Consultation on the proposed National Tariff Payment System

Thank you for the opportunity to comment on the 2020/21 National Tariff Payment System. While we will not answer the specific questions included in the consultation document, we would like to emphasise the following key points:

• The College of Optometrists welcomes the priority given to ophthalmology to improve patient care and efficiency from changing the way ophthalmology services are delivered and paid for across primary and secondary care.
   
• We strongly support the move towards a blended payment system centred around the journey of patients through the system. It will better reflect demands and costs and has the potential to support the objective of the NHS Long-Term Plan. But it will also require a constructive dialogue between all health and care professionals involved throughout relevant pathways rather than just a volume and cost discussion. This dialogue would require a careful and realistic assessment of clinical needs and risks. It should also ensure that optometrists working in primary and community care are funded for the follow up and enhanced services we know will contribute to improving capacity and reducing avoidable referrals in secondary eye care.
   
• The College welcomes the suggestion to remove the current outpatient front loading policy from published prices. NHS Ophthalmology services arepredominantly out-patient-based for patients with long-term eye conditions that require ongoing activity review and management. We have long asked for the front loading policy to be abandoned. We would welcome such a move as an indicator of a fair payment structure and one that truly reflects clinical need and risk.
   
• The proposed blended payment approach (placing more emphasis on system planning and working and less emphasis on individual units of activity delivered by consultations in a face-to-face setting) effectively encourages and supports innovation, efficiency and quality of patient care. It rightly supports the development of new models of eye care based on clinical risk stratification and clinical competencies and the appropriate application of technological advances to deliver services.
   
• The College actively supports the drive for more efficient models of delivery of outpatient follow-up activity, including transfer of care to primary and community providers. As part of the Clinical Council for Eye Health Commissioning (CCEHC), we have already developed a System and Assurance Framework for Eye Health to reduce avoidable referrals to the hospital eye service and to encourage more step-down care in the community. We support the discharge of appropriate patients to local community ophthalmology and primary eye care services, but a sea-change in commissioning thinking is needed at ICS level, combined with workforce development and an IT connectivity solution, to do this safely at the scale required within the timescale of this tariff.
   
• In the interests of patient safety, these proposed changes to ophthalmology tariffs should be accompanied by the necessary support for service redesign to rightly address the current capacity pressures in the hospital eye service and reduce the risk of sight loss due to delayed follow-ups in patients with long-term and high-risk eye disease. These patients may have no prospect of a cure and many will have serious sight-threatening conditions which mean that ongoing management is essential.

Submitted: January 2020