College responds to GOC consultation on the future of CPD for optometrists

No. 

Our reasons are:

1. Effective CPD should empower registrants to maintain and develop the competencies that directly protect patients and underpin safe and effective clinical practice. A structured, GOC-led framework provides the consistency, independence, and quality assurance that neither employers or the market alone can reliably deliver. The College supports a system that recognises the diverse careers of registrants while keeping patient safety at its core. We believe that evolving the current framework will achieve better outcomes than a wholesale restructure.
2. The objectives, taken in isolation, are worthy, but do not effectively consider the preparedness for change in the sector, and are not clearly connected to the principles presented in the introductory narrative.
3. The sector needs a framework that registrants can work to, to inform their CPD and career development activities. We are a procedural profession – removing too much of the framework without cultural change brought about with sustained support from the GOC will cause anxiety and will reduce the quality of CPD activity undertaken by a large proportion of registrants.
4. CPD activities in relation to enhanced practice, and additional qualifications are already recognised via provider CPD. This should not be promoted at the expense of maintaining oversight of core competence.
5. To move to an outcomes-based system registrants will need strong reflective skills. The GOC need to support registrants to develop reflective practice and make it easier for them to record this.
6. The College is concerned that the GOC will replace CPD points with CPD hours, or a less objective measure of activity, without addressing the variable quality of the CPD activities undertaken (or of the activities currently delivered by providers).
7. Equally, whilst recognition of the diverse career trajectory of registrants is important, development focused purely on enhancing non-protected activities should not replace development and maintenance of competences that are essential to patient safety. Registrant CPD should focus on maintaining and enhancing competence as a registrant.
8. It is not clear that current restrictions in freedom to undertake self-directed CPD are inhibitory.
9. As presented, the proposals could be interpreted as the GOC reducing costs by withdrawing from overseeing and assuring the quality of CPD and career development activities in favour of letting employers control it. Employers are not independent and will favour business and commercial needs and requirements when the focus should be on the individual and their development.
10. Employers are reluctant to take on this responsibility, and the College feels that this move will significantly adversely affect small businesses and locum optometrists.
11. We need to know what the costs of compliance are – there could be far better, more economical ways of doing this than restructuring the whole system. We believe that these current proposals will lead to an increase in fitness to practice cases and so would just transfer costs rather than save money. It will also risk the GOC missing non-compliance because random sampling cannot economically provide comprehensive coverage over a reasonable timescale. This might be rectified if a risk or judgment-based sampling approach could be developed.

No.

Our reasons are: 

1. The College does not support moving away from a points-based system at this time. Whilst the ambition to foster a more self-directed, intrinsically motivated approach to CPD is one the College shares, the preconditions for that shift do not yet exist across the profession (GOC report: only 3.9% of points in the last cycle were self-directed). Whilst many capable registrants would welcome the flexibility signalled by the proposals the registrants who need to be more closely managed to protect the public are not yet ready for the ownership of outcomes. To do so now could be a retrograde step.
2. The current evidence base tells a clear story: a significant proportion of registrants complete the majority of their CPD activity in the weeks immediately before the deadline. This is not a failure of the points system, it is a signal that the profession has not yet developed the self-assessment skills, professional confidence, or cultural relationship with CPD that a less structured framework would require. Removing the framework before that foundation is in place risks a measurable decline in CPD quality and engagement, with foreseeable consequences for patient safety and fitness to practise.
3. The College's position is that a structured, objective, and accountable CPD framework must remain in place until a profession-wide cultural shift has been achieved. A shift towards CPD as an integral and energising part of professional life rather than a compliance exercise, is achievable, but will require sustained investment, guidance, and coordination from the GOC and sector bodies over a realistic timeframe of five to seven years. To remove structural accountability before that groundwork is complete would be to prioritise administrative simplicity over professional standards

No. 

Our reasons are: 

Note: We have interpreted this question as an intention to improve flexibility and removing 
constraints by moving to guidance.

1. Guidance needs to be specific and measurable, itemising/describing fully clear criteria against which registrants will be assessed and what constitutes adequacy/inadequacy. This requires transparent piloting to enable the maximum number of registrants to engage in peer- and self-assessment in an environment providing safety to fail. Current barriers to self-directed learning stem not from GOC restrictions but from fear of 
   “getting it wrong”.
2. In order to be more flexible, as a stepping stone to removing specific requirements, the GOC should be far more creative, and inspirational, in their guidance on what are suitable activities and the amount of time needed to meet requirements. 
   1. Include formal education
   2. Include Educating Others as a domain which would include teaching and preparing optical learning events which should attract recognition
   3. Include Research and Service Improvement as a domain to recognise everybody’s role in improving the sector and the care of patients.
      1. Writing and presenting scientific papers and posters should be recognised
      2. ii. Active participation in transformative committees and projects should be recognised
      3. Peer auditing other registrants should be introduced and peer auditing another registrant mandatory. So, everybody gets audited by somebody they do not know – outcomes could inform judgement-sampling by the GOC for audit purposes. This could be submitted as (part of) the peer review
      4. Service improvement activities
   4. Include non-clinical leadership activities that may not be in the optical sector and may be gained from registrants’ hobbies and interests outside work, but that can be demonstrated to enable increased clinical leadership capabilities
3. Specific guidance should be in place for registrants who take breaks from practice due to maternity, childcare, sabbaticals or illness. This should embrace a flexible approach.
4. Specific guidance should be in place to advise new qualified optometrists who join the register mid-year / cycle and part time workers. This should embrace a flexible approach.

Sufficient CPD

Our reasons are: 

1. Registrants who dislike CPD will work to any minimum amount the GOC publish as a target. The worry is that more registrants see the minimum as the target so “sufficient” will need to be carefully worded to prevent this. Perhaps have “expected” as well as minimum amounts.
2. Emphasis should be on the quality and measurable impact of CPD activities, not how long they take to complete.

No. 

Our reasons are: 

1. We feel that this will reduce equity as registrants working for large employers will have better access to support on this than independent practices and locums.
2. It must be a personal plan, written by the individual for the individual - as employers and registrants will have different priorities to the contents of a CPD plan and this action could lock registrants into working for an employer – it will reduce workforce mobility.
3. Employers should have goals for their employers, and development plans but these should not constitute the registrants’ personal development plan, although they may overlap. There is a significant difference, given the current commercial cross-subsidy of healthcare provision, between being a more effective employee and being a safe and effective practitioner. The GOC’s own registrant survey highlights this disparity.
    

No. 

Our reasons are: 

1. It is insufficient to make a declaration when optometrists are already saying they comply with the standards in making their application. Focus should be in keeping the system honest and robust – sampling audits is inadequate for this. We feel that focused audits should be implemented based on outcomes from (anonymous) peer reviews.
2. The GOC needs to be very clear of what constitutes “sufficient learning” to those registrants who say they meet the expectations and to define what those expectations are. A mechanism will also need to be in place for those who report that they comply and do not meet the requirements as they could be viewed as lying which is a very serious fitness-to-practice situation.

Choose GOC systems or own records

Our reasons are: 

1. Both - large practices and the multiples are likely to have their own systems which may be excellent and encourage CPD; but what about small practices, individual practitioners or locums? There needs to be a safety net system for these people. Also, in independent system without commercial pressures. Perhaps such systems could be subject to approval?
2. If the GOC system is not used, the registrants should use software approved and validated by the GOC and upload a statement each year. Such software must:
   • export records in a consistent format
   • meet specified criteria
   • meet security requirements
   • cannot shackle a registrant to an employer

Yes.

Our reasons are: 

1. Yes - we think this should be mandatory for auditing any quality system. The GOC needs to evidence the quality of their systems so that targeted improvements can be made on solid data.
2. Whilst we recognise that audit can only ever be conducted on a sampling basis, accountability can be very variable as a consequence, with some overdoing through fear of lack of compliance and others hoping they will “get away with it”.
3. We suggest using targeted auditing as sample auditing needs to be large and detailed (and so, expensive) to be effective at raising standards.
4. Mechanisms such as universal, randomised, anonymous peer review of records should be used to manage and inform risk-based sampling for audit and provide a more comprehensive and equitable approach. This would also have the advantage of enabling cross-fertilisation of ideas and standards across the whole body of registrants.

Yes.

Our reasons are: 

1. Yes, unless there is a valid reason for that failure, such as prolonged illness or disability which could restrict access to resources - although this also might be considered as a lack of fitness-to-practise.
2. Mechanisms for development, akin to the “speed awareness course” could be used to develop registrants who fail compliance.
3. Maybe introduce “postponed renewal” registrations pending remedial CPD activity (that cannot be used in the current cycle).

Yes.

Our reasons are: 

1. Educating Others needs to be added to the domains as an excellent learning strategy and to encourage peer-led learning and the effective training / education of the next generation of optometrists.
2. Research and Service Improvement domain needs to be added as a domain to encourage audit and research.
3. The addition of these two domains will align optometrists with the four pillars used in other healthcare professions.
4. The GOC needs to significantly expand the types of activities that contribute to the (especially non-clinical) domains. This will increase the likelihood of registrant compliance by making development more enjoyable and easier to achieve. Forcing people to do a very limited list of activities does not make the process attractive for those who prefer to learn in different ways.
5. GOC must include studying for higher qualifications and teaching / developing others as acceptable activities for CPD.
6. Routine activities and those that do not cost registrants their own money must be prioritised – especially in self-directed learning.

No.

Our reasons are: 

1. Optometrists need to be able to participate in a more varied and innovative range of points so we suggest an increase in the diversity of means of being able to achieve the points.

No.

Our reasons are: 

1. We support making it a much more level playing field for optometrists to gain provider-led and self-directed CPD points.
2. Provider-led CPD is easier to maintain high-quality CPD activities. Some providers are far better than others so the registrant workforce does not have a clear idea of what constitutes “good CPD activity”. This could be phased out in the future but the GOC would need to identify the quality providers (and why) to demonstrate good activities. When this is firmly established we can then begin to phase out / reduce provider-led activity.
3. Making registrants and providers responsible for assessing the quality of activities needs careful management as some essential development may not be fun or easy to put on.
4. There is no evidence that the current limit represents a barrier, since the amount of self-directed CPD undertaken is still very low.

No.

Our reasons are: 

1. The College strongly opposes the removal of reflection statements from self-directed CPD activity. Reflective practice is not an administrative burden, it is a clinically validated learning technique that deepens self-awareness, supports the identification of developmental needs, and drives meaningful improvement in practice. 
2. The College's concern is not with reflection as a requirement, but with the inconsistent quality of reflective writing across the registrant population. More experienced registrants, in particular, often lack confidence and formal grounding in reflective methodology, not because they are less capable, but because structured reflection was not embedded in their early professional training. The GOC has a responsibility to address this through accessible, high-quality guidance and support, rather than removing a requirement that, properly undertaken, is one of the most valuable elements of the CPD framework.
3. To remove reflection statements would be to lower the standard of CPD at precisely the moment the profession should be raising it, and a move away from a robust pedagogical approach. 
4. We would support, in the future, requiring reflection on all activities as reflective practice is a fundamental aspect of learning and development. This should not happen immediately as a well-supported change in culture is required.
5. The process of documenting reflective practice must be less bureaucratic. 

1. Make it an expectation that businesses support their staff with CPD activities and give them resources/protected time in which they can do CPD activities.
2. Registrants could report each year how they are supported by their employer to achieve their development/CPD.

No.

Our reasons are: 

1. The PDP is a personal development plan and so needs to be personal. If businesses gain too much responsibility for registrants’ PDPs then they will influence them to align with the business requirements, not the individual optometrist (who might be developing their skills to leave that employer). This will tie registrants into particular businesses and will reduce workforce mobility, which drives down the quality of patient care. This is one reason the NHS is improving the workforce mobility of its scientific staff.*
2. Aligning registrants’ PDPs to the requirements of their employer’s business plans (officially) is a retrogressive move that will tie registrants to their employers and reduce the opportunities for self-development.
3. It is more important that businesses should support their employees’ CPD activities and give them protected time to do CPD rather than monitoring it.

* Note: The GOC’s Workforce & Perceptions Survey highlights high levels of bullying (36%) and commercial pressure (33%) within the optical sector. Increasing employer control over CPD and PDPs risks exacerbating existing power imbalances, particularly for locums, part-time workers, and those in precarious employment.

1. The College does not support strengthening the Standards for Optical Businesses as a mechanism for delivering this outcome. CPD is fundamentally a matter of individual professional responsibility and development, it sits with the registrant, not the employer.
2. Businesses have an important role to play in creating conditions that support CPD: providing protected time, facilitating access to relevant activities, and fostering a workplace culture in which professional development is valued. The College would welcome guidance that encourages employers to fulfil that enabling role more consistently.
3. However, there is a meaningful and important distinction between an employer supporting a registrant's development and an employer directing or controlling it. Extending business standards into the governance of individual CPD risks conflating those two things. Employers are not independent arbiters of professional competence; they have commercial interests that may not always align with the registrant's broader developmental needs or with the public interest. Oversight of CPD must remain with the GOC and the profession, not be delegated to the business environment.

1. Good clinical governance should involve patient feedback and all good clinicians should be involved in governance and audit.
2. Perhaps encourage it by providing patient feedback forms which ensures anonymity in paperwork and asks well-designed questions that could drive CPD and development.
3. Patient feedback should not stand alone but be supported by a new Research and Service Improvement domain.

No. 

Our reasons are: 

1. Do not deregulate it – make it less bureaucratic. Strengthen it and do more to assess the quality of the CPD provided by approved providers.
2. The GOC should maintain a register of approved providers and strike people off after investigation. This will require a process for whistleblowing for registrants to highlight poor quality.

Yes.

Our reasons are: 

1. Yes. The pre-approval paperwork appears as a rather tick-box exercise. Focus more on the quality of CPD events when they are delivered to drive up the overall quality of events.
2. Make the process less onerous by providing clear guidance and feedback when applying for approval.
3. Provide objective criteria for quality that providers will be held to.

No.

Our reasons are: 

1. No. Less provider audits and more event audits – “secret shoppers” with consequences for approved providers who deliver low-quality CPD events.
2. To do this the GOC will need to publish clear objective criteria for quality against which providers/events can be audited.