Written evidence from the Optical Confederation
(COM 83)
1. INTRODUCTION
1.1 The Optical Confederation represents
the 12,000 optometrists, the 6,000 dispensing opticians and 7,000
optical businesses in the UK who provide high quality and accessible
eye care services to the whole population. The Confederation is
a coalition of the five optical representative bodies: the Association
of British Dispensing Opticians (ABDO); the Association of Contact
Lens Manufacturers (ACLM); the Association of Optometrists (AOP);
the Federation of Manufacturing Opticians (FMO) and the Federation
of Ophthalmic and Dispensing Opticians (FODO). The Optical Confederation
welcomes this opportunity to submit evidence to the inquiry on
commissioning.
2. CLINICAL ENGAGEMENT
IN COMMISSIONING
2.1 We welcome the commitment in the White
Paper that GP commissioning consortia will engage with "the
full range of other health and care professionals" in the
commissioning process. We also welcome the specific references
to commissioning community eye care services and we hope that
this is a long overdue recognition of the effective role of the
community optical practices in delivering high quality, accessible
services as well as delivering significant cost savings for the
NHS and social care.
2.2 Engagement with the optical sector at
a national, regional and local level through the national professional
and representative bodies, and Local Optical Committees will be
essential to delivering the Government's agenda. To ensure nationwide
joined-up decision making and multidisciplinary involvement, clinical
engagement in GP commissioning should be designed into this new
system, and not added as an afterthought.
2.3 Community optometry has a great deal
of expertise in meeting the needs of their patients, from the
clinical, customer satisfaction and commercial points of view.
The highly competitive, open market in which optical practices
operate delivers high levels of quality, access and choice to
all patients, including housebound patients. The money genuinely
follows the patient and practices compete for patients; if not,
they go out of business and others move in to take their place.
This expertise and understanding of patients' needs should be
better utilised and community optometry can make a valuable contribution
to those commissioning services.
2.4 We would propose that GP Consortia be
encouraged to establish multi-professional stakeholder groups,
possibly analogous to the old multi-disciplinary PECs. We have
found these to be effective models of engagement and service improvement
especially where community optometric expertise has direct membership
of such boards or committees. If GP Consortia are developing such
professional stakeholder groups to inform their commissioning,
we would argue strongly that optometrists and dispensing opticians
nominated by the Local Optical Committee should be included.
3. HOW OPEN
WILL THE
SYSTEM BE
TO NEW
ENTRANTS?
3.1 GP consortia should be very clear to
potential bidders about the health need they are aiming to meet,
any constraints that they foresee in the delivery of the services.
They should also ensure the bidding process is not overly and
unnecessarily complex so that particular groups are not excluded
from bidding. GP consortia should also be flexible in enabling
local bidders to work in new and innovative ways to deliver care
models to meet the needs of the consortium has identified.
3.2 For example we do not believe it would
be effective to simply transfer the necessarily more complex requirements
for hospital services onto community optical practices where these
requirements are neither necessary, desirable or cost-effectively
attainable.
4. ACCOUNTABILITY
FOR COMMISSIONING
DECISIONS
4.1 We support the role of local authorities
in promoting the joining up of local NHS services, social care
and health improvement, to strengthen democratic legitimacy at
a local level. We do however believe there still needs to be greater
clarification around where accountability will lie in the new
system and how this may be challenged by patients, the public
and local partners.
4.2 Representation from the Local Optical
Committee on the local Health and Wellbeing Board would help to
ensure democratic support from the eye care community but nevertheless,
in our view, there needs to be some vehicle for challenge and
appeal for the public.
4.3 The role of the NHS Commissioning Board
should include making specific recommendations to GP consortia,
where there is a substantial financial and clinical benefit to
patients and the NHS in rolling out services, for example, national
availability of the successfully piloted enhanced eye care services
in community optical practices, as has been argued and recommended
by the Bosanquet Report, Liberating the NHS: Eye Care (2010).[149]
5. INTEGRATION
OF HEALTH
AND SOCIAL
CARE
5.1 In eye care, low vision services provide
a good example of where there is a need for joint needs assessment
and joint commissioning. Low vision services are currently the
Cinderella of Cinderella services and are significantly underprovided.
Requiring GP consortia to have a duty to work with other professionals
in the NHS and social care, will promote better integration. For
low vision services GP consortia need to work closely with Local
Optical Committees, to ensure the health and social care needs
of patients with low vision, visual impairment and blindness are
effectively met.
6. WHAT WILL
BE THE
ROLE OF
LOCAL AUTHORITIES
IN PUBLIC
HEALTH AND
COMMISSIONING DECISIONS?
6.1 We support the role of local authorities
"leading on local health improvement and prevention strategy."
In eye care early detection and treatment are crucial to prevent
visual impairment and blindness, as well as reducing significant
downstream costs for both the NHS and social care services. 50%
of blindness is preventable through regular sight tests and screening
programmes. A far greater role can be played by both the NHS and
local authorities in partnership with local optical committees,
to target those most at risk in local communities, such as BME
groups and older people, and to reduce this high level of avoidable
sight loss. Eye care should also be specifically included in local
Joint Strategic Needs Assessments.
7. TRANSITIONAL
ARRANGEMENTS
7.1 We welcome the Government's specific
commitment to work with the NHS and professional bodies during
the transitional period. The optical professional and representative
bodies are keen to be part of this process.
7.2 Innovation in the transitional period
should be driven by engagement with stakeholders and by listening
to new and innovative solutions to improve care for patients while
making cost savings for reinvestment. The Bosanquet Report (2010)
outlines how eye care can be a lead area to deliver more community
eye care (even during this transitional period), while being cost-effective
and freeing hospital eye care capacity to focus on those facing
acute or chronic sight loss. Patients would also benefit from
quicker access to eye care services, and with greater choice and
more services delivered in the community. Eye care can be the
exemplar service of how to drive innovation during the transitional
period.
October 2010
149 Bosanquet, N (2010) Liberating the NHS: Eye
Care: Making a Reality of Equity and Excellence Back
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