The College of Optometrists

Responding to the consultation on Healthcare Professional Regulation, the Council is positive about efforts to introduce greater consistency and collaboration between regulators and the other players in the UK health system.

The Council warns that differences between systems for regulating medical and non-medical professionals would undermine these efforts. However, it argues for proportionality in regulation, to recognise differences in size, practice settings and risk among the different professions.

There is also support for proposals to change the ‘culture’ of regulation, through a greater emphais on supporting good standards of practice, including provision for retraining and rehabilitation where problems arise.

GOC Chairman Rosie Varley said: “These two reports provide the basis for regulators to move ahead with some critical reforms which will promote public health and safety. The GOC is committed to strengthening public protection, and we look forward to working with the Department of Health, CHRE and other regulatory bodies to put key measures in place swiftly.”

Response on key points:

• The Council welcomes the principle of revalidation, provided that any approach is proportionate. Any revalidation approach should include a practical assessment, and the consequences of failure should be considered including opportunities for retraining and rehabilitation.
• The Council does not oppose the idea of a lay majority as this may improve public trust in regulation. Election of some members should continue to secure professional engagement.
• The GOC supports a single independent adjudicator for all the healthcare professions.
• Setting standards for entry to the profession is at the heart of professional regulation. The GOC strongly opposes moving education functions from the General Medical Council to the Postgraduate Medical Education and Training Board.
• A common standard of proof is a pre-requisite for common sanctions and a shared adjudication function. Respondents to the GOC’s consultation emphasised the seriousness of the available sanctions, citing in particular the effect of erasure on an individual’s livelihood in support of maintaining the criminal standard.
• Optical support workers pose a low level of risk to the public and currently work under the supervision of registered professionals. The GOC would not support further extension of regulation without a strong evidential case which addressed issues of risk and proportionality.