REFERRAL LETTER FROM THE MINISTER OF HEALTH AND LONG-TERM CARE

TO

THE HEALTH PROFESSIONS REGULATORY ADVISORY COUNCIL

The Health Professions Regulatory Advisory Council (HPRAC) provides independent policy advice to the Minister of Health and Long-Term Care on matters related to the regulation of health professions in Ontario.

The Advisory Council consists of seven members who are appointed by the Lieutenant Governor on the recommendation of the Minister of Health and Long-Term Care. These members are selected to provide a variety of expertise and experience as well as to reflect the geographical and cultural diversity of the province.

Before making recommendations to the Minister of Health and Long-Term Care, input is sought from a variety of sources including the public, interest groups, health professionals, health professional regulatory colleges and associations. Depending on the nature of the project, a variety of channels are used including written submissions, public hearings, focus groups, and community meetings.
 

On February 7th, 2005 the Minister asked HPRAC for advice on a number of issues relating to the regulation of health professions under the authority of the Regulated Health Professions Act, 1991, ("RHPA"), and to seek HPRAC's recommendations on certain issues. The Minister has sought advice on numerous issues; one of the issues is directly related to the practice of Opticians:
 

“Whether there is a risk of harm in dispensing eye wear and what aspects, if any of this activity need to be controlled by the RHPA, whether refractometry is within the scope of practice of Opticianry, and how standards should be set and measured for both of these activities.” Minister’s Referral Letter – February 7, 2005
 

As the regulator of the profession in Ontario, the College of Opticians was asked to present a submission to HPRAC regarding the above issue. This portion of the referral consists of five individual, but inter-related parts that will be addressed in this submission.

• Is there a risk of harm in dispensing?

• What aspects of dispensing should be a controlled act under the RHPA?

• How should standards be set and measured for dispensing?

• Is refraction within the scope of practice of Opticians?

• How should standards be set and measured for refraction?

Each of these topics has undergone a lengthy examination within the eye care professions over the course of the past number of years. The College strongly believes that there are inherent risks of harm in the dispensing of eye wear, whether it be contact lenses, sub normal vision devices or eyeglasses. The College also believes that dispensing should remain a controlled act under the RHPA. Furthermore, the College has worked diligently with the Ministry of Health and other eye care stakeholders to establish educational programs, standards and safeguards for refraction.

The submission to HPRAC from Opticianry will be made in various stages, and will include the following:

• April 21, 2005 – two presentations to HPRAC Council, one by the College of Opticians of Ontario and one by the Ontario Opticians Association

• April 29, 2005 – two full paper submissions to HPRAC, one by the College and one by the Association

• Week of May 9, 2005 – College and Association submissions circulated to all interested stakeholders

• Week of June 13, 2005 – Participants submissions due

• Week of July 11, 2005 – Public and stakeholder meetings/consultations

• July 29, 2005 – all additional submissions due –

While the College of Opticians does not act in an advocacy role, it does have a responsibility to the public to determine standards of practice, increase the scope of practice safely and improve public awareness in these areas.