Download Draft Optometry Policy(Comments).

OPTOMETRY POLICY
To Inform the Revision of the
Opticians (Registration) Act 36 of 1960.
DRAFT
Table of Contents
1.0 Background ................................................................................................................... 2
2.0 Introduction ................................................................................................................... 3
3.0 Current Legislative Framework ................................................................................ 5
4.0 Goal of the Policy ......................................................................................................... 6
5.0 Policy Objectives .......................................................................................................... 6
6.0 Policy Outcomes ........................................................................................................... 7
7.0 Policy Framework ......................................................................................................... 7
7.1 Governance .............................................................................................................. 8
7.1.1 The Ministry of Health....................................................................................... 8
7.1.2 Trinidad and Tobago Optical Council ............................................................... 9
7.1.3 Trinidad and Tobago Optometrists Association (TTOA) ............................ 1110
7.1.4 Trinidad and Tobago Dispensing Opticians Association (TTDOA) ........... 1211
8.0 Registration of Optometrists and Dispensing Opticians ............................................. 14
8.1 Licensure ............................................................................................................ 1514
9.0 Continuing Education (Optometrists and Dispensing Opticians) ........................... 1514
10.0 Student Optometrists ............................................................................................. 1615
1
DRAFT
1.0 Background
The World Health Report 1998 stated that blindness and low vision constitute major
public health challenges globally particularly in developing countries. In 2006 the World
Health Organisation (WHO) estimated that 161 million individuals globally were visually
impaired (less than 20/60 in the better eye). Approximately 124 million have low vision
(between 20/70 and 20/400). The remaining 37 million are blind (corrected visual acuity
of less than 20/400 in the better eye). Eighty percent (80 %) of the worlds‟ 37 million
blind people have avoidable causes of blindness.
This figure was revised upwards to 314 million in 2008 to include persons that are
visually impaired due to uncorrected refractive error (they simply do not have a pair of
glasses). In 2009 the figure was further revised to include an estimated 356 million
presbyopes (people who are visually impaired because they need reading glasses)
worldwide. This puts the worldwide tally of the blind and visually impaired at a
staggering 670 million worldwide.
According to the World Health Organization (WHO), despite current interventions,
blindness in the world is increasing by 1 to 2 million cases per year mainly in developing
countries. The result of this is a “doubling of world blindness by the year 2020 unless
more aggressive interventions are undertaken.
These statistics lead to the introduction of the World Health Assembly Resolution 59.25:
Agenda item 11.7, 27th May 2006 “Prevention of Avoidable Blindness and Visual
Impairment” The most relevant points of which are:
To reinforce efforts to set up National Vision 2020 Plans as called for in
resolution WHA56.26;
To develop and strengthen eye-care services and integrate them in the existing
health-care system at all levels, including the training and re-training of health
workers in visual health;
To make available within national health systems essential medicines and medical
supplies needed for eye care.
According to the 2000 Population Census, there are 18,583 individuals living in Trinidad
and Tobago with visual impairment. This can be further broken down into 7,998 males
and 10,585 females.
The best defense against avoidable blindness is access to quality, effective primary,
secondary and tertiary preventive vision and eye care. Regular comprehensive evaluation
of eye health and vision status reduces the risk of vision loss and provides clear,
2
Comment [D1]: Is this correct? It would be
important to include the exact reference.
DRAFT
comfortable binocular vision. The profession of Optometry has evolved as the primary
eye care profession responding to the universal need for quality, accessible, cost-effective
eye and vision care.
2.0 Introduction
Opticians who test sight were first required to register in Trinidad & Tobago on January
2nd 1933 under the Optician‟s (Registration) Ordinance Number 10 of 1932. This allowed
for the formulation of the Opticians Registration Board which consists of the Director of
Medical Services as Chairman of the Board, two Medical Practitioners and two
Opticians. These appointments were made by the Governor from time to time.
In 1959 a Bill was introduced to create the Optician‟s Registration Council and repealed
the Optician‟s Ordinance Number 10 of 1932. In this Bill, Opticians who test sight, or
Ophthalmic Opticians, were first recognized as Optometrists and Opticians who
compound and dispense spectacles only were recognized as Dispensing Opticians.
The Trinidad & Tobago Optician‟s Registration Council (TTORC) was constituted with
the appointment of two Medical Practitioners appointed by the Medical Board, three
Optometrists appointed by the Minister after consultation with the Ophthalmic Opticians
Association and one Dispensing Optician appointed by the Minister and the Director of
Medical Services or his nominee.
Comment [D2]: Suggest: “Optometry has
evolved as an important component in the provision
of eye care service, responding ….etc”.
Optometry is a profession concerned with examining
the eyes for defects or faults of refraction. In the UK,
optometrists (previously known as ophthalmic
opticians) are graduates who have undertaken a three
or four-year degree course in optometry followed by
a period of at least a year in supervised practice
before taking professional qualifying examinations
which lead to registration with the General Optical
Council. Optometrists prescribe optical aids (e.g.,
eye glasses, contact lenses, low vision aids),
supervise eye exercise programmes to treat vision
problems, and examine the eyes for disorders such as
glaucoma and cataract.
Optometrists are generally not licensed to prescribe
drugs or trained to perform surgery. Optometrists
screen patients for signs of ocular disease and refer
them to medical practitioners for treatment when
necessary.
In April 2009, the National Institute for Health and
Clinical Excellence (NICE) issued guidelines on the
diagnosis, monitoring and treatment of chronic openangle glaucoma and ocular hypertension. These
guidelines recommend that certain areas of
glaucoma-related work should be undertaken only by
an optometrist with a specialist qualification or who
is working under the supervision of a consultant
ophthalmologist. The Association of Optometrists
advises its members to refer any patients with an
intraocular pressure above 21 mmHg regardless of
the method of measurement.
Optometrists were barred from taking, using or assuming the title of „Doctor‟ under this
legislation for the first time. Prior to this legislation Optometrists followed the British
rules and regulations under the National Health Services Regulations and freely used
diagnostic drugs such as mydriatics and cycloplegics in practice.
The Optician‟s Act was amended in 1968, after Independence in 1962, to recognize the
independent state of Trinidad & Tobago. With this amendment, the Chief Medical
Officer replaced the Director of Medical Services.
The next change in the legislation came with Act 27 of 1987 which once again changed
the constitution of the TTORC to replace one of the Medical Practitioners on the TTORC
with a Dispensing Optician appointed by the Dispensing Opticians Association. The
Ophthalmic Opticians Association was replaced by the Trinidad & Tobago Optometrists
Association. Companies or firms practicing Optometry or the practice of Dispensing
Opticians were required to register under the Act for the first time.
3
Comment [SSR3]: Delete „
DRAFT
The use of diagnostic drugs was tightly regulated for the first time and only Optometrists
trained after 1960 were allowed to use diagnostic drugs in a small schedule which
consisted of topical anesthetics and sodium flourescein. Optometrists trained prior to
1960 had to show evidence of training in the use of diagnostic drugs.
The fitting of contact lenses were was also regulated for the first time, so that all
Optometrists trained after 1960 were allowed to fit contact lenses. Optometrists and
Dispensing Opticians trained before 1960 were allowed to fit contact lenses providing
that they could satisfy the Council of their proficiency.
In 2008 the Trinidad & Tobago Opticians Registration Council accepted the World
Council of Optometry‟s concept of Optometry and core principles when it applied for and
was accepted as an affiliate member of the World Council of Optometry (WCO).
According to the WCO, “Optometry is a healthcare profession that is
autonomous, educated, and regulated (licensed/registered), and optometrists are
the primary healthcare practitioners of the eye and visual system who provide
comprehensive eye and vision care, which includes refraction and dispensing,
detection/diagnosis and management of disease in the eye, and the rehabilitation
of conditions of the visual system.”
On April 8, 2005, the General Delegates Meeting of the World Council of Optometry
(WCO) formally adopted the Global Competency-Based Model for the Scope of Practice
in Optometry. This model provides a rational framework for addressing the challenges of
increased practitioner mobility across international borders; it assists states and countries
around the world to reconcile the variations in the scope of optometric practice
internationally and to support the need to promote greater harmonization in optometric
education around the world.
Additionally, the model responds to the challenges of the World Trade Organization
(WTO) and its General Agreement on Trade in Services (GATS), whose intention is to
allow the mobility of professional services across international boundaries through
Mutual Recognition Agreements (MRA‟s) that would be negotiated between states
(countries).
This competency model includes four categories of services which also provide a vertical
career ladder for individuals seeking to expand their scope of clinical responsibility. As
such, each category requires a set of competencies which includes the previous
category. The four categories of service are:
4
DRAFT
Level 1:
Optical Technology Services - Management and dispensing of ophthalmic lenses,
ophthalmic frames and other ophthalmic devices that correct defects of the visual
system.
Level 2:
Visual Function Services - Optical Technology Services, plus investigation,
examination, measurement, diagnosis and correction/management of defects of the
visual system.
Level 3:
Ocular Diagnostic Services - Optical Technology Services, plus Visual Function
Services, plus investigation, examination and evaluation of the eye and adnexa, and
associated systemic factors, to detect, diagnose and manage disease.
Level 4:
Ocular Therapeutic Services - Optical Technology Services, plus Visual Function
Services, plus Ocular Diagnostic Services, plus the use of pharmaceutical agents and
other procedures to manage ocular conditions/disease.
By virtue of its affiliate membership to the World Council of Optometry (WCO) Trinidad
and Tobago is seeking to adopt this competency based model as the standard for the
practice of Optometry locally.
The profession of Optometry has evolved as the primary eye care profession responding
to the universal need for quality, accessible, cost-effective eye and vision care.
3.0 Current Legislative Framework
The principal piece of legislation governing the profession of Optometry in Trinidad and
Tobago is the Optician‟s (Registration) Act of 1960. The Act is outdated and does not
support many aspects of a modern Optometric profession. Some of the limitations of the
Act are as follows:
1. The Act restricts the scope of practice of Optometrists to Level 2 of the Global
Competency Based Model. The USA, Canada, New Zealand, Australia, England,
Wales, Scotland Nigeria, South Africa, Bahamas, and St Lucia are examples of
countries that allow Optometrists the use of topical diagnostic and therapeutic
5
Comment [D4]: Please note: All graduates of the
UWI Optometry programme will be trained in
Ophthalmic Technology Services, plus investigation,
examination, measurement, detection and correction
of defects of the visual system.
Comment [D5]: Please note: Graduates of the
UWI Optometry programme will not be trained to
evaluate associated systemic factors or to diagnose
and manage disease.
Comment [D6]: Please note: Graduates of the
UWI Optometry programme will not be trained to
use pharmaceutical agents and other procedures to
manage ocular conditions/disease.
Comment [D7]: Suggest: “The profession of
optometry is an important component of the team for
the provision of eye care services.
DRAFT
2.
3.
4.
5.
drugs in professional practice. These countries have realized the relationship
between the scope of practice of Optometrists and the country‟s public health
needs.
The current Opticians (Registration) Act of Trinidad and Tobago does not
recognize Students Optometrists
The current Act does not allow the regulatory body for Optometrists, the Trinidad
& Tobago Optician‟s Registration Council (TTORC), to register Optometry
Students graduating from the University of the West Indies.
The current Act prohibits Optometrists registered under the Act the use of the
Title “Doctor”. This includes optometrists who have obtained a scientific
doctorate (PHD ) and a professional doctorate qualification Doctor of Optometry
(OD).We see this not only as a deterrent to returning nationals that have qualified
abroad but as a possible source of embarrassment to the University and the
Republic of Trinidad & Tobago.
The current Act offers only a very narrow scope of practice regarding the use of
diagnostic and therapeutic drugs in professional practice. This presents a major
challenge for the University to attract and adequately train students who may
wish to work in jurisdictions outside Trinidad & Tobago such as the Bahamas, St
Lucia, the USA, Canada, the United Kingdom, Australia and New Zealand.
These constraints presented by the current Act and advancements in the practice of
Optometry makes it necessary for the development of this Policy to inform the revision of
the current Opticians (Registration) Act 36 of 1960.
Comment [D8]: In the UK, a specific
examination in the use of drugs forms part of
professional qualifying examinations which lead to
registration with the General Optical Council.
Optometrists so registered have the right to use a few
diagnostic drugs (Level 1) with no requirement for
additional training. Since some of the drugs used by
optometrists in the UK are prescription-only
medicines (POMs), specific exemptions have had to
be established from the general rules laid down in
the Medicines Act. These exemptions are provided
for in the Prescriptions Only Medicine (Human Use
Order) 1997 SI No1830 (the „POM Order‟) and the
Medicines (Sale or Supply) (Miscellaneous
Provisions) Regulations 1980 SI No 1923.
Access to the Level 2 list involves additional training
and accreditation. The additional training is quite
considerable and can involve a number of teaching
and learning methods including a “learning in
practice” element which involves sessions spent in
the Hospital Eye Service under the supervision of a
designated ophthalmologist. A log book of clinical
cases is kept and this forms part of the final
assessment by two examiners (an optometrist and an
ophthalmologist).
The Community and Hospital Allied Network
Glaucoma Evaluation Scheme (CHANGES) began
in 2006 and involved trained optometrists with a
special interest in glaucoma (OSIs) to assess patients
suspected as having glaucoma in Cambridgeshire,
UK (supervised by the Glaucoma Service of
Hinchingbrooke Hospital NHS Trust). More recently
there has been monitoring of patients in the
community by accredited OSIs.
The National Institute for Health and Clinical
Excellence (NICE) published guidelines on the
diagnosis and treatment of chronic open-angle
glaucoma and ocular hypertension in April 2009.
These guidelines recommend that certain areas of
glaucoma-related work should be undertaken only by
...
Comment [D9]: Should read “ the existence of
“student optometrists
4.0 Goal of the Policy
The goal of the Policy is to provide a framework for the scope of practice for
Licensed and Registered Optometrists which is aligned with best practice standards
as outlined by the World Council of Optometry for the delivery of safe and quality
Optometry services.
Comment [D10]: The current Act does not allow
AUTOMATIC registration, but the TTORC can
assess and grant registration if the Council is
satisfied that the UWI Optometry programme
(syllabus and training) allows the UWI graduate to
function at Level 2.
Comment [D11]: This is not correct.
Comment [D12]: Please clarify.
Comment [D13]: Current Act allows practice at
Level 2.
5.0 Policy Objectives
Comment [D14]: The mandate of UWI
undertakes primarily to train graduates for service in
the region. As with all graduates of the Faculty of
Medical Sciences, UWI graduates wishing to work
elsewhere will need to satisfy the respective
requirements within those jurisdictions.
The policy objectives are to:
Establish the legislative and governance framework for revision of the Opticians
(Registration) Act;
6
Comment [D15]: The UWI is not in agreement
with the majority of these points.
Comment [D16]: Is revision of the Act
necessary?
DRAFT
Provide guidelines for broadening the scope of practice and the use of diagnostic
and therapeutic drugs in the professional practice of Optometrists;
Provide guidelines for continuing education for all Registered Optometrists;
Protect the public by ensuring health care is delivered by Registered Optometrists
in a professional, safe and competent way;
Uphold the standards of practice within the Optometry profession;
Maintain public confidence in the Optometry profession.
Improve the quality and expand the quantity of primary eye and vision care
provided to citizens of Trinidad and Tobago.
Comment [D17]: Open to discussion BUT
a) with additional training and certification
AND
b) under the supervision of a consultant
ophthalmologist.
Comment [D18]: Suggest: “As part of the eye
care team,improve….”
Formatted: Font color: Red
Formatted: Font color: Red
6.0 Policy Outcomes
Clear and unambiguous guidelines for the scope of practice of Optometry;
Optometrists who are current with advancements in their field;
An increase in the number of Optometrists practicing in public healthcare
facilities;
Increased public confidence in the practice if Optometry.
Provide comprehensive primary eye care services to the citizens of Trinidad and
Tobago.
Comment [D19]: Under the supervision of a
consultant ophthalmologist
Comment [D20]: Suggest:”As part of the eye
care team, provide……”
Formatted: Font color: Red
Formatted: Font color: Red
7.0 Policy Framework
The Optometry Policy seeks to provide the framework for the governance, management
and operations of the profession of Optometry. More specifically the policy includes the
following:
Governance,
Scope of practice for Optometrists and Dispensing Opticians,
Registration,
Continuing education,
Standards of practice.
7
DRAFT
7.1 Governance
Figure 1
OPTOMETRY GOVERNANCE
FRAMEWORK
MINISTRY OF HEALTH
TRINIDAD AND TOBAGO
OPTICAL COUNCIL
TRINIDAD AND TOBAGO
OPTOMETRIST ASSOCIATION
TRINIDAD AND TOBAGO
OPTICIANS ASSOCIATION
OPTOMETRISTS
DISPENSING OPTICIANS
University of the West Indies School of Optometry and Visual Sciences should be
included in governance framework as a stakeholder. Please add a 3rd UWI division
also.
Figure 1 illustrates the proposed governance framework for the profession of Optometry.
Comment [D21]: a) UWI is not needed as part
of the framework
b) UWI Optometry programme is housed in the
Office of the Dean, FMS. In addition, the
Optometry programme does not yet have a Visual
Sciences component.
Formatted: Superscript
7.1.1 The Ministry of Health
The Ministry of Health through the Minister of Health has the ultimate authority and
responsibility with respect to the governance of the practice of Optometry in Trinidad and
8
DRAFT
Tobago. The Minister of Health on the advice of the Chief Medical Officer, the Trinidad
and Tobago Optometrist Association, the Trinidad and Tobago Dispensing Opticians
Association, shall appoint the members of the Trinidad and Tobago Optical Council.
Comment [D22]: Include the Medical Board of
Trinidad and Tobago
7.1.2 Trinidad and Tobago Optical Council
The profession of Optometry shall be governed by the Trinidad and Tobago Optical
Council (TTOC) which will replace the Trinidad and Tobago Opticians Registration
Council (TTORC) and have regulatory oversight for the Trinidad & Tobago
Optometrists Association and the Trinidad and Tobago Dispensing Opticians
Association.
The Minister of Health, through the Trinidad & Tobago Optical Council, shall have
oversight for the Trinidad & Tobago Optometrists Association and the Trinidad and
Tobago Dispensing Opticians Association.
The members of the TTOC shall be appointed by the Minister of Health and nominated
by the TTOA and the TTDOA. A representative of the Ministry of Health shall be
nominated by the Chief Medical Officer and appointed by the Minister of Health.
The authority of the Council shall be in accordance with the legal framework created for
its establishment.
The Chairman of the Council shall exercise lead responsibility for the effective and
efficient functioning of the Council and shall be accountable to the Minister of Health.
The functions of the Council are as follows:
1. To develop and implement standards of practice for Optometrists and Opticians;
2. To impartially apply the approved criteria for the recognition of continuing
education courses and credits for Optometrists and Dispensing Opticians;
3. To develop a database of Optical firms, Optometrists and Opticians
4. To track the continuing education credits, registration and licensure status of
members;
5. To register and license Optical Firms, Optometrists and Opticians;
6. To collect statutory annual fees from Optometrists, Dispensing Opticians and
Optical firms;
7. To appoint statutory committees to execute its various functions.
The following Committees will be established to carry out the functions of the
Council.
9
Comment [D23]: Suggest: “and the Medical
Board of Trinidad and Tobago”
DRAFT
1. Fitness to Practice Committee;
2. Registration Committee;
3. Investigation & Inspection of premises Committee
4.
5.
6.
7.
Appeals Committee;
Education, Accreditation, Regulations and Standards Committee;
Audit Committee.
Inspection of premises
Additional committees may be established as need
This proposed composition of the TTOC is most problematic for the TTOA as we accept
the concept of Optometry as an autonomous and independent and self regulating
profession .The inclusion of two representatives of the Medical Board is not consistent
with this ideal particularly as they are not considered stakeholders and are not governed
under this policy.This composition would give Optometry less control rather than more
and would be resisted by all Optometrists.
If this composition is maintained we would strongly suggest that an independent and
separate Optometry Board and and Dispensing Board be established and the TTOC be
given regulatory oversight powers only leaving the TTOA as a private organisation to
advocate on behalf of the Optometrists. We recognize the University of the West Indies
School of Optometry as a major stakeholder and recommend the inclusion of two
nominees from the UWI School of Optometry instead. The inclusion of lay people on the
council is primarily to protect the public therefore they do not need to specify
professional qualifications.There is no justification for increasing the number of
Dispensing Opticians
Composition of the TTOC
Formatted: Font: 12 pt
Comment [D24]: Suggestion: two
ophthalmologists nominated by the Medical Board
of Trinidad and Tobago should be included as
certain functions of the optometrists need to be under
the supervision of an ophthalmologist.
Comment [D25]: UWI Optometry programme
(not a School of Optometry).
Comment [D26]: Agree – nominated by the
Dean, Faculty of Medical Sciences
Comment [D27]: UWI disagrees with this
position. Should be persons from professional
organisations. In addition, the TTORC should be
able to coopt other health professionals such as
Paediatricians and Endocrinologists as required.
Formatted: Font: 12 pt, Not Bold
1. A representative of the Ministry of Health appointed by the Minister of Health
2. Two Ophthalmologist nominated by the Medical Board of Trinidad and Tobago; No
need they are not governed by this act what is there function? Optometry and
opticianry are independent professions. Please remove them.
3. Three Optometrists nominated by the Trinidad & Tobago Optometrists Association;
4. Two persons from UWI Optometry School.
5. Three Dispensing Opticians nominated by the Trinidad and Tobago Dispensing
Opticians Association; (or two dispensing opticians )
6. Two (2) lay persons appointed by the Minister – one from the Legal profession and
one from the Finance and Accounting profession.(or one lay person)
10
Comment [D28]: Ophthalmologists should be
included as certain functions of the optometrists need
to be under the supervision of an ophthalmologist.
Formatted: Strikethrough
Comment [D29]: Two academic faculty
members affiliated with the Optometry programme,
nominated by the Dean, Faculty of Medical Sciences
Comment [D30]: Two lay persons should have
professional qualifications and should be nominated
by the respective governing body.
DRAFT
The Chairman of the Council shall be appointed by the Minister of Health on advice of
the Trinidad & Tobago Optometrists Association and the Trinidad and Tobago
Dispensing Opticians Association. after a majority vote of the council.
The Secretary of the Council shall be appointed by a majority vote of the Council.
Term of Office of Members
A member of the Council shall hold office for not more than three years from the date of
his/her appointment and shall be eligible for reappointment.
7.1.3 Trinidad and Tobago Optometrists Association (TTOA)
The TTOA shall be responsible for protecting and promoting the interests of Optometrists
as well as the interest of the public. The Chairman or the TTOA shall report to the TTOC
as prescribed in the legislation
The functions of the TTOA include the following:
i.
ii.
iii.
iv.
v.
Regulating/Policing the standard of practice for Optometrists;
Issuing guidelines for appropriate standards;
Inspection of premises; Concerns have been raised about conflict of interest this
function should be left with TTOC or Optometry Board
Making recommendations for disciplinary action;
Performing any other functions conferred on the Association by the legislation.
Composition of the Association
The Executive Committee of the TTOA shall be comprised of seven (7) members:
1.
2.
3.
4.
5.
The President;
The President-Elect;
The Treasurer;
The immediate past-President;
Three (3) members elected at the Annual General Meeting.
11
DRAFT
7.1.4 Trinidad and Tobago Dispensing Opticians Association (TTDOA)
The TTDOA is responsible for protecting and promoting the interests of Dispensing
Opticians as well as the interest of the public. The Chairman or the TTDOA shall report
to the TTOC as prescribed in the legislation.
The functions of the TTDOA include inter alia:
i.
ii.
iii.
iv.
v.
Regulating/Policing the standard of practice for Optometrists;
Issuing guidelines for appropriate standards;
Inspection of premises; Justification the same as before with TTOA
Making recommendations for disciplinary action;
Performing any other functions conferred on the Association by the legislation.
Composition of the Association
The executive committee of the TTDOA shall be comprised of five (5) members:
1. A representative from the Ministry of Health appointed by the Chief Medical
Officer;
2. Three (3) Dispensing Opticians, nominated by the membership of the Association,
one of which will be appointed Chairman by the Minister of Health on the advice
of the Association;
3. A lay person appointed by the Minister of Health.
Scope of Practice for Dispensing Opticians
Interpreting optical prescriptions written by Optometrists and Ophthalmologists;
Giving advice to patients on lens types, frames and styling;
Fitting contact lenses and giving advice on its care;
Taking frames and facial measurements to ensure correct fit and positioning;
Adjusting frames and repairing spectacles;
Ordering lenses from optical laboratories;
Selecting, managing and ordering a range of optical products;
Checking lenses on delivery to ensure that they meet the required specifications;
Liaising with sales representatives from vision care product suppliers;
Supervising and training Dispensing Opticians in apprenticeship programmes.
12
Formatted: Strikethrough
Formatted: Strikethrough
DRAFT
Scope of Practice for Optometrists
Level 1:
The practice of Optometry at Level 1 includes the following:
Optical Technology Services Management and dispensing of ophthalmic
lenses;
Ophthalmic frames and other ophthalmic devices that correct defects of the
visual system.
Level 2:
The practice of Optometry at Level 2 includes the following:
Visual Function Services;
Optical Technology Services;
Investigation,
examination,
measurement,
correction/management of defects of the visual system.
diagnosis
and
All registered and licensed Optometrists shall be permitted a scope of practice equivalent
to and not exceeding Level 2.
Level 3:
Comment [D31]: Agree. All graduates of the
UWI Optometry programme will be trained to
function at Level 2 – Optical Technology Services
plus investigation, examination, measurement,
detection and correction of defects of the visual
system.
The practice of Optometry at Level 3 includes the following:
Ocular Diagnostic Services;
Optical Technology Services;
Visual Function Services;
Investigation, examination and evaluation of the eye and adnexa, and
associated systemic factors, to detect, diagnose and manage disease.
Registered and licensed Optometrists shall be permitted a scope of practice
equivalent to and not exceeding Level 3 after meeting the following criteria:
1. The applicant must be in continuous practice (licensed and registered) for a
minimum of three years at Level 2 immediately prior to the time of application;
2. The applicant must provide evidence of having met all their continuing education
credits requirements;
3. The applicant must successfully complete a Level 3 competency based
assessment exam.
13
Comment [D32]: CME must be specific and
focused on knowledge gap closure. Additional
training must be detailed – please elaborate.
Comment [D33]: Please clarify and provide
details of the examination including who would
administer the examination.
DRAFT
3.
What about new graduates? They should be able to practice at this level
right away.All new graduates registering with TTOC since 1960 have been
trained to level 3, whilst existing practitioners may need refresher courses it is
unfair to subject new graduates to another exam.
Level 4:
Comment [D34]: All graduates of the UWI
Optometry programme are trained to Level 2 on the
Global Competency-Based Model for the Scope of
Practice in Optometry. Graduates of the UWI
Optometry programme will not be trained to evaluate
associated systemic factors or to diagnose and
manage disease (Level 3).
Formatted: Normal, Indent: Left: 0.5", No
bullets or numbering
The practice of Optometry at Level 4 includes the following:
Ocular Therapeutic Services;
Optical Technology Services;
Visual Function Services;
Ocular Diagnostic Services;
Use of pharmaceutical agents and other procedures to manage ocular
conditions/disease as specified
Registered and licensed Optometrists shall be permitted a scope of practice
equivalent to and not exceeding Level 4 after meeting the following criteria:
1. The applicant must be in continuous practice (licensed and registered) for a
minimum of two (2) years at Level 3 immediately prior to the time of application;
2. The applicant must provide evidence of having met all their continuing education
credits requirements;
3. The applicant must successfully complete a Level 4 competency based
assessment exam run by an approved provider in consultation with the TTOC.
3.
Again, new graduates?As before in certain jurisdictions new graduates
have already been trained to this level.
All practicing Optometrists will be required to submit evidence of the required
continuing education credits when renewing their license.
Comment [D35]: In the UK, optometrists are
graduates who have undertaken a three or four-year
degree course in optometry followed by a period of
at least a year in supervised practice before taking
professional qualifying examinations which lead to
registration with the General Optical Council. A
specific examination in the use of drugs forms part
of professional qualifying examinations which lead
to registration with the General Optical Council.
Optometrists so registered have the right to use a few
diagnostic drugs (Level 1) with no requirement for
additional training. Since some of the drugs used by
optometrists in the UK are prescription-only
medicines (POMs), specific exemptions have had to
be established from the general rules laid down in
the Medicines Act. These exemptions are provided
for in the Prescriptions Only Medicine (Human Use
Order) 1997 SI No1830 (the „POM Order‟) and the
Medicines (Sale or Supply) (Miscellaneous
Provisions) Regulations 1980 SI No 1923.
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Comment [D36]: Please elaborate and clarify.
CME must be focused on closing gaps in the
knowledge base.
Comment [D37]: Please provide details.
Comment [D38]: All graduates of the UWI
Optometry programme are trained to Level 2 on the
Global Competency-Based Model for the Scope of
Practice in Optometry. Graduates of the UWI
Optometry programme will not be trained to evaluate
associated systemic factors or to diagnose and
manage disease (Level 3), or in the use of
pharmaceutical agents and other procedures to
manage ocular conditions/disease (Level 4).
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bullets or numbering
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8.0 Registration of Optometrists and Dispensing Opticians
All persons or businesses wishing to provide Optometry services shall make an
application to the TTOC for registration on the prescribed forms and providing proof of
identity of the person making the application or proof of registration as a legitimate
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DRAFT
business entity under the Companies Act No. 35 of 1995. The TTOC shall evaluate the
applicant‟s eligibility based on pre-described criteria.
All practicing Optometrists shall be required to maintain their annual registration with the
TTOC. All businesses involved in the delivery of optometry services shall be required to
maintain annual registration with the TTOC. Each registered business must also have on
staff
one
or
more
qualified,
licensed
and
registered
Ophthalmologist/Optometrist/Dispensing Optician(s). (Each registered business must
also have one or more qualified and duly registered Optometrists /dispensing Optician on
their board of directors)
This measure should be introduced slowly to allow existing business to make
adjustments , this is particulary important for firms practising Optometry to maintain
professional standards
Comment [D39]: Does this not constitute an
infringement on the freedom of association of the
business owner?
8.1 Licensure
All persons or businesses wishing to provide optometry services must pay an annual fee
in January of each year to the TTOC to obtain a license to operate in that year. Licensing
fees are due each year commencing with the year following the year of registration.
9.0 Continuing Education (Optometrists and Dispensing Opticians)
All registered Optometrists and Dispensing Opticians shall be required to maintain
professional competence by completing continuing education courses commencing the
year following their initial registration.
Continuing education courses shall be accepted by the Council once it is provided by an
accredited school or college of Optometry or by a Provider approved by an Accredited
International Optometry Agency. Proof of participation in continuing education courses
equivalent to twelve (12) credits per year (or 36 credits in three years )will be required for
the renewal of licenses. Persons who qualified abroad will be allowed to use the
continuing education points obtained locally of internationally to satisfy local registration
requirements.
Thirty six credits over three years will allow more flexibility in case of hardship ,illness
or practitioners taking a sabbatical whilst maintaining international standards.
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DRAFT
10.0 Student Optometrists
Student Optometrists in the final year of the Optometry Programme will be required to
complete a prescribed number of hours of practicum at an accredited health care
institution. These students will be supervised by the Clinical Coordinator of the
respective University as well as Optometric and /or Ophthalmologists staff at the
respective institutions. These Students will continue to be the responsibility of the
respective tertiary level education institution(s) until they have successfully completes all
their clinical competencies and cleared for graduation.
Not all medical staff are qualified to supervise students.
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Comment [D40]: In the UK, optometrists
(previously known as ophthalmic opticians) are
graduates who have undertaken a three or four-year
degree course in optometry followed by a period of
at least a year in supervised practice before taking
professional qualifying examinations which lead to
registration with the General Optical Council.
Comment [D41]: Should be “and”