“What is at stake is not just a tinkering around the edges of how NHS optometry works in Wales”
AOP chief executive, Adam Sampson, discusses responding to consultations and the importance of the current consultation about the future of primary eye care in Wales
25 May 2023
Dealing with Government consultations should be a simple process. Analyse the issues, understand the questions, and construct an evidenced, sensible set of answers.
But consultations are not like exams: you’re not usually aiming to produce the answer the question-setter wants to hear. Having been on both sides of consultations over my career, both constructing and answering them, I am only too aware that in many cases the process of consultation is just a formality, with the outcome already determined. For those engaging with them, what you are often aiming to do is to convince government that there is another, superior solution to the problem they are struggling with. Failing that, your objective is less constructive: to provide an answer which makes life difficult for government to claim that what they are doing has the full support of those being consulted, and make clear the risk they are taking in pressing ahead with what they are intending.
This makes the key quality in responding to consultations political acumen. Success means exerting influence, using every weapon you have – knowledge, argument, naked power (or at least the threat of power) – to shape government policy.
In truth, there are consultations which are not worth bothering with. But sometimes, they matter. And occasionally, as in the case of the consultation about the future of primary eye care services in Wales, they matter very much. What is at stake is not just a tinkering around the edges of how NHS optometry works in Wales, but a substantive reworking of the current settlement. Getting our response right will be absolutely essential.
Yes – there is a lot in the proposals to welcome, not least the increased funding for GOS sight tests. But there are also some areas which cause us serious concern: the treatment of domiciliary care, the reduction of voucher values, the idea of mandatory spectacle supply, and the lack of clarity about exactly what the overall burden of activity for GOS work will look like
Responding correctly will require us to manage two very important dynamics. First, there is the – not unusual – tension between criticism and praise from opposition and support. You can only exert influence if what you say has impact, and if officials think you are totally opposed to everything they are trying to do, they will brand any legitimate criticisms as mere bad faith. Equally, playing too nice rarely proves effective: while no-one wants to go the full Machiavelli, there is an element of truth in the dictum that fear breeds respect and respect is what one is playing for.
Second, there is the question of the extent to which you can convince officials that what you say matters. If, as the AOP, we represent 80% of optometrists, you’d have thought that in itself represents an easy passport to influence. But it’s rarely that simple. It is not the biggest organisations which carry most sway, but the ones which are capable of projecting importance. This is why media and political activity matters so much: they can make even the smallest organisation look big.
My entry as a campaigner was in penal affairs, revelling in the important-sounding title of deputy director of the Prison Reform Trust and learning to operate in the media and on policy platforms. In truth though, I was merely one of three people. Fortunately, no-one ever stopped to ask themselves why on earth what I said mattered; had they done so, the cover would have been blown and my influence with it.
Both these dynamics will be tested in responding to the consultation on the proposed reforms of primary eye care in Wales. Yes – there is a lot in the proposals to welcome, not least the increased funding for GOS sight tests. But there are also some areas which cause us serious concern: the treatment of domiciliary care, the reduction of voucher values, the idea of mandatory spectacle supply, and the lack of clarity about exactly what the overall burden of activity for GOS work will look like. The balance between welcoming and opposing will be crucial.
We are not approaching this consultation from an English – or even UK – perspective, but from a Welsh one
Even more delicate will be our political positioning. In the run-up to the consultation, the Welsh Government made it very clear that it was only interested in doing business with Welsh organisations. Exerting the influence we need to exert to manage the risks attached to the proposals has required us to adopt a twin-track approach. On the one hand, we have been working hard to support and equip Optometry Wales in constructing its response. If theirs is the voice the Government will listen to, we need to be humble enough to accept that and work with it.
At the same time, we need to assert our own legitimacy in Wales. We are not approaching this consultation from an English – or even UK – perspective, but from a Welsh one. When we construct our response, it will be built on detailed input from our Welsh members provided not just in response to a survey we are currently running, but face to face and virtually via specially arranged Welsh events. Our head office may be in England, but our last two chairs have been proud representatives of other nations and it is our mission to serve our members throughout the whole of the UK. And the AOP is, above all, driven by its mission.