20 November 2019

Consultation on plans to cease NHS Digital General Ophthalmic Services workforce and activity public

The College has responded to a consultation on GOS statistics publications (November 2019).

1. Do you currently use the General Ophthalmic Services, Workforce Statistics for England and Wales publication, or the General Ophthalmic Services, Activity Statistics publication? Please state which you use and how? 

Yes, the College of Optometrists uses both of these data sets. In our 2015 workforce survey project, these data sets were invaluable for national level data on the profession and on General Ophthalmic Services (GOS) activity.

We also use the data sets to monitor change within the sector and to support applications for research funding.

2. Are you supportive of the change proposed?

We do not support the change proposed.

While we appreciate there are concerns related to the reliability and accuracy of the data in these sets, discontinuing the collection of such data without a better alternative in place would not support activities to improve eye care and health.

We currently know far too little about the UK’s eye health, access to and use of eye health services, and the professions that provide them. While there may be flaws in the current GOS data sets, they are important resources to help understand the national situation and inform commissioning and public health decision making and planning. The data on GOS activity and the number of people on the performers’ list, although less rich and reliable than we and others in the sector would like, is vital to inform NHS England and NHS Wales, the Westminster and Welsh Governments and other key bodies’ collective thinking and planning on issues including service levels and demand, workforce and education.

Data can be used to improve health care, from better operational decisions, to quality improvement, commissioning, policymaking and public debate. Rather than reducing the data available, we need better data to:

  • monitor the quality of care being delivered over time, so that problems can be identified as soon as possible
  • understand mismatches between demand for health care and resources, helping policy makers and the eye health and care sector to adapt
  • evaluate the impact of interventions, to help policy makers and the eye health and care sector learn and improve services over time

While we would strongly advocate in favour of improving the quality of data collected across both the GOS domains covered, we would equally strongly oppose collection of these datasets ceasing before better data is available. To simply stop would leave a critical void. 

3. What would the impact of the change be to you/your work? 

Without these datasets, there would be no objective national data to refer to. This would undermine work to evaluate service use, the impact of health and social interventions and campaigns on access to/uptake of services.

Monitoring the profession would become more difficult and thus any scope for proactively planning the future workforce would be significantly undermined. Without these key datasets, it would be impossible to build a picture of current workforce levels in the optical sector and to answer questions on the current and future requirements of the optometric and the wider optical workforce. 

These datasets are the absolute minimum that not only The College of Optometrists, but also the NHS bodies need. Given the pace of change facing eye health, and the challenge of planning to meet patient need and demand, the range and quality of data on GOS collected and published by NHS Digital for England and Wales needs to be significantly better than it is now. However, better quality GOS data will not be achieved by stopping current data collection until an improved dataset can be established. We would instead support work to build on and improve the current datasets, as they provide a substantial base to achieve this. 

4. Do you have any other comments on this proposal?

Please note, practitioners have to provide GOS every 12 months to remain on the performers list, and not every six months as stated in the consultation document.

The GOS activity and performers’ list data really should not be difficult for NHS Digital to collect (and verify to a reasonable level of confidence), because both flow naturally from core PCSE functions.

We acknowledge that such data sets are unlikely to be accessed by large volumes of users, but user number should not be the correct measure for their utility or value. 

These are likely to be accessed by academics in relation to funding applications or as background data for their research, and by sector organisations to be used either to monitor impact of activities, or to share key data, or analyses with their members.

At a time of great challenges facing health services, we need to have better informed decisions to plan the right services to meet patient need and demand – this data 
collection is key and must be continued.


Submitted: November 2019

Related further reading

Dr Paramdeep Bilkhu MCOptom, Clinical Adviser for the College, on the scope of practice and eye care services in optometry practices.