pointers with consequences which could have been fatal – examples include shining laser beams into the cockpits of aircraft and young children suffering permanent eye damage as the result of having beams from ‘toy’ pointers shone directly into their eyes. The Department for Business, Energy and Industrial Strategy is considering whether further measures, for example restrictions on advertising, greater awareness raising, and introducing controls relating to the supply, ownership and/or use of laser pointers would help tackle the problem.

 

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Driver and Vehicle Licensing Agency - The Motor Vehicles (Driving Licences) Regulations 2013 (SI No 258)

The Driver and Vehicle Licensing Agency (DVLA) seeks views on their review of the Motor Vehicles (Driving Licences) Regulations 2013 (SI No 258) in relation to eyesight and driving. These regulations amended the minimum vision standards for driving in the UK. The College of Optometrists recommended that:

  • All drivers aged 17-59 have a vision check every five years
  • All drivers aged 60 and over have a vision check every two years
  • All drivers aged 70 and over should have a mandatory sight test upon renewal of their driving licence

 

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General Optical Council - Fitness to practise complaints strategy: policy for consensual disposal of cases

The GOC seeks views on a proposed change of policy to introduce a process for the consensual disposal of fitness to practise cases. Consensual disposal is a case management tool that will be used by the GOC to identify and process cases which may be suitable for concluding without a contested hearing. The GOC will not seek to dispose of a case by consent unless they are satisfied that to do so will not adversely affect public protection or be detrimental to the wider public interest.

 

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General Optical Council – Accreditation of Prior Learning policy

This GOC seeks views on its draft Accreditation of Prior Learning (APL) policy. The purpose of this policy is to outline the circumstances in which GOC-approved education providers can implement APL arrangements on an individual basis or part of a general group arrangement. APL is a process that allows individuals to be recognised for the skills and knowledge they have gained through previous learning. APL arrangements are used by education providers to determine whether training and assessment can be waived for an individual on entry to a course and is generally considered on an individual basis

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NICE consultation on age-related macular degeneration

This guideline covers diagnosing and managing age-related macular degeneration (AMD) in adults aged 18 and over. It aims to optimise service organisation and identification of risk factors, and improve diagnosis, management and review of this condition. It also aims to improve support and availability of information for people with AMD. The College’s response mainly highlights the important role optometrists play in the detection and management of AMD.

 

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London Assembly Health Committee eye health consultation

The London Assembly Health Committee seeks views and information on eye health and preventing sight loss in London to examine how to reduce health inequalities among Londoners. Regular sight testing and early detection of eye conditions can prevent sight loss. There are significant health inequalities in relation to access to eye screening, eye health advice and treatment services in London. Take up of regular eye screening in London is low, particularly for some at-risk groups. The Mayor has a duty to produce a strategy to promote the reduction of these inequalities. Access to appropriate prevention, diagnostic and treatment support for eye health in London is currently variable both geographically and across socio-economic boundaries and demographic boundaries. Eye health and sight loss are also affected by a number of lifestyle factors. The Mayor’s election manifesto included specific pledges to support Londoners to adopt healthier lifestyles.

 

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NICE consultation on Glaucoma

NICE seeks the views on its recommendations to address uncertainty and variation in clinical practice by giving clear recommendations on testing for chronic open angle glaucoma and ocular hypertension, and on effective diagnosis, treatment and reassessment to stop these conditions progressing. The College's response highlights five areas which we consider as having the potential to improve the quality of care:

  1. The tests required before referral should be commissioned as an extended community service
  2. The NICE recommendation to provide results of all examinations and tests with the referral should be also commissioned as an extended community service as this is outside the GOS contract.
  3. Repeats measures are not mandated within the GOS contract and would need to be commissioned as an extended community service.
  4. The diagnosis of chronic open angle glaucoma could be made by a suitably qualified health care professional with the relevant experience.
  5. The recommendations for a specialist qualification (according to case complexity) should be considered to apply equally to those healthcare professionals working within a consultant-led service and those working independently of consultant ophthalmologist supervision.

 

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NICE draft scope consultation - Dementia (update)

This consultation seeks views on the Guideline scope on Dementia: supporting people with dementia and their carers in health and social care. This guideline will update the NICE guideline on Dementia (CG42). We mainly recommended to NICE to include sensory impairments throughout this guideline as these factors are often overlooked.

 

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NICE cataracts in adults guidance consultation

NICE seeks the views on its recommendations to improve care before, during and after cataract surgery by optimising service organisation, referral and surgical management, and reducing complications. The College's response highlights four areas which we consider as having the potential to improve the quality of care:

  1. To commission the pre-referral decision for cataract surgery as an extended community service
  2. To commission the postoperative assessment – which is also outside the GOS contract – as an extended community service
  3. To include positive visual and refractive outcomes after a cataract surgery into the guidelines
  4. To identify who is accountable for patients if they have been discharged for follow-up cataract surgery in the community

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NICE Quality Standard Topic Overview - Black, Asian and other minority ethnic groups: promoting health and preventing premature mortality

NICE is consulting on the topic overview for the Black, Asian and other minority ethnic groups: promoting health and preventing premature mortality. This quality standard will be relevant in all age groups and all settings. The College highlighted the evidence of the higher prevalence of eye disease in the non-white population of the UK, and the important role optometrists have in raising awareness of eye health and encouraging uptake in minority populations.

 

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General Optical Council - Equality, diversity and inclusion scheme

The General Optical Council (GOC) has launched a consultation seeking feedback on its proposed Equality, Diversity and Inclusion (EDI) Scheme, which is designed to ensure these principles are embedded throughout its work. The scheme includes proposals to ensure fair access to GOC services; to ensure that all staff, registrants, Council and committee members are adequately trained and informed of their duties in respect of equality, diversity and inclusion; and to gather more data to better understand the makeup of the optical professions.

 

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Optical Confederation consultation on refractive surgery

The Optical Confederation has launched a consultation on new standards to promote best practice in the refractive surgery sector. The standards follow the adoption of the General Medical Council’s Guidance for doctors who offer cosmetic interventions, and give a framework for how this can be implemented in the refractive surgery sector.

 

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Welsh Government - Together for a dementia friendly Wales 2017-22

The Welsh Government seeks views on developing and implementing a national dementia strategy for 2017 – 2022. The consultation focuses on the key themes and actions to be included in the strategy, the services available for people living with dementia, and the evidence of existing good practice.

 

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GOC's education review: Call for evidence

This consultation sought the views of a wide range of stakeholders on the plans for an education strategic review to ensure that education programmes and qualifications leading to GOC registration equip students to meet patients' future needs. The consultation was set in the context of rapid technological change and the increased prevalence of enhanced services, which are altering the roles that optometrist and dispensing opticians play in delivering eye care. 

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GOC Strategic Plan 2017-2020

This consultation sought the view of a wide range of stakeholders about the GOC’s draft strategic plan which aimed to ensure opticians were equipped for the roles of the future, that its regulation was targeted at the risks to the public’s health and safety and that it developed into an organisation that the public, registrants and all its stakeholders found accessible in engagement and increasingly easy to work with.

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GOC supplementary guidance on the duty of candour

The aim of the guidance is to give GOC registrants further support and clarity on the principles set out in the GOC's Standards of Practice for Optometrists and Dispensing Opticians and Standards for Optical Students. This standard places an explicit duty on GOC registrants to be open and honest with patients when things go wrong.

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GOC supplementary guidance on consent

The aim of the guidance is to give GOC registrants further support and clarity on the principles set out in the GOC's "Standards of Practice for Optometrists and Dispensing Opticians" and "Standards for Optical Students". Patients have a basic right to be involved in decisions about their healthcare and agree or consent to any examination or treatment that is proposed by their healthcare professional.

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Consultation response on changes to HSCIC statistics 2016-17 and 2018 -19

The HSCIC publishes around 90 series of Official Statistics and National Statistics each year. Use of health and care statistics helps those involved to manage the system more effectively, commission better services, understand public health trends in more detail, develop new treatments and monitor the safety and effectiveness of care providers. The HSCIC is proposing a series of changes over the next three years which will help to better prioritise resources and to better meet the needs of users.

Download our response 

 

 

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Refractive surgery standards consultation

The Royal College of Ophthalmologists has been working with some of the UK's leading refractive surgeons, RCOphth Council members and patient and optometry representation to develop improved standards for the practice of refractive surgery in the UK. This is in response to the Keogh Report.

Download our response 

 

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Standards for virtual clinics in glaucoma care in the NHS eye hospital service

In order to cope with the increasing demands of glaucoma care on outpatient services, a number of hospitals have started to introduce virtual clinics as a way of increasing outpatient capacity. However, there are no national guidelines for the development of such services. NIHR has developed a draft document defining standards for virtual clinics in the secondary care setting.

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HCPC Consultation on the sale, supply and administration of medicines via exemptions for orthoptists

NHS England, with the four country governments, has proposed amendments to the Human Medicines Regulations 2012 legislation to enable appropriately-trained orthoptists to sell, supply and administer certain prescription-only medicines on their own initiative as part of their practice. Currently, orthoptists are not able to prescribe medicines for patients in the way that doctors, dentists and some other qualified health professionals can, although they may supply or administer medicines without a prescription in some cases. The consultation document suggests to set standards for the use of exemptions by orthoptists; annotate the Register entries of orthoptists who are qualified to use the exemptions; and approve post-registration programmes delivering relevant training.

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NHS England policy guidance on whistle blowing

NHS England has drafted whistleblowing policy guidance specifically for primary care. The intention is that the guidance should be used by primary care organisations to review their policies and procedures on staff raising concerns about safety. The policy sets out: - who can raise a concern - the process for raising a concern - how the concern will be investigated - what will be done with the findings of the investigation. From 1 April 2016, NHS England is a prescribed person under the Public Interest Disclosure Order 1999, meaning primary care service staff working at GP surgeries, opticians, pharmacies and dental practices, can raise concerns about inappropriate activity directly.

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Welsh Government - school pupil eye care service for Wales

The College supports the Welsh Government proposal to develop, implement and deliver an ophthalmic service in special schools across Wales. The proposed special schools service will deliver eye health care services for pupils attending maintained special schools. Services will be offered to pupils who are learning in a special school setting, in line with the education definition of a special school. It will form a new part of the existing primary care Wales Eye Care Services. It is proposed that Special School Ophthalmic teams, consisting of optometrists, orthoptists and dispensing opticians will provide the service to pupils within the school setting during the school day.

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A competency framework for all prescribers

The single competency framework for prescribers was originally published by the National Prescribing Centre/NICE in 2012. The single framework consolidated all previous competency frameworks developed to support independent and supplementary prescribers. This is an update of an existing competency framework which is already widely used in practice.

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GOC hearings guidance and indicative sanctions consultation

The aim of this document is to assist all individuals when sitting on the Fitness to Practise Committee to understand their individual and collective responsibilities, leading to the making of fair and just decisions. The professional and lay personnel appointed to sit on the Committee exercise their own judgments in making decisions, but must also take into consideration the standards of good practice the General Optical Council has established.

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NICE topic engagement- improving health and wellbeing

NICE seeks the views on key areas for quality improvement to be covered by this quality standard. The College's response highlights three areas which we consider as having the greatest potential to improve the quality of care:

  1. Increase in counselling services about the effect of smoking on Age-related Macular Degeneration (AMD) and cataracts
  2. Increase in visual assessment as part of falls prevention assessments
  3. Improvement of visual assessment services tailored to people with dementia.

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Consultation on the Government's mandate to NHS England to 2020

This consultation sets out, at a high level, how the Government proposes to set the mandate to NHS England to 2020. The College's response highlights why it is important to specifically include eye care services within the mandate. Positive change in eye care services is essential if the aims of the mandate are to be achieved.

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GOC voluntary code of practice for online supply of contact lenses

The GOC seeks the views on a voluntary code of practice for online contact lens suppliers to make it safer for people to buy contact lenses online. The College of Optometrists supports the code of conduct, provided that compliance is strictly monitored.

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UK National Screening Committee recommendation on Diabetic Retinopathy screening

The UK National Screening Committee is consulting on whether the interval between screening tests within the Diabetic Eye Screening Programme should be changed for some people. The Committee's proposal is that in people at low risk of sight loss, the interval between screening tests should be changed from one year to two years; in people at high risk of sight loss, the current one year interval between screening tests should remain unchanged. The College agrees with this modification.

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UK National Screening Committee - Screening for glaucoma

This consultation seeks the views on the UK National Screening Committee's draft report on screening for glaucoma. The Committee recommends that screening should not be offered. The College's response highlights the important role community optometrists have in opportunistic case finding for glaucoma. The lack of evidence surrounding the benefit of a screening programme should not detract from the important work done by community optometrists in opportunistic case finding for glaucoma which is in its early stages - asymptomatic.

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