VISION 2020 (UK) Limited:
Registered Charity Number 1146746
VISION 2020 UK Learning Disabilities and Sight Loss Committee:
Possible Changes to GOC and DH Regulations.
Discussion Document.
Following discussions in the last meeting of the VISION 2020 UK Learning Disabilities and Sight Loss Committee this is the information about GOS (General Ophthalmic Services) and what would be advantageous to include in the future.
For People with Learning Disabilities (PWLD) the GOS Sight Test is funded by NHS England and is currently(fortunately) uncapped.
There are 2 issues here:
Entitlement to a GOS funded Sight Test.
We think it is appropriate that people who are 'classed' as learning disabled (maybe GP register, local LD register, other means?) are entitled to an NHS GOS Sight Test, based on their learning disability alone (for evidence use the 10 times more likely data in LD people etc.)
Restriction of spectacle dispensing to a qualified professional.
The current regulations state:
"Statutory regulation applies to the dispensing of spectacle
prescriptions of a kind that unqualified persons are not permitted by
law to dispense to children under 16 and patients who are registered as severely sight impaired or sight impaired (blind or partially
sighted) 2. Sales of spectacles to persons in these classes can only
be made by or under the supervision of a registered practitioner."
Therefore, spectacles can only be dispensed by qualified professionals
(Dispensing Opticians and Optometrists) to under 16s, SI certified
patients (registered partially-sighted, in old terms), SSI certified
patients (registered blind, in old terms). We think that PwLD should be added to this group (and potentially those with Dementia too).
David Hewlett (FODO and Optical Confederation) has suggested that we (as a VISION 2020 UK Committee) write formally (by email) to Mike George (chair) and Ann Blackmore (secretary) of OFNC (Optometric Fees Negotiating Committee).
OFNCnegotiates the NHS GOS Sight Test Fee value with the DoH every year.
We should ask whether OFNC would support this proposal, and then pursue with the DoH when occasion permits (i.e. the regulations are next updated).
Their emails are:
and
Once we agree the details, and have the approval of the VISION 2020 UK Learning Disabilities Committee Bruce will run the proposal past David Hewlett and LOCSU for their comments and approval before we send.
At the moment the NHS (GOS) will fund a Sight Test for certain groups
of people, at agreed intervals
(from
You're entitled if you're:
- aged 60 or over
- registered blind or partially sighted
- diagnosed with diabetes or glaucoma
- aged 40 or over and have a close relative (parent, sibling or
- child) with a history of glaucoma
- you have been advised by an ophthalmologist that you are at risk of glaucoma
You will also qualify for a free NHS sight test and be eligible for an optical voucher if you're:
- aged under 16, or under 19 and in qualifying full-time education
- eligible for an NHS complex lens voucher - see below
- a prisoner on leave from prison
- If you or your partner - including civil partner - receive, or you're
- under the age of 20 and the dependant of someone receiving:
- Income Support or Income-based Jobseeker's Allowance (not
- contribution based)
- Pension Credit Guarantee Credit
- Income-based Employment and Support Allowance
- Universal Credit and meet the criteria
If you're entitled to or named on:
- a valid NHS tax credit exemption certificate - if you don't have
- a certificate, you can show your award notice; you qualify if you get:
- Child Tax Credits, Working Tax Credits with a disability element (or
- both) and have income for tax credit purposes of £15,276 or less
- a valid NHS certificate for full help with health costs (HC2)
People named on an NHS certificate for partial help with health costs
(HC3) may also get help.
We will also need to stress the concept of 'protection' of PWLD regarding both the GOS funded S/T and the dispensing of spectacles.
Regulation of dispensing extends past spectacles to spectacle mounted low vision aids and complex low vision aids - as a GOC member we looked at this wording some years ago and it was concluded that these categories of appliance should be included although if you ask the GOC for any ruling on whether a certain type of LVA is included they always refer you to your professional association
for clarification!
Is approaching the OFNC the best (only) route?
Do they have the power to make policy as they are really concerned with setting fees for GOS services. Although you have mentioned vouchers I did not think we were looking for the granting of vouchers towards the cost of spectacles, simply the protection of GOS funded eye exams and regulated professional dispensing for a seriously vulnerable group of patients.
There is no doubt we need to get the GOC in on this as they would be the administrators and watchdogs for any transgressions, should the aims succeed. This is another reason why we need to stress the protection issue. We should also get the College of Optometrists officially on board for PWLD too.
I think ultimately PWLD have a clearer case for protection than patients with dementia as they are generally identifiable due to local registration or lists(?) and we should be able to fulfil the requirement for evidence from Seeability's numerous case histories - eg Sally who had glaucoma and ultimately lost most of her sight because her eye examination came too late or patients who appear introverted and sullen or frightened, simply because they could not see properly and had never had an eye exam. The eye exam and spectacles changed their lives.
Entitlement to a GOS funded Sight Test.
VISION 2020 UK is the umbrella organisation which leads collaboration and co-operation between organisations with an interest in eye health and sight loss. The VISION 2020 UK Learning Disabilities and Sight Loss Committee includes representatives from: LOCSU, the British and Irish Orthoptic Society, the Royal College of Ophthalmologists, SeeAbility, ABDO, College of Optometrists, Guide Dogs, RNIB, RNIB Scotland and the Royal College of GP’s.
We believe it is appropriate that people who are 'classed' as learning disabled are entitled to an NHS GOS Sight Test and Optical Voucher, based on their learning disability alone[1]
Restriction of spectacle dispensing to a qualified professional.
The current regulations state:
"1) Statutory regulation applies to the dispensing of spectacle
prescriptions of a kind that unqualified persons are not permitted by
law to dispense to children under 16 and patients who are registered as severely sight impaired or sight impaired (blind or partially
sighted).
2. Sales of spectacles to persons in these classes can only
be made by or under the direct supervision of a registered practitioner."
Therefore, spectacles can only be dispensed by qualified professionals
(Dispensing Opticians and Optometrists) to under 16s, SI certified
patients (registered partially-sighted, in old terms), SSI certified
patients (registered blind, in old terms). We believe that People with Learning Disabilities should be added to this group.
We are asking the OFNC to support this proposal.
We are also asking the Department of Health to support this proposal and update the regulations when this is next undertaken.
1
[1]Please see ‘The Estimated Prevalence of Visual Impairment among People with Learning Disabilities in the UK’ for further evidence.