OPTOMETRY POLICY - The Ministry of Health - Trinidad and

OPTOMETRY POLICY

To Inform the Revision of the

Opticians (Registration) Act 36 of 1960.

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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

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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,

Comment [D1]: Is this correct? It would be important to include the exact reference.

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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.

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.

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 open-

angle 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.

Comment [SSR3]: Delete „

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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:

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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

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.

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drugs in professional practice. These countries have realized the relationship

between the scope of practice of Optometrists and the country‟s public health

needs.

2. The current Opticians (Registration) Act of Trinidad and Tobago does not

recognize Students Optometrists

3. 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.

4. 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.

5. 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.

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.

5.0 Policy Objectives

The policy objectives are to:

Establish the legislative and governance framework for revision of the Opticians

(Registration) Act;

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

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.

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.

Comment [D15]: The UWI is not in agreement with the majority of these points.

Comment [D16]: Is revision of the Act

necessary?

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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.

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.

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.

Comment [D17]: Open to discussion BUT

a) with additional training and certification

AND

b) under the supervision of a consultant

ophthalmologist.

Formatted: Font color: Red

Comment [D18]: Suggest: “As part of the eye

care team,improve….”


Comment [D19]: Under the supervision of a

consultant ophthalmologist


Comment [D20]: Suggest:”As part of the eye

care team, provide……”


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7.1 Governance

Figure 1

OPTOMETRY GOVERNANCE FRAMEWORK

MINISTRY OF HEALTH

TRINIDAD AND TOBAGO OPTICAL COUNCIL

TRINIDAD AND TOBAGO OPTICIANS ASSOCIATION

TRINIDAD AND TOBAGO OPTOMETRIST 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.

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

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

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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.

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.

Comment [D22]: Include the Medical Board of

Trinidad and Tobago

Comment [D23]: Suggest: “and the Medical Board of Trinidad and Tobago”

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1. Fitness to Practice Committee;

2. Registration Committee;

3. Investigation & Inspection of premises Committee

4. Appeals Committee;

5. Education, Accreditation, Regulations and Standards Committee;

6. Audit Committee.

7. 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

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)

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

Formatted: Strikethrough

Comment [D28]: Ophthalmologists should be included as certain functions of the optometrists need

to be under the supervision of an ophthalmologist.

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.

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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. Regulating/Policing the standard of practice for Optometrists;

ii. Issuing guidelines for appropriate standards;

iii. Inspection of premises; Concerns have been raised about conflict of interest this

function should be left with TTOC or Optometry Board

iv. Making recommendations for disciplinary action;

v. 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. The President;

2. The President-Elect;

3. The Treasurer;

4. The immediate past-President;

5. Three (3) members elected at the Annual General Meeting.

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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. Regulating/Policing the standard of practice for Optometrists;

ii. Issuing guidelines for appropriate standards;

iii. Inspection of premises; Justification the same as before with TTOA

iv. Making recommendations for disciplinary action;

v. 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.



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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:


Visual Function Services;

Optical Technology Services;

Investigation, examination, measurement, diagnosis and

correction/management of defects of the visual system.

All registered and licensed Optometrists shall be permitted a scope of practice equivalent

to and not exceeding Level 2.

Level 3:


Ocular Diagnostic 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.

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.

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.

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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:


Ocular Therapeutic 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.

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

Formatted: Normal, Indent: Left: 0.5", No

bullets or numbering

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).

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.

Formatted: Font:

Comment [D36]: Please elaborate and clarify.

CME must be focused on closing gaps in the knowledge base.

Comment [D37]: Please provide details.

Formatted: Normal, Indent: Left: 0.5", No

bullets or numbering

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).

Formatted: Font:

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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

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.

Comment [D39]: Does this not constitute an infringement on the freedom of association of the

business owner?


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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.

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”

Documents

OPTOMETRY POLICY - The Ministry of Health - Trinidad and