Written evidence from the Optical Confederation
(CFI 25)
1. INTRODUCTION
1.1 The Optical Confederation represents the 12,000
optometrists, 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 five
optical bodies; the Association of British Dispensing Opticians,
the Association of Contact Lens Manufacturers, the Association
of Optometrists, the Federation of Manufacturing Opticians and
the Federation of Ophthalmic and Dispensing Opticians.
2. COMMISSIONING
COMMUNITY EYE
CARE SERVICES
2.1 We welcome the proposals in the Health and Social
Care Bill to retain a national sight testing service commissioned
by the NHS Commissioning Board. This efficient and cost-effective
NHS service delivers high levels of quality, access and choice
to all patients, including those patients that are confined to
their homes, due to a physical or mental disability. Being a national
service, set out in regulations, regulated by the General Optical
Council and market-led, the funding genuinely follows the patient
and the system delivers accessible care without waiting, wherever
patients want it, the length and breadth of the country.
2.2 The Bill also enables the Board to use powers
of delegation to allow local enhanced eye care services (ie beyond
the national sight testing service) to be commissioned by GP commissioning
consortia. We understand that such local enhanced services would
include cataract referral and glaucoma management schemes, for
example.
2.3 However there are other services, particularly
acute emergency eye conditions and glaucoma referral refinement
services (which like an NHS Sight Test are single defined services),
which we believe should be commissioned at a national level by
the Board to minimise transaction costs. Or, failing that, we
propose that the Board should recommend to commissioning consortia
a single agreed national pathway for these services (ideally at
an agreed average national price) to spare the NHS unnecessary
transaction costs and minimise the risks inherent in a multiplicity
of broadly similar but marginally different schemes.
2.4 The benefits of services such as glaucoma referral
refinement and minor emergencies schemes being delivered in optical
practices, is that they avoid unnecessary and costly referrals
to hospital eye clinics, GP surgeries and A&E depts. These
services have been provided successfully in some parts of England
and across the whole of Wales, resulting in significant cost savings.
We therefore believe that these services should be commissioned
nationally by the Board. This approach has also recently been
endorsed in an authoritative report by Professor Nick Bosanquet
of Imperial College, a former adviser to the Health Select Committee.
The report can be viewed via this link:
http://www.epolitix.com/fileadmin/epolitix/stakeholders/liberating_NHS.pdf
3 UTILISING LOCAL
HEALTHCARE PROFESSIONAL
EXPERTISE
3.1 We agree with the Committee that it is
essential for clinical engagement in commissioning, "to draw
from as wide a pool of practitioners as is possible in order to
ensure that it delivers maximum benefits to patients." The
Committee rightly highlights that GPs should, "be seen as
generalists who draw on specialist knowledge when required."
3.2 Although the Bill provides for commissioning
consortia to "obtain appropriate advice from healthcare professionals"
(Clause 22) we believe there should be a statutory requirement
to consult the relevant local representative committee. These
committees are the local voice of primary healthcare and refer
to the local network of the four contractor professions' committees
ie the Local Medical Committees, Local Pharmaceutical Committees,
Local Dental Committees and Local Optical Committees. They embrace
the whole range of healthcare professions and modalities of care
locally and are ideally placed to advise GP Commissioning Consortia
on the commissioning of wider services in their professional areas.
It follows therefore that it would be sensible for GP Commissioning
Consortia to consult for example Local Optical Committees, when
considering the commissioning of optical and ophthalmology services
(as well of course as the local hospital service and social care).
4 TRANSPARENCY
IN COMMISSIONING
4.1 Although we have long supported the split between
purchaser and provider of healthcare services, we are concerned
that the current proposals for local commissioning do not go far
enough to ensure that the tendering process is open and fair.
We hope that the Health Select Committee will investigate whether
there are sufficient measures in place to ensure that commissioning
decisions are transparent.
4.2 For the proper functioning of a liberated NHS,
transparency and openness in commissioning will be key to patients'
confidence in the system and its success. We believe that the
NHS Commissioning Board should make clear regulations about openness
and fairness in commissioning and tendering processes, as well
as appropriate timescales to enable any willing providers to participate
and ensure that innovative commissioning models are considered.
We also believe that the Government should confirm that there
will be declarations of conflicts of interest, transparency in
the decision making process and that full information about the
commissioning process as well as the right to appeal is clearly
communicated to all stakeholders. We also believe that GP Commissioning
Consortia should have a duty to consult commissioning partners
and other relevant stakeholders such as the local representative
committees and local HealthWatch on commissioning plans.
February 2011
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