Visibility and Advocacy
NZAO: The voice for optometry and optometrists
We make representations to Government and other stakeholders about a range of issues and policy affecting the eye health of New Zealanders and the delivery of optometric services.
We do this by informing the public about optometry through media and promotional campaigns and contributing to inquiries on eye health issues and related issues where optometric knowledge and services can benefit the community.
As a member of NZAO you will have the opportunity to contribute to the submissions that the Association makes on professional issues.
- Submission to the Ministry of Health on the Child New Zealand Health Survey Stakeholder Feedback Questionnaire (July 2019). We noted the importance of vision for academic, social and physical development and advocated for the inclusion of indicators on status of eye health or vision function of children across the birth to 14 years age span. We requested the inclusion of questions relating to access to primary eye health services as this is a current gap in data.
- Submission to the Ministry of Health on the Adult New Zealand Health Survey Stakeholder Feedback Questionnaire (July 2019). We suggested that an important omission from the data on chronic conditions is information about low vision. Similarly, to the child health survey, we advocated for the inclusion of questions relating to access to primary eye health services and indicators on status of eye health or vision function.
- Submission to PHARMAC on the Proposal to list adalimumab – (July 2019) where we supported the proposal to widen funded access to adalimumab to include treatment of severe or chronic ocular inflammation (uveitis), as an alternative first‐line biologic treatment to infliximab. We also noted our support for the Special Authority criteria for severe and chronic ocular inflammation as being reasonable and that widening the funding would be a positive step.
- Submission to Ministry of Health on the Well Child Tamariki Ora Review (August 2019). We noted that vision and problems with visual functioning are not well covered by the WCTO programme and advocated expanding the vision screening program to truly screen a wide range of visual function; ensuring that vision problems are quickly and professionally diagnosed and where necessary that treatments are available and ensuring that investigation of childhood learning, behavioural and development problems includes investigation of vision function.
- Submission to Medafe on Proposed warning statements for substances (e.g. allergens) in medicines that may cause undesirable reactions (August 2019) where we were in general agreement with all proposals.
- Submission to Medsafe on Proposed changes to paracetamol warning and advisory statements (January 2020) where we were in general agreement with all proposals.
- Submission to the Optometrist and Dispensing Opticians Board on the Proposal to Amend Dispensing Optician Scope of Practice (January 2020) where we said we were not in favour of the proposed changes with its current wording. Our rationale included that the extended description required for “delegated tasks” is confusing for health consumers and open to misinterpretation by local/overseas employers of dispensing opticians unfamiliar with NZ health regulation. In addition, the proposed changes take place with no change to the health education component of the minimum qualification required for registration as a dispensing optician in NZ. Lastly, we felt it was not consistent with the regulation of optometrists by ODOB, or the regulation of other health professions under HPCAA by other Responsible Authorities.
- Submission to the Optometrist and Dispensing Opticians Board on the Preliminary Consultation - Revised Standards of Ethical Conduct (April 2020) where we noted in general strong support for the proposed changes. We raised the question if there should be a distinction between the ethics of the dispensing opticians and optometrists.
- Submission to Medical Council of New Zealand on their draft statement on Unprofessional behaviour: How it impacts patient safety and team‐based care. NZAO affirmed the proposed changes. We noted that making zero tolerance for unprofessional behaviour clear is helpful and the suggestion to discuss the problem in the first instance is a good idea.
- Submission to the Ministry of Health on the Draft Terms of Reference and Core Standards for Performance Reviews of Responsible Authorities. Our detailed submission made two specific recommendations, the first that the reference to competence and practice standards explicitly include a requirement that these be up to date or any other form of words that indicate that a contemporary standard is required not a traditional one. The second recommendation was that there be an explicit performance standard that relates to the performance of the responsible authority in providing and undertaking processes to assess applications by any health practitioner who applies for an authorisation for extended scopes of practice to include new services
- Submission to the Ministry of Health on the Therapeutic Products Bill which stated that NZAO would like provision in the new Act that ensures access to new medicines relevant to the scope of practice for all current professions, defined as authorised prescribers in the Medicines Act. In the case of optometry, NZAO want regulations that include any new medicines in scope if they are relevant to treating eye disease.
- Submission to the Ministry of Health on the New Zealand Health and Disability Systems review setting out a view of an ideal future health and disability system that would operate across community and hospital locations and recommends hospitals are for inpatient and specialist care and where possible outpatient services are moved to community based locations.
- Submission to the NZTA on the Land Transport Driver Amendment Rule 2019 contending that vision testing at initial application and every 10 years thereafter is safe and workable for the new online system.
- Submission to Ministry of Business, Innovation and Employment on the draft supplier code of conduct where NZAO suggested an addition regarding corporate social responsibility in relation to engaging in our local economy by contributing to their share of the tax burden and social responsibility.
- Submission to Ministry of Business, Innovation and Employment on proposed Government Procurement Rules 4th Edition where our focus was to encourage a more level playing field to the benefit of both NZ health consumers and NZ businesses. NZAO suggested that monitoring of professional standards, enforcement of those standards, and measurement of health consumer outcomes should carry equal or higher weighting than price alone in the procurement process.
- Submission to the Ministry of Health on the national strategic health and disability workforce priorities 2019-2024 where NZAO was asked to select and order the top ten of pre-prescribed priorities.
- Submission to the Optometrists and Dispensing Opticians Board of New Zealand on a proposal to amend APC fee & impose discipline levy for optometrists.