11 January 2019

NHS Wales' consultation on over-the-counter prescriptions

Read our response to the consultation on conditions for which over the counter items should not be routinely prescribed in primary care.

General

People on low incomes may not be able to afford to buy over-the-counter medicines and products. We fully appreciate that there are issues across the whole of NHS Wales, not just in prescription medicines, but imposing blanket policies on GPs that do not take into account demographic differences across the country, or allow for flexibility for individual patients, risk alienating the most vulnerable in society.

There is evidence that self-restriction of medications due to cost is common in seniors who lack prescription coverage, particularly among certain vulnerable groups. Seniors in these high-risk groups who have prescription coverage are much less likely to restrict their use of medications1. There are also studies, where health care provision is not universally funded, that highlight the direct and indirect costs of dry eye treatment2. These costs are significant in the context of the poorest in society and could drive further health inequalities.

1. Steinman, M.A., Sands, L.P. & Covinsky, K.E. J GEN INTERN MED (2001) 16: 793.
2. J Yu, CV Asche and CJ Fairchild.  (2011) The economic burden of dry eye disease in the USA: A decision tree analysis

Page 11 / section 1.3 Conjunctivitis

We disagree with the recommendation to advise health boards/trusts that a prescription for treatment of conjunctivitis should not routinely be offered in primary care as the condition is self-limiting and will clear up on its own without the need for treatment. 

We are of the opinion that this advice would be used as a steer to health boards/trusts that schemes to diagnose, manage and treat dry eye and conjunctivitis are not required, as people should use self-care measures and visit the pharmacy as stated in this proposal. A high proportion of minor eye conditions appointments relate to dry eye and conjunctivitis, so we could reasonably see health boards/trusts decommissioning on that bases, without the acknowledgement that these schemes differentially diagnose the red flag conditions and triage urgent pathologies that present with similar symptoms to conjunctivitis. 

The most common reasons for patients needing a minor eye condition assessment are ‘red eye’ (36.7% of patients), ‘painful white eye’ (11.1%), ‘flashes and floaters’ (10.2%)1. Ocular lubricants are most commonly supplied (29.7% of all patients seen), followed by topical antibiotic drops (12.1%)1.

We would suggest adding in this consultation an acknowledgement of the role that optometrists play in self-care and management. Optometrists are the best placed professional to advise people on self-care and the professional who people should go to if a condition, in fact, does not self-limit or has a red flag. Both the dry eye and conjunctivitis sections should recognise optometrists as professionals who can help support people's self-care. Secondly, optometrists should be stated in this document as the professionals people should access if self-care does not work, or if they have a red-flag symptom. This would support the aim of reducing unnecessary GP appointments. 

1. Evgenia Konstantakopoulou, Robert A Harper, David F Edgar, Genevieve Larkin, Sarah Janikoun, John G Lawrenson, Clinical safety of a minor eye conditions scheme in England delivered by community optometrists, 10.1136/bmjophth-2017-000125 Published 20 February 2018

Page 15 / section 2.4 Dry eyes/Sore tired eyes

We disagree with the recommendation to advise health boards/trusts that a prescription for treatment of dry or sore eyes should not routinely be offered in primary care as the condition is appropriate for self-care.

See previous comment.

Page 27 / section 3.1 Probiotics

We agree with the recommendation to advise health boards/trusts that probiotics should not be routinely prescribed in primary care due to limited evidence of clinical effectiveness.

Page 28 / section 3.2 Vitamins and minerals

We agree with the recommendation to advise health boards/trusts that vitamins and minerals should not be routinely prescribed in primary care due to limited evidence of clinical effectiveness.

DECLARATION OF INTERESTS

Do you have any business or personal interests that might be material and relevant to the project/document under consideration?

No.

Submitted: January 2019