General Ophthalmic Services
Advice to providers of goods and services in the home or place of work:
The Optical Confederation and the UK Domiciliary Eyecare Committee has updated its advice to providers of goods and services in the home to also include the provision of goods and services in a place of work. The new statutory cooling off period of seven days applies to all goods and services ordered/contracted for in the home and, in some circumstances, in a place of work, for over £35, including the supply of spectacles, contact lenses and other optical devices. Providers contracting to supply optical devices or other goods and services to a patient in their home, residential home, day centre or, in some circumstances, place of work, are required by law to:
- Give the patient written notice of their right to cancel within 7 days of the order (or should that patient be incapable of making the decision for themselves, give that right to a close relative or an authorised representative of the patient)
- Do so in a specified format and containing specified information
- Contain specified words
- Provide a detachable form for the patient to use if they wish to cancel
- Accept notice of cancellation in writing in any format e.g. email or letter
Failure to implement these regulations is punishable by a fine of up to £5,000.
GOS Contracts in England
Joint guidance from ABDO, AOP, BMA and FODO on the [new] GOS contracts (England), issued in November 2008, applies to both mandatory (GOS) services and additional (domiciliary) services contracts. Please click here to view the guidance.
General Ophthalmic Services Contract in England: Contract Compliance Framework
NHS Primary Care Contracting (PCC) published its Contract Compliance Framework in April 2009. It is aimed at PCTs, to help them to monitor GOS compliance in England. You can view the full framework by clicking here or on the zipped file to the right of your screen. The individual sections are also listed separately, for quick access.
The framework comprises four elements: an introduction; a form to be completed by the PCT at the time of a practice visit; a standard post payment verification (PPV) protocol and guidance (previously published separately by NHS Counter Fraud and Security Management [CFSMS]; and a post-visit questionaire for contractors.
The framework focusses only on:
- contractual requirements
- there are no pre-visit questionaires to be filled in by practice/businesses
- recommends visits should normally only be once every three years
- makes clear that cliical governance is not a contractual requirement (whilst recognising that thre are some elements of contract compliance which would, in other circumstances, be considered elements of clinical governance)
- does not give PCTs the right to impose wider clinical governance requirements or reporting
- recommends that PCTs should invite practices to complete levels 1 and 2 of Quality in Optometry and agree reasonable fees with the LOC for doing this
- recommends that the PCT should consult LOCs about implementing the compliance framework locally (although LOCs do not have a right of veto)
- makes clear that visits should be helpful and supportive and that this is likely to generate a positive response from practices
- includes in grey information PCTs might like to have but which is not mandatory
- includes a follow-up questionnaire for hte practice for their parallel assessment of the PCT's visit
As the framework is only a guide for PCTs and is in no way mandatory, it is open to LOCs to agree variants of the framework in these and other areas. However, the national bodies strongly advise against this and certainly against agreeing more onerous variants, without first seeking advice from them or LOCSU.
Reporting NHS Complaints to PCTs
From 1 April 2009 the NHS complaints system was replaced by a new system in England. It was designed as a single, simplified approach for dealing with complaints about the NHS and adult social services. The effects of the new system on GOS contractors are marginal with the principal difference being that the patient can now complain directly to the PCT rather than via the service-provider i.e. the GOS contractor.
Whilst the obligation on contractors to have a complaints procedure in place is not new, the contractor is now obliged to inform the PCT regularly of the number of complaints which the contractor has received (Part 17, Clause 115) at an interval to be agreed between the PCT and LOC.
The LOC Support Unit and the professional bodies recommend strongly that contractors provide information on the number of complaints received, even if that number is zero, on an annual basis. The optical bodies recommend reporting complaints by 30th June for the period of the preceding financial year. To access joint guidance on NHS complaints from the representative, optical bodies, please click here
Definition of a complaint
Basically, a definition of an NHS complaint would be a complaint about the NHS service i.e. a sight test, whether it is put in writing or not and which is done in accordance with the formal, NHS complaints procedure. This complaint would not be a first level complaint, as it were i.e. something that could easily be put right by the practitioner, or a complaint about dispensing, which is a private transaction.
For more information on GOS please click here
National Patient Safety Agency and NHS Numbers
Please click here to view the joint advice issued by ABDO, AOP and FODO on the safer practice notice issued by the NPSA on NHS numbers. This notice sates that, from 18th September 2009, all primary and secondary providers should use the patient's NHS number. However, this advice is medically driven and primarily concerns general practice and the secondary sector. it cannot and does not apply to community optometric practices.
Revisions to application forms for GOS Contracts
Primary Care Commissioning (PCC) has revised the Section B declarations which form part of the model application forms for a new GOS contract. The revisions take account of changes introduced by the National Health Service (Miscellaneous Amendments Relating to Ophthalmic Services) Regulations which came into force on 1 April 2010 but they also make other relevant additions and amendments. The revised model forms have been produced in four variants for:
- Individual or partnership application for a mandatory services contract
- Individual or partnership application for an additionsl services contract
- Body corporate application for a mandatory services contract
- Body corporate application for an additional services contract
All the revised variants can be found by clicking http://www.pcc.nhs.uk/325
PCTs are being advised to introduce the new forms as soon as possible.