Work and Pensions Committee - Universal Credit implementation: meeting the needs of vulnerable claimantsWritten evidence submitted by the College of Optometrists and the Optical Confederation


We welcome the opportunity to contribute to the Committee’s inquiry on the Government’s progress towards implementation of the Universal Credit.

We respond on behalf of the optical practitioners and practices that will provide NHS eye care services to adults who will be eligible to receive Universal Credit. In terms of eye health and eye care, the key passported benefits for these recipients will be the NHS sight test and the NHS optical voucher.

As previously stated in our submission to the SSAC Review of Passported Benefits, we very much support moves to simplify the benefits system with a view to making it genuinely easier for our patients to understand their entitlements, and easier for optical practices to administer.

We have limited our response below to those aspects of NHS eye care that are relevant to the inquiry.

1. Eligibility for NHS Sight Tests (as Passported Benefits)

1.1 NHS sight tests are vital to detecting avoidable sight loss and facilitating patient access to treatment. In this way, the NHS sight test offers a valuable and cost effective screening service, which delivers early and timely detection of a range of sight threatening conditions, in particular for patients with limited means or who are at higher risk of developing sight loss.

1.2 Visual impairment carries a substantial social and human cost. This can shorten life, increase the risk of other health conditions, restrict social participation and independence, and impair physical and mental health. The annual societal cost of blindness was estimated to be £22 billion in 2008. Sight loss is also projected to double by 2050, an increase of 115%.1 Yet, according to the Royal National Institute of Blind people (RNIB), half of this is estimated to be avoidable through early detection and prompt access to treatment. Even modest reductions in avoidable sight loss would therefore result in significant public health gains and savings in NHS and social care expenditure over the coming years.

1.3 Surveys of public attitudes indicate that the cost of eye care is a barrier to attending for a sight test.2 , 3 Restricting access to NHS sight tests for those on low incomes would therefore be likely to reduce their uptake and increase their likelihood of suffering avoidable sight loss.

1.4 Following on from an NHS sight test, patients in receipt of a range of means tested benefits currently qualify for help towards the cost of spectacles or contact lenses (a GOS 3 optical voucher) if required.4 Spectacles or contact lenses are, of course, provided to correct distance or near vision, which we would argue is fundamentally important to every individual’s quality of life, safety, employment prospects, and participation in society.

1.5 An NHS sight test and optical voucher are highly valued passported benefits and a key lever to prevent avoidable sight loss. We would strongly oppose any reduction in those eligible for NHS eye care passported benefits, which we feel would be a retrograde step in public health terms.

1.6 We note that Universal Credit will also be paid to certain individuals that re-enter the workplace (expected to be those on lower incomes for a transitional period). With respect to eye care, a problem may only become apparent once the individual returns to work, for example, when driving or concentrating on a near visual task. To offer such individuals a fair chance of staying in work, NHS eye care passported benefits should continue to be available while they are in receipt of Universal Credit. Otherwise, such individuals might not be able to afford to have their sight corrected and therefore struggle in their working environment.

1.7 We would therefore wish to see all patients in receipt of Universal Credit being eligible for an NHS sight test and optical voucher. Given that more individuals are predicted to receive Universal Credit than the range of benefits they replace this would result an increase in expenditure on NHS eye care, as noted above there are offsetting benefits from the early detection of and resolution of eye conditions.

2. Operation of Passported Benefits

2.1 Eligible patients currently complete General Ophthalmic Services (GOS) forms when they attend for an NHS sight test and where appropriate to apply for an NHS optical voucher. Each patient’s entitlement to a sight test or optical voucher is then checked by the optical practice. This system functions effectively and ensures that patients can access a sight test when they need one and the responsibility lies with the practice to check that the patient is eligible. While the system on the whole works well, we would however wish to see clearer information provided to individuals regarding their eligibility and have added further details about this in the following section.

2.2 We would like to add that, in addition to the benefits outlined above, allowing all of those in receipt of Universal Credit to qualify for NHS sight tests would have the added benefit of being a far more simple system to oversee and operate. This would deliver significant administrative savings to the optical practitioners, optical practices and NHS officials that collectively oversee the operation of the current system. These savings would help to offset another part of the cost of greater numbers becoming eligible for passported benefits under Universal Credit.

3. Support and Advice for Claimants

3.1 In our experience there is a great deal of uncertainty among patients regarding eligibility for passported benefits such as an NHS sight test, in particular with respect to NHS optical vouchers.

3.2 We feel that the transition to Universal Credit offers a great opportunity to provide clear and unambiguous information to patients regarding their eligibility for passported benefits such as an NHS sight test. This should ideally be clearly stated in the letter of entitlement sent to recipients, as a simple and cost effective way to raise awareness. We understand that concerns have previously been raised by Department of Work and Pensions lawyers regarding a benefit that is provided by another Government Department (ie the Department of Health determines eligibility for NHS sight tests). We do not feel this is a good enough reason for the lack of clarity regarding passported benefits. It would certainly be possible to convey the message that the recipient would be likely to qualify for health-related benefits such as an NHS sight test, and signpost the recipient to another source of information produced by the Department of Health or the NHS. The same clear and unambiguous information should also be clearly included in the letter of entitlement sent to recipients of Pension Credit Guarantee Credit (which will of course remain alongside Universal Credit).

4. About Us

4.1 The College of Optometrists is the Professional, Scientific and Examining Body for Optometry in the UK, working for the public benefit. Supporting its 13,000 members in all aspects of professional development, the College provides Pre-Registration training and assessment, continuous professional development opportunities, and advice and guidance on professional conduct and standards, enabling our Members to serve their patients well and contribute to the wellbeing of local communities.

4.2 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 Opticians (FODO). As a Confederation, we work with others to improve eye health for the public good.

17 August 2012

1 Access Economics (2009) Future sight loss UK (1): The economic impact of partial sight and blindness in the UK adult population

2 RNIB (2011) Preventing Sight Loss in Older People—Barriers and Enablers to the Uptake of Regular Sight tests

3 College of Optometrists (2011) Britain’s Eye Health in Focus

4 (Last accessed: August 2012)

Prepared 21st November 2012