27 November 2019

Member alert: Q&A on a degree apprenticeship in optometry

The College has published a Q&A to address the most commonly asked questions from members on a degree apprenticeship in optometry.

We are listening to your concerns and will use all member feedback to inform both our position and our consultation response.

We are working on a response to the consultation, and we want your input. The comments we have had so far will help inform our response, but we want your feedback before we make our final submission. 

Your voice will be heard, and we look forward to working with you.

No, the apprenticeship agenda is a government initiative enshrined in law. No individual sector body can prevent an apprenticeship proposal being developed. However, we can ensure that key points of concern are considered at each stage of the formal process for considering whether an apprenticeship proposal should be approved for delivery.

Yes, we are. We know that the petition’s signatories include many of our members, and we will continue to address their concerns through our individual and member communications. We will continue to invite member feedback to inform our response to the consultation and future discussions on the degree apprenticeship.

Opposing the proposal at this point would not stop the degree apprenticeship or prevent it being progressed. By being involved, and reflecting member views, we will be in a better position to ensure that educational and professional standards in optometry are upheld than if we stepped away.

We are listening to member concerns; we will continue to invite you to share your opinions (now closed) so that we can represent them. We will use member feedback to shape our response to the consultation on the draft degree apprenticeship standard, and to inform what we say at the trailblazer group meetings. We are also encouraging members to respond to the consultation, as the trailblazer group will have to take account of all submissions. 
As the development of the degree apprenticeship progresses, we will keep our position under review. We will strongly oppose any proposal that diminishes professional standards or quality of education, or puts patient safety at risk.

The College is a professional body and our role is to ensure high educational and professional standards. Opposing the plan, or refusing to be involved in the trailblazer group at this stage, would not prevent the degree apprenticeship development. It would instead mean that the degree apprenticeship would be developed without our, and our members’, critical input. 

Yes. The College’s response to the consultation will take full account of all member feedback. We have taken on board members’ strength of feeling, and think it is vital to feed this into the proposal. We will highlight members’ specific concerns in our consultation response and our future contributions to the degree apprenticeship discussions. 

We will be submitting a full response to the consultation on the draft standard. We will develop this by taking full account of member feedback. We will also share our draft consultation response with members, for your feedback, in the coming week. 

Our response will reflect the strength of concern expressed by members, particularly relating to the potential dilution of optometry’s high-quality education and professional practice, risks to patient safety, and the imperative that an optometrist degree apprenticeship would have to relate to all the sectors and settings in which optometrists practise. We will also highlight gaps and ambiguities in the current draft. 

See question 20 for details on how you can share your views.

We do not know at this stage. It is proposed that individuals undertaking the apprenticeship would need to meet the demands of a Master’s degree. The admissions requirements would need to reflect this. 

As this is a degree apprenticeship, we would expect that the admission requirements would ensure that anyone who is accepted into such a programme would have the potential to successfully achieve the academic, professional and regulatory requirements of an optometry degree. Admission requirements for other degree apprenticeships are usually set by employers and universities in partnership. The College wouldn’t have a role in setting the admission standards – as we don’t now for university courses.

The College will strongly oppose any proposal that would put patient safety at risk. 

The same legal requirements would apply to degree apprentices as any optometry student or pre-registration trainee. Degree apprentices would have to have to fully meet the academic requirements of the underpinning degree and the regulatory requirements of the GOC, in the same way as for current optometry students and trainees. This includes working under supervision until they have met the requirements for full registration with the GOC to practise independently as an optometrist.

We also expect employers and universities intending to deliver any degree apprenticeship to ensure there is appropriate and safe learning progression through both work-based and university-based learning. There would need to be transparent and clear agreements about the limits of apprentices’ status, scope of practice and competence at any stage, as they progress through their degree. 

Any degree apprenticeship standard has to be of demonstrable relevance to a profession wherever it is practised, not just a particular employment sector or setting. For optometry, the standard must meet GOC requirements for full registration for safe optometry practice in the UK - and in every setting where optometrists practise. We will strongly oppose the degree apprenticeship if we do not think this is the case. 

The College will be actively involved in the degree apprenticeship discussions as we want to ensure that all the necessary requirements and approvals are robustly put in place at every stage.

There is a risk that it could - this is what the College is seeking to guard against. Our involvement in the trailblazer group will be to uphold high professional and educational standards and to raise objections if we believe these could be compromised. 

A degree apprenticeship in any profession should not, and must not, lower the high standards of the profession concerned.  Any degree apprenticeship for a profession that is subject to statutory regulation has to meet the academic, professional and regulatory requirements for that profession. 

It would not be appropriate for any party, or from any perspective, to put staff under pressure to take on apprentices against their will. The knowledge, skills and support that staff need to facilitate high-quality work-based learning and development (including up to Master’s degree level, as proposed by the optometrist degree apprenticeship proposal) is significant. It requires strong working links between the clinical environments and the university delivering the academic learning components. 

The investment of time, professional development and support to staff who are called upon to support degree apprentices is significant, and something that employers must take into full account when determining their readiness and commitment to engage with the apprenticeship model. 

Yes. Degree apprenticeships have been developed in a number of other clinical professions that are subject to statutory regulation. Examples include nursing, midwifery, clinical science, biomedical science, and most of the allied health professions. A degree apprenticeship has recently been approved for delivery for physician associates. 

Degree apprenticeships are more established in other professions outside health, such as law, chartered surveying and engineering.

We will be analysing key issues, including whether the same academic, professional and regulatory requirements can be safely, effectively and rigorously met through a different education route (albeit still underpinned by a degree) and with a different funding stream. We will also be looking at the central role that professional bodies have to play in ensuring that standards and quality are upheld at all stages of a degree apprenticeship’s development and implementation. 

This should not be the case. While individuals employed and enrolled on a degree apprenticeship would obviously be paid a lower salary than their fully-qualified colleagues, following qualification and registration, we would expect salary levels to be the same as those who have demonstrated the same threshold requirements through successfully completing a different route. The College has no role in salary setting, but we will continue to ensure that optometrists are valued as a key clinical professionals and that funding for eye care continues to be a priority for all UK health systems.

The College will oppose any development that could result in this. The checks and balances that apply to how a degree apprenticeship is developed, including having to meet the same GOC regulatory requirements to exist and be delivered, should avoid this. However, for the reasons set out in response to other questions, we believe that it is essential to engage at all stages to mitigate this risk.

At the moment, we do not have a clear picture. The College’s Optical Workforce Survey undertaken in 2015 suggested that there may be a net undersupply of optometrists, but highlighted considerable variations in the supply across regions and UK nations.

We don’t know. It is something that we will highlight in our consultation response. We recognise that apprentices would be employees whose learning would extend across the whole calendar year, rather than being limited by the shorter academic year, so the length of time studying would not be comparable to an academic year. We would expect to see that the length of any degree apprenticeship programme would enable the depth and breadth of learning that is required to meet the academic, professional and regulatory demands attached to pre-registration optometry education.

We strongly advise members to engage with the current consultation exercise on the standard. Please respond by the 9 December deadline and also let us know directly what you think by responding to us here.

The GOC is currently reviewing the requirements for full registration as an optometrist in the UK. They plan to develop a new set of ‘learning outcomes’ that define these requirements by the spring of 2020. 

We understand that the standard for an optometrist degree apprenticeship is due to be mapped to the new GOC learning outcomes. As the regulator, the GOC would need to be satisfied that the knowledge, skills and behaviours (KSBs) defined in the degree apprenticeship standard fit with these outcomes to approve it as a route to qualification. As the new learning outcomes don’t yet exist yet, we expect that this will create a significant delay in the development of the degree apprenticeship. The College is involved in informing the GOC’s work to set the learning outcomes and the GOC are regularly asking registrants to feed into the process. As there is such a strong link to the degree apprenticeship outcomes, we encourage members to also feed into the GOC’s work to develop the new outcomes

We understand that, while concerns raised about other degree apprenticeships have been listened to, this hasn’t stopped their development being progressed. 

For example, we understand that opposition to the pharmacy degree apprenticeship led to a period of review, but that the pharmacist degree apprenticeship proposal is still going to be developed

This is why we feel it is very important to be involved in the trailblazer group for the optometry degree apprenticeship, so we can directly influence its decisions and standards.

Related further reading

Claire Moulds examines the impact of a power of attorney on the patient relationship.

Research, including work carried out in high-street optometry practices, is driving innovation in clinical practice and at a policy level, writes Mark Gould.