Association Position Statements

Association Submissions


New: Position Statement on Uniform Optometry Legislation (Adopted March 2011)

The Position Statement on Uniform Optometry Legislation sets out the policy basis for seeking a uniform State and Territory legislative environment in respect of certain issues relating to optometry consequential to the National Law. It reflects relevant policy already approved.

Uniform Optometry Legislation (450kb)

Bulk Billing

The Position Statement on bulk billing sets out the Association’s recommendations to members on bulk billing.  Optometrists should develop their own policies on which, if any patients, they should bulk-bill.
 
Optometrists Association Australia does not require members to bulk-bill any or all of their patients and the Position Statement sets out issues optometrists may wish to consider in deciding which patients to bulk-bill.

Bulk Billing (31kb)

Contact Lenses and Welding

The Position Statement on contact lenses and welding sets out to dispel common myths about contact lenses and welding.

Contact Lenses and Welding  (55kb)

eHealth

The Position Statement on eHealth recommends to members they use emerging eHealth technology in their practise to the benefit of patient care.

eHealth  (43kb)

Expired Prescriptions

The Position Statement on expired prescriptions recommends to optometrists that expired prescriptions should not be filled unless there is a compelling reason to do so.  It is illegal to do so in SA and Tasmania.

Expired Prescriptions  (42kb)

Optometric Vision Therapy

The Position Statement on optometric vision therapy states that approximately half the Australian population has some vision problem requiring treatment. While the majority of people have refractive errors (shortsightedness, longsightedness, astigmatism and presbyopia), many people have problems that can be improved or remediated by vision therapy. Although its impact is greatest in children and young adults, vision therapy is effective for patients of any age who may have difficulty utilising their visual system efficiently.

Optometric Vision Therapy  (32kb) 

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Primary Health Care

The Position Statement on primary health care provides statement of optometry’s place in Australia’s Primary Healthcare sector. 

Primary Health Care  (58kb)

Private Health Insurance and Optometry

The Position Statement on private health insurance and optometry sets out the position of the Association on preferred provider arrangements and the need for transparent and consistent information; and fair equitable benefit for patients. 

Private Health Insurance and Optometry  (35kb)

Ready-Made Spectacles

The Position Statement on ready-made spectacles sets out the Association position on the sale of ready made spectacles.  Optometrists Association Australia believes that although ready-made spectacles are unlikely to cause a direct injury to someone using them, their unrestricted sale poses a risk to the community through its potential to divert people with serious eye conditions from seeking professional care.  Purchase of ready-made spectacles may lead to a false sense of security, since the spectacles may temporarily address one vision problem whilst other problems have not even been detected.

Ready-Made Spectacles  (54kb)

Regulation of the Prescription of Optical Appliances

The Position Statement on the regulation of the prescription of optical appliances sets out the Association position on the laws governing who should be permitted to prescribe optical appliances.  Misdiagnosis or mismanagement of what appear to be simple refractive errors can have significant impact on the health of individuals. Permanent loss of vision, blindness and in some rare cases, death are possibilities if eye disease is undetected. To protect the public from incompetent persons it is necessary to limit who may examine eyes.

In all States and Territories of Australia the prescription of optical appliances is restricted, except in special circumstances, to optometrists and medical practitioners. Governments have chosen to maintain the restriction on the understanding that the prescription of optical appliances is not an activity that can safely be separated from a comprehensive eye examination and that the person who prescribes an optical appliance also has the responsibility for the entire visual wellbeing of that patient.

Regulation of the Prescription of Optical Appliances  (86kb)

Rural Optometry

The Position Statement on rural optometry sets out the position of the Association on rural optometry workforce issues and the advocacy platform of the Association.  This has been drafted with the assistance of the Rural Optometry Group. 

Rural Optometry  (69kb)

Shared Care

The Shared Care Position Statement provides advice to members on successfully sharing patient care with other health professionals.

Shared Care  (45kb)

Supply of Contact Lenses

The Position Statement on the supply of contact lenses sets out the position of the Association on the sale of contact lenses. Contact lenses may pose a significant risk to ocular health and vision if they are not professionally prescribed or if they are not used and maintained correctly.
 
It is therefore the position of Optometrists Association Australia that contact lenses, regardless of type, tinting, optical power or intended use, should not be supplied except on presentation of a valid prescription.

Supply of Contact Lenses  (37kb)

Tobacco Smoking

The Position Statement on tobacco smoking sets out the Association’s view on tobacco smoking.  Given tobacco smoking can cause damage to ocular tissue, mainly via ischaemic or oxidative mechanisms, Optometrists Association Australia believes that:

  • Optometrists have a responsibility to advise their patients of the risks of tobacco smoking and to encourage smokers to stop smoking.
  • Optometrists should promote the health benefits of not smoking.
  • Optometrists should refrain from smoking when identifiable in their occupational role.
  • All workers are entitled to a smoke-free workplace.
  • Optometrists should include in occupational health and safety assessments advice on the risks of passive or environmental smoke to the eye and ocular health.
  • Research into the effects of tobacco smoking on eyes and ocular health is important and should be supported.

Tobacco Smoking  (61kb)

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Ultraviolet and the Eye

The Position Statement on ultraviolet and the eye sets out the Association position on the need for the protection of the eye from exposure to UV radiation.   

Ultraviolet and the Eye  (70kb)

Unpreserved Saline with Contact Lenses

The Position Statement on unpreserved saline with contact lenses indicates that the use of unpreserved saline in multi-use bottles in contact lens maintenance systems poses an unacceptable risk to contact lens wearers and should therefore not be recommended by optometrists.

Unpreserved Saline with Contact Lenses  (49kb)

Vision and Learning Disabilities

The Position Statement on vision and learning disabilities indicates that whilst optometry does not offer a 'cure' for dyslexia and other learning disabilities it is reasonable to provide learning disabled individuals with optometric assistance if they exhibit the signs and symptoms of a visual anomaly that is easily treated.

Vision and Learning Disabilities  (44kb)

Vision Screenings

The Position Statement on vision screenings sets out Association views on what matters ought to be considered before undertaking vision screenings for members of the public. 

Vision Screenings  (84kb)
 

Association Submissions

Pre Budget submission 2012-13

Our submission highlights the importance of continuing investment in optometry services, particularly investment in rural and regional optometry including for Aboriginal and Torres Strait Islander communities to ensure all Australians receive timely and equitable access to eye health care.

Download Submission (142kb)

Submission on the Skilled Occupation List

The following submission has been prepared in response to a request from Skills Australia about the Skilled Occupation List (SOL) for 2012.

Download submission (36kb)

Submission to the OBA’s public consultation paper on the definition of practice

The following submission has been prepared in response to the circulation by the Optometry Board of Australia of a public consultation paper on the definition of practice. 

Download submission (74kb)

Submission to the OBA’s consultation document on guidelines for supervision of optometrists

The following submission has been prepared in response to the circulation by the Optometry Board of Australia of draft guidelines for the supervision of optometrists.

Download submission (74kb)

Submission to Health Workforce Australia

The Association has provided the following submission to Health Workforce Australia in response to their Rural and Remote Health Workforce Innovation and Reform Strategy released in August 2011. This submission should be read in conjunction with the Association's position statements on Rural Optometry and Uniform Optometry Legislation. 

Download submission (307kb)

Submission on the development of the Rural Health Outreach Fund

The Government has announced the development of a new flexible fund for rural health outreach.  Draft Guidelines were issued and the Association made a submission which can be accessed here.

Submission to the OBA on draft registration standards for general and limited registration issued August 2011

The Association has provided the following submission to the OBA in response to the circulation of  on registration standards for general and limited registration issued August 2011.  This submission should be read in conjunction with the Association’s first submission made on the OBA’s Proposal for therapeutic qualification as a requirement for general registration. 

Download submission (81kb)

Submission on proposed amendments to NRAS

Download submission (75kb)
 

Submissions to Government - establishment of 'opt in' PCEHR

The following two submissions have been prepared in response to two Government discussion papers on the establishment of the 'opt in' Personally Controlled Electronic Health Records (PCEHR).

Legislation Issues Paper (157kb)
Submission to Draft Concept of Operations document (154kb)

OAA submission to Government discussion on MBS rebates for on line consultations

The following submission has been prepared in response to a Government discussion paper on the development of MBS rebates for on line consultations.

Submission to discussion paper (128kb)

Submission to the OBA: Proposal for therapeutic qualification as a requirement for general registration

Optometrists Association Australia welcomes the opportunity to comment on the Optometry Board of Australia’s (OBA) Consultation Document on proposal for therapeutic qualification to be included as a requirement for general registration.

Download Submission (79kb)

FOI request for workforce submissions

The association made two submissions to Skills Australia on the optometric workforce, which are available to view here:

The Department of Education, Employment and Workplace Relations has received a request for access to these documents, under the Commonwealth Freedom of Information Act.

VOS Review

The Australian Government has employed Health Policy Analysis (HPA) to undertake a review of the Visiting Optometrists Scheme (VOS) to be finalised by August 2011.  Optometrists Association Australia has prepared a submission which can be accessed here. Please contact Genevieve Quilty for further information.

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Association Position Statements

Association Submissions


New: Position Statement on Uniform Optometry Legislation (Adopted March 2011)

The Position Statement on Uniform Optometry Legislation sets out the policy basis for seeking a uniform State and Territory legislative environment in respect of certain issues relating to optometry consequential to the National Law. It reflects relevant policy already approved.

Uniform Optometry Legislation (450kb)

Bulk Billing

The Position Statement on bulk billing sets out the Association’s recommendations to members on bulk billing.  Optometrists should develop their own policies on which, if any patients, they should bulk-bill.
 
Optometrists Association Australia does not require members to bulk-bill any or all of their patients and the Position Statement sets out issues optometrists may wish to consider in deciding which patients to bulk-bill.

Bulk Billing (31kb)

Contact Lenses and Welding

The Position Statement on contact lenses and welding sets out to dispel common myths about contact lenses and welding.

Contact Lenses and Welding  (55kb)

eHealth

The Position Statement on eHealth recommends to members they use emerging eHealth technology in their practise to the benefit of patient care.

eHealth  (43kb)

Expired Prescriptions

The Position Statement on expired prescriptions recommends to optometrists that expired prescriptions should not be filled unless there is a compelling reason to do so.  It is illegal to do so in SA and Tasmania.

Expired Prescriptions  (42kb)

Optometric Vision Therapy

The Position Statement on optometric vision therapy states that approximately half the Australian population has some vision problem requiring treatment. While the majority of people have refractive errors (shortsightedness, longsightedness, astigmatism and presbyopia), many people have problems that can be improved or remediated by vision therapy. Although its impact is greatest in children and young adults, vision therapy is effective for patients of any age who may have difficulty utilising their visual system efficiently.

Optometric Vision Therapy  (32kb) 

Back to top

Primary Health Care

The Position Statement on primary health care provides statement of optometry’s place in Australia’s Primary Healthcare sector. 

Primary Health Care  (58kb)

Private Health Insurance and Optometry

The Position Statement on private health insurance and optometry sets out the position of the Association on preferred provider arrangements and the need for transparent and consistent information; and fair equitable benefit for patients. 

Private Health Insurance and Optometry  (35kb)

Ready-Made Spectacles

The Position Statement on ready-made spectacles sets out the Association position on the sale of ready made spectacles.  Optometrists Association Australia believes that although ready-made spectacles are unlikely to cause a direct injury to someone using them, their unrestricted sale poses a risk to the community through its potential to divert people with serious eye conditions from seeking professional care.  Purchase of ready-made spectacles may lead to a false sense of security, since the spectacles may temporarily address one vision problem whilst other problems have not even been detected.

Ready-Made Spectacles  (54kb)

Regulation of the Prescription of Optical Appliances

The Position Statement on the regulation of the prescription of optical appliances sets out the Association position on the laws governing who should be permitted to prescribe optical appliances.  Misdiagnosis or mismanagement of what appear to be simple refractive errors can have significant impact on the health of individuals. Permanent loss of vision, blindness and in some rare cases, death are possibilities if eye disease is undetected. To protect the public from incompetent persons it is necessary to limit who may examine eyes.

In all States and Territories of Australia the prescription of optical appliances is restricted, except in special circumstances, to optometrists and medical practitioners. Governments have chosen to maintain the restriction on the understanding that the prescription of optical appliances is not an activity that can safely be separated from a comprehensive eye examination and that the person who prescribes an optical appliance also has the responsibility for the entire visual wellbeing of that patient.

Regulation of the Prescription of Optical Appliances  (86kb)

Rural Optometry

The Position Statement on rural optometry sets out the position of the Association on rural optometry workforce issues and the advocacy platform of the Association.  This has been drafted with the assistance of the Rural Optometry Group. 

Rural Optometry  (69kb)

Shared Care

The Shared Care Position Statement provides advice to members on successfully sharing patient care with other health professionals.

Shared Care  (45kb)

Supply of Contact Lenses

The Position Statement on the supply of contact lenses sets out the position of the Association on the sale of contact lenses. Contact lenses may pose a significant risk to ocular health and vision if they are not professionally prescribed or if they are not used and maintained correctly.
 
It is therefore the position of Optometrists Association Australia that contact lenses, regardless of type, tinting, optical power or intended use, should not be supplied except on presentation of a valid prescription.

Supply of Contact Lenses  (37kb)

Tobacco Smoking

The Position Statement on tobacco smoking sets out the Association’s view on tobacco smoking.  Given tobacco smoking can cause damage to ocular tissue, mainly via ischaemic or oxidative mechanisms, Optometrists Association Australia believes that:

  • Optometrists have a responsibility to advise their patients of the risks of tobacco smoking and to encourage smokers to stop smoking.
  • Optometrists should promote the health benefits of not smoking.
  • Optometrists should refrain from smoking when identifiable in their occupational role.
  • All workers are entitled to a smoke-free workplace.
  • Optometrists should include in occupational health and safety assessments advice on the risks of passive or environmental smoke to the eye and ocular health.
  • Research into the effects of tobacco smoking on eyes and ocular health is important and should be supported.

Tobacco Smoking  (61kb)

Back to top

Ultraviolet and the Eye

The Position Statement on ultraviolet and the eye sets out the Association position on the need for the protection of the eye from exposure to UV radiation.   

Ultraviolet and the Eye  (70kb)

Unpreserved Saline with Contact Lenses

The Position Statement on unpreserved saline with contact lenses indicates that the use of unpreserved saline in multi-use bottles in contact lens maintenance systems poses an unacceptable risk to contact lens wearers and should therefore not be recommended by optometrists.

Unpreserved Saline with Contact Lenses  (49kb)

Vision and Learning Disabilities

The Position Statement on vision and learning disabilities indicates that whilst optometry does not offer a 'cure' for dyslexia and other learning disabilities it is reasonable to provide learning disabled individuals with optometric assistance if they exhibit the signs and symptoms of a visual anomaly that is easily treated.

Vision and Learning Disabilities  (44kb)

Vision Screenings

The Position Statement on vision screenings sets out Association views on what matters ought to be considered before undertaking vision screenings for members of the public. 

Vision Screenings  (84kb)
 

Association Submissions

Pre Budget submission 2012-13

Our submission highlights the importance of continuing investment in optometry services, particularly investment in rural and regional optometry including for Aboriginal and Torres Strait Islander communities to ensure all Australians receive timely and equitable access to eye health care.

Download Submission (142kb)

Submission on the Skilled Occupation List

The following submission has been prepared in response to a request from Skills Australia about the Skilled Occupation List (SOL) for 2012.

Download submission (36kb)

Submission to the OBA’s public consultation paper on the definition of practice

The following submission has been prepared in response to the circulation by the Optometry Board of Australia of a public consultation paper on the definition of practice. 

Download submission (74kb)

Submission to the OBA’s consultation document on guidelines for supervision of optometrists

The following submission has been prepared in response to the circulation by the Optometry Board of Australia of draft guidelines for the supervision of optometrists.

Download submission (74kb)

Submission to Health Workforce Australia

The Association has provided the following submission to Health Workforce Australia in response to their Rural and Remote Health Workforce Innovation and Reform Strategy released in August 2011. This submission should be read in conjunction with the Association's position statements on Rural Optometry and Uniform Optometry Legislation. 

Download submission (307kb)

Submission on the development of the Rural Health Outreach Fund

The Government has announced the development of a new flexible fund for rural health outreach.  Draft Guidelines were issued and the Association made a submission which can be accessed here.

Submission to the OBA on draft registration standards for general and limited registration issued August 2011

The Association has provided the following submission to the OBA in response to the circulation of  on registration standards for general and limited registration issued August 2011.  This submission should be read in conjunction with the Association’s first submission made on the OBA’s Proposal for therapeutic qualification as a requirement for general registration. 

Download submission (81kb)

Submission on proposed amendments to NRAS

Download submission (75kb)
 

Submissions to Government - establishment of 'opt in' PCEHR

The following two submissions have been prepared in response to two Government discussion papers on the establishment of the 'opt in' Personally Controlled Electronic Health Records (PCEHR).

Legislation Issues Paper (157kb)
Submission to Draft Concept of Operations document (154kb)

OAA submission to Government discussion on MBS rebates for on line consultations

The following submission has been prepared in response to a Government discussion paper on the development of MBS rebates for on line consultations.

Submission to discussion paper (128kb)

Submission to the OBA: Proposal for therapeutic qualification as a requirement for general registration

Optometrists Association Australia welcomes the opportunity to comment on the Optometry Board of Australia’s (OBA) Consultation Document on proposal for therapeutic qualification to be included as a requirement for general registration.

Download Submission (79kb)

FOI request for workforce submissions

The association made two submissions to Skills Australia on the optometric workforce, which are available to view here:

The Department of Education, Employment and Workplace Relations has received a request for access to these documents, under the Commonwealth Freedom of Information Act.

VOS Review

The Australian Government has employed Health Policy Analysis (HPA) to undertake a review of the Visiting Optometrists Scheme (VOS) to be finalised by August 2011.  Optometrists Association Australia has prepared a submission which can be accessed here. Please contact Genevieve Quilty for further information.

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