22 November 2021

The College says proposed apprenticeship standard fails to address sector concerns

We have responded to the Institute for Apprenticeships and Technical Education’s (IfATE) degree apprenticeship consultations.

The College has responded to the Institute for Apprenticeships and Technical Education’s (IfATE) degree apprenticeship consultations saying that, as currently drafted, they will undermine the profession and risk patient safety.

Commenting on the standard and end point assessment (EPA) for the proposed Optometry Degree Apprenticeship, the College identified serious failings in the characterisation of the optometric profession, optometrists’ contribution to healthcare, as well as the knowledge, skills and behaviours that would be required of apprentices to enter it. 

The draft standard appears to have been submitted without addressing many of the concerns raised in the public consultation or having involved key stakeholders in development.

Lizzy Ostler, Director of Education for The College of Optometrists, said: “The proposed apprenticeship standard fails to capture the distinctive professional and autonomous nature of contemporary optometric practice or properly address the requirements introduced by the GOC through its Education Strategic Review, as was required after the public consultation. It is only weakly aligned with the new GOC outcomes and does not capture the characteristics of a qualification at level 7/11 (Masters) as is also required for professional registration.

“We believe that these, and other issues identified across all areas of the consultation, can only be remedied by substantial redrafting in collaboration with leading sector bodies and stakeholders. Without this, it is unclear how a degree apprenticeship could be implemented safely and effectively, and without significant, on-going challenge from the sector.” 

The College has also criticised the issuing of the endpoint assessment plan for consultation at the same time as the standard, rather than following the usual sequential process. It says it is essential that weaknesses in the standard are addressed before an effective endpoint assessment plan can be produced.

The College has concerns that the current cap on apprenticeship funding means that it is not clear how the costs of providing four years of full-time scientific and clinical education, will be met. We have also expressed doubts that it would be feasible, safe or effective for the apprenticeship and integrated Master’s degree to be completed within 48 months, whilst employed in practice. 

IfATE is expected to make a formal decision on the optometry apprenticeship proposal in January 2022. All detailed apprenticeship proposals will need to be approved by the GOC

The College’s full consultation responses on the standard and EPA are available here:


The College firmly believes that optometric education and training must remain of the highest quality, be patient-centred, delivered across the full range of settings in which optometry is practised, and responsive to the growing eye health needs of the population. 

We will not support any initiative that lowers the quality of that education, undermines the profession’s standing or risks patient safety. It is not in the College’s power to prevent the development or progression of an apprenticeship degree, but we will use our weight as the professional body to ensure that approval is only given to proposals that meet the highest standards of our profession.

The apprenticeship agenda is a government initiative enabled through law. Apprenticeships are developed by a Trailblazer group comprising employers representing the relevant occupation. Other interested organisations, such as regulatory and professional bodies (the College), are encouraged to participate, and can provide advice or raise concerns, but they cannot 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.

The College became involved in the process in 2019 in order to maintain standards, patient safety and to represent the profession, but we have not been made aware of any action or progress since our last consultation response at the start of 2020. 

In January 2020, we provided a response to the consultation on the introduction on an optometrist degree apprenticeship, and published an open letter to the Trailblazer Group. We challenged many aspects of the proposal, and called for a pause to any further development until these challenges can be fully reviewed and addressed.  We are disappointed that we were not consulted any further and were unaware of its progress and submission to IfATE. Although some of our previous consultation responses have been acted on, many have not.

You can find our response on the standard and EPA here.

As the professional body for optometry, the College is working with other key organisations across the health sector, and with national government, to ensure that optometrists have a voice in the debate, and are involved in the issues shaping their profession. 

IfATE will advise of the results of the consultation, and consequent action, in January 2022.   

Read further Q&As, and more information on the proposed Optometrist Degree Apprenticeship and the College’s activity here

You can also read an updated Q&A from the Trailblazer group here.