The College submits its response to the GOC's draft strategy 2025-2030

Yes.

We support this vision in principle. All registrants, as healthcare professionals, have a responsibility to ensure the care and safety of their patients.

We welcome the use of ‘eye care’ rather than ‘optical’ as it reflects the wider range of activities that are undertaken by registrants.

However, we would welcome more information from the GOC on how they will measure success in achieving its vision. The GOC should define what it means by “eye care”. It is not clear whether “effective eye care” refers to its delivery by registrants and/or outcomes for patients.

In addition, the delivery of safe and effective eye care for all is not limited to optometrists, dispensing opticians, students and businesses, but it also involves other professions not regulated by the GOC, like ophthalmologists, ophthalmic nurses, or orthoptists.

We recommend the GOC specifies which aspects of eye care it will measure to assess progress towards achieving its vision.

No.

As mentioned in our response to Q1, the delivery of safe and effective eye care is not limited to optometrists, dispensing opticians, students and businesses, but it also involves other professions not regulated by the GOC. It is therefore not possible for the GOC to uphold high standards in all eye care services in the UK. The GOC sets standards for the performance and conduct of registrants to ensure the care and safety of their patients, but not standards in eye care services.

We acknowledge that the GOC uses ‘services’ rather than ‘professions’ to reflect the fact that both individuals and businesses (using any of the protected titles in their company or trading name) are registered with them. We also recognise that the GOC is seeking an extension of its power to regulate all businesses in the eye care sector carrying out restricted functions.

Therefore, we suggest the GOC better aligns its mission with the scope of its core functions and better defines its mission.

Yes.

We welcome the increased focus on the changes in the workforce and the recognition of the impact technology is having on the profession and the care they provide, including remote eye care, international delivery of services into the UK and new technologies, including artificial intelligence (AI). As technology improves, registrants will be able to deliver more care in new ways, closer to patients’ homes. Developing good practice around the use of telemedicine is an opportunity for registrants to offer a wider range of services in the future, and to widen access to primary care for patients.

We recommend including the lessons learned from the COVID-19 pandemic which have brought to light that some of the GOC’s legislation and regulations may have prevented care being delivered effectively during the pandemic. To address this, the GOC published statements to remove unnecessary regulatory barriers.

We also welcome the recognition of an ageing population which will lead to increased needs for eye care in general – and not only domiciliary eye care – as it will have an impact on the eye care workforce that is required to meet their needs. However, we recommend also adding the expected increase for eye care of the younger population, as not all children have regular access to eye care services. The prevalence of myopia is expected to increase leading to more eye care needs. The proportion of myopes in the UK has more than doubled over the last 50 years in children aged between 10–16 years and children are becoming myopic at a younger age (McCullough SJ, O’Donoghue L, Saunders KJ (2016) Six Year Refractive Change among White Children and Young Adults: Evidence for Significant Increase in Myopia among White UK Children. PLoS ONE 11(1): e0146332.)

Furthermore, we recommend including the expected development of innovative diagnostics and treatments that have the potential to lead to improved prevention, earlier detection and better treatments for eye conditions. This will transform eye care services, including through digital transformation, such as telemedicine solutions, artificial intelligence and remote patient monitoring. Currently, treatments are focused on the slowing or halting of progression, and in some cases partial reversal of condition. Over time, better treatments will evolve towards reversal of deterioration in sight and prevention of disease. Emerging advanced digital technologies, digital therapeutic approaches and innovation in drug delivery also provide new challenges and opportunities for optometry. It will be important to ensure that future regulation:

• reflects current and future context of healthcare delivery, including in terms of developments within technology and treatments, and the potential increase of clinical care and health services delivered by optometrists.
• reflects future workforce needs and the development of different roles required to deliver the eye care needs in the UK.

It is important to ensure that registrants are prepared for future treatments and new technologies on the horizon through appropriate education and training and are supported to upskill to deliver more clinical services for the benefits of patients.

Regulation should support optometrists in expanding their scope of practice, including IP optometrists with the development of future new medicines and treatments. We have published guidance on expanding the scope of practice setting out the principles that will support optometrists when deciding whether a particular procedure or therapeutic activity falls within their scope of practice, or when moving into a new area of practice, to ensure patient safety and robust governance.

We recommend adding the increasing role optometrists play in primary and preventative healthcare for both ocular and systemic conditions. They are in a good position to deliver important public health services to patients attending for regular eye examinations who may not be in regular contact with other healthcare professionals. Optometrists can identify both eye problems and other wider systemic diseases, and provide advice, treatment, referral, signposting and support to manage these. 

For example, as well as identifying eye conditions, eye examinations can identify high blood pressure, high cholesterol and patients that may have diabetes or are pre-diabetic. A good case study is the Healthy Living Optical Practice initiative, which started in Dudley. Through the scheme, optometrists and colleagues in primary eye care offer a range of health-related advice, including NHS health checks, smoking cessation services, alcohol screening and weight management. Patients can also receive lifestyle advice and, if necessary, referral into other support services.

A pilot stroke prevention study has been set up in East Cheshire, to determine if primary eye care practices could identify patients with undiagnosed atrial fibrillation. Patients aged 60 and over who were already attending for a sight test were screened. Five practices took part and in 12 months 329 patients were screened and 31 patients were referred for further investigation at their GP. The pilot demonstrated that screening in primary eye care reduced the burden on GPs and identified a number of people at risk of stroke, enabling them to seek appropriate treatment and reducing the negative impact a stroke could have on their lives and to the wider health and social care system.

Prevention and wellbeing are an important part of moving towards a healthier population and optometrists are well placed to provide relevant prevention and public health advice. It is important that optometry practices continue to be seen as supportive, accessible and inclusive providers of care.

Where enhanced services require skills and expertise beyond the core standard competencies, additional training, and potentially accreditation, will be needed. However, the regulation of such training, approval of courses and accreditation should be reasonable, rapid, proportionate and not duplicate existing CPD requirements. 

Optometrists should be supported to obtain the higher qualifications required to provide additional services. The biggest barrier in delivering this objective is access to clinical learning placements. A national improved approach to removing the bottlenecks in clinical placement opportunities is needed so that we can increase specialist skills in the optometrist workforce and ensure that practices can continue to provide eye care while their employees attend courses or training. 

We suggest including the impact the implementation of GOC's Education and Training requirements (ETR) is having on optometry education, employers, and other stakeholders involved in the design, delivery and assessment of GOC-approved qualifications – as this will continue within the lifetime of the GOC’s new strategy. 

Finally, we suggest adding the developments occurring in each of the devolved nations. We fully acknowledge that the GOC is the UK regulator, but the specificities of each nation and required regulatory changes should also be included. There are potential challenges across the four nations that should be considered when developing the GOC’s new strategy. With universities having integrated pre-registration style placements starting and finishing at different times, assessing students in different ways, and having them qualify at varying times, means that there will be a lot of variety across the UK and that might restrict movement of qualified registrants between each nation, exasperating unequal access to eye health services across the UK.

Yes.

We agree with this strategic objective but would recommend putting more emphasis on tackling negative working environments since the GOC Registrant Workforce and Perceptions Survey 2023 found high numbers of registrants experiencing bullying, harassment, abuse, or discrimination in the workplace.

We also recommend adding more emphasis on regulation that facilitates more inclusive access to eye care services across the UK, considering geographical disparities and wealth inequalities, in addition to groups with protected characteristics, eg tackling the postcode lottery and ensuring every person in the UK has access to an optometrist.

Although 17% of the population live in rural areas, a 2016 workforce survey indicated that only approximately 11% of the eye care workforce worked in non-urban areas. This indicates that there is a disparity in the location of primary eye care services in non-urban areas, compared to the size of population that lives there. 

There is also evidence that people living in socio-economically deprived areas face more barriers to accessing primary eye care and regular eye examinations, and therefore present later to hospital eye services. The association between socioeconomic deprivation and eye disease is well established. UK research finds significant unwarranted variation in uptake and inequality in the number and rate of sight-testing in areas of deprivation versus areas of affluence:

1. Lane M, Lane V, Abbott J, Braithwaite T, Shah P, Denniston AK.  Multiple deprivation, vision loss, and ophthalmic disease in adults: global perspectives. Surv Ophthalmol 2018; 63(3):406-436.
2. Rathore M, Shweikh Y, Kelly SR, Crabb DP. Measures of multiple deprivation and visual field loss in glaucoma clinics in England: lessons from big data. Eye 2023: doi.org/10.1038/s41433-023-02567-z
3. Shickle D, Farragher TM. Geographical inequalities in uptake of NHS-funded eye examinations: small area analysis of Leeds, UK.  Journal of Public Health 2015; 37(2): 337-45.
4. Shickle D, Farragher TM, Davey CJ, Slade SV, Syrett J.  Geographical inequalities in uptake of NHS funded eye examinations: Poisson modelling of small-area data for Essex, UK.  Journal of Public Health 2017; 40: 171-179.
5. Shickle D, et al. Addressing inequalities in eye health with subsidies and increased fees for General Ophthalmic Services in socio-economically deprived communities: a sensitivity analysis. Public Health. 2015 Feb;129(2):131-7.
6. Harper RA, Hooper J, Fenerty CH, Roach J, Bowen M.^.  Deprivation and the location of primary care optometry services in England.  Eye 2024; 38 (4): 656-658.

It is important that primary eye care services in non-urban and more deprived areas are commissioned, and local residents supported to access both regular eye examinations and enhanced eye care services, to help prevent sight loss and improve vision and related wider health outcomes. Regulation should not be a barrier to this, and the GOC should consider how they can encourage registrants to work in these areas – perhaps through encouraging people from local communities to consider optometry as a career and be supported to enter the profession.

When it comes to eye health, prevention is key. Although the risk of developing many eye conditions such as cataracts and age-related macular degeneration (AMD) increases with age, worse eye health is also linked with indicators of inequality such as ethnicity and deprivation (Atlas of variation in risk factors and healthcare for vision in England, PHE, 2021) and the environment.

We support the GOC’s priorities aiming at reducing unwarranted variation in uptake of sight-testing in areas of deprivation versus areas of affluence. 

We recommend that the GOC considers how it can use its regulatory levers to help reduce barriers to people accessing services, via a proportionate and collaborative approach.

Yes.

We agree with this strategic objective, however, we are of the opinion that the protection of the public is the primary role of the GOC and should therefore be at the heart of all three objectives.

In Section 2 of the consultation document, the GOC identifies innovation and technology as being particularly relevant to its work, mentioning for example AI and remote eye care. Developments in technology and innovations in optics are increasingly influencing the delivery of eye care. However, there is little detail related to what the GOC plans to do in the priorities it has identified under this strategic objective. We would welcome more information on how the GOC plans to effectively support innovation and the use of new technologies, including AI. Appropriate and proportional regulation should support innovation while also providing patients and the public with the sufficient level of protection and trust they expect.

We welcome the GOC objective to support the professions to grow in size and develop their roles to meet more patient eye care needs. However, we note that the GOC fails to recognise that health systems do not consistently make use of the full skills and competencies already available within the eye care workforce. This prevents registrants from delivering a greater scope of clinical care and is a barrier to improving eye care services. Delivering more clinical eye care is not only about education and training but it is also about the opportunities to use these skills. Making full use of registrants’ core competencies, as well as higher qualifications and independent prescribing, can help reduce the reliance on local GPs, cut NHS waiting times and enable more people to live independently. 

We would welcome more detail regarding the GOC’s priority in taking a more strategic approach to post-registration qualifications. Optometrists who have Independent Prescribing (IP) and Higher Qualifications can offer a wider range of specialist eye care services and treatments for managing more patients closer to home. With continued pressures on hospital eye services, it is important to support the optometry workforce so that the skilled staff needed to deliver patient care can be recruited, trained and retained. However, the availability of clinical placements that are required to complete higher qualifications and IP is severely restricted and constitutes the greatest barrier to achieving them. If not addressed, this will continue to impact patient outcomes. A national approach to removing the bottlenecks in clinical placement opportunities is needed. We would recommend the GOC capitalises on the ETR to make use of supervisors and settings flexibility to open up more placement opportunities. This requires new ways of working and infrastructure to support multi-setting clinical experience, and accessibility.

We would also recommend the GOC adopts a proportionate approach, in collaboration with employers, to support registrants’ growth in roles, by better protecting the time needed to develop additional skills and competencies, and incentivising optometrists to contribute to the education of the next generation. We would also welcome the recognition by the GOC of the time and preparation requirements for supervision within a profession. 

Finally, we welcome the proposal to extend the regulation to all businesses carrying out restricted activities in the UK. While there is little evidence to explicitly suggest that patients have suffered as a result of the current absence of universal business regulation, there are potential new risks, including those arising from the introduction of new technologies and remote consultations, and businesses outside the UK providing services. We believe that, in order to provide adequate protections to patients and the public and to provide public reassurance and enhanced confidence in the profession, the GOC should adopt a more consistent and comprehensive system of effective business regulation.

Extending regulation to all businesses carrying out restricted activities also provides an opportunity for the GOC to further tackle the illegal supply of eye care services and optical appliances from both within the UK and abroad. In recent years, there has been an increase in online prescribing and dispensing of optical appliances. This raises issues concerning potential lack of appropriate supervision for the safe supply of contact lenses without specification verification, and spectacles supplied without ensuring the prescription is valid. This has always been a concern for the sector and registrants. We appreciate that the GOC does not have jurisdiction to take action on overseas sales, but we would like the GOC, as a minimum, to raise the issue with the appropriate local regulator/authority and have the powers to end the illegal practice occurring in the UK.

See our responses to Q3 and Q5. We believe optometrists should be better supported and incentivised to upskill and obtain the higher qualifications required to provide enhanced services. Furthermore, employers and local commissioners should be able to audit the wider skills of their local optometric workforce to ensure that the skills available are being effectively used to provide the best possible patient care.

We welcome the GOC priority to support workforce planning and patient choice by collecting better data about registrants and improving how the GOC publishes and shares this with others. However, we recommend the GOC to continue to maintain all existing registers, including student registration and specialty practitioners. Maintaining a record of higher and additional qualifications (HQs) on the GOC register is key for a number of reasons.   

The GOC register helps to maintain public trust in the profession.  If patients receive enhanced or specialised treatment or management by an optometrist in primary or secondary care, they need to be reassured that the individual is not only regulated but also has the specialist skills required to provide that enhanced service.  The requirement for these additional skills is set out in national guidance and frameworks including:

• Eye care workforce competency mapping carried out by NHS England for its National Eye Care Recovery and Transformation Project (NECRTP)
• The Ophthalmic Practitioner Training framework
• A national framework for designing glaucoma care pathways
• NICE’s guidelines for glaucoma diagnosis and management
• Welsh Government’s new WGOS contract for primary eye care services
• Enhanced primary eye care services are also provided by Health Boards in Scotland (NB the qualifications required by optometrists to deliver those services are decided locally).

Such services help to take pressure off ophthalmologists and hospital eye services, and so it is vital that the qualifications required to provide such services can be seen by members of the public.

The register is also widely used beyond members of the public. It is a useful and unique resource for national and regional workforce and service commissioners and planners. At a time when Hospital Eye Services are over capacity and patients are losing sight unnecessarily due to long wait times, it is imperative that more enhanced and shared care services can be commissioned and provided in the community. To enable this, commissioners need to know where optometrists (and dispensing opticians) with additional clinical skills are located, and the register provides an authoritative source to identify and confirm their qualifications.

We welcome the GOC’s priority to “support workforce planning and patient choice by collecting better data about registrants” and advocate that the registration data that GOC is planning to share more widely will be a complete and up-to-date picture of the number and location of registrants with all relevant core and additional qualifications. 

Yes.

See our response to Q3. An ageing population will lead to increased needs for eye care, and we believe that older patients may be disproportionally impacted if regulation becomes a barrier to them accessing services. Similarly, regulation needs to enable all children to have full access to eye care services, especially with the rising rates of myopia. 

Yes.

See our response to Q4. We recommend the GOC includes more emphasis on the need to ensure more inclusive and equal access to eye care services across the UK, considering geographical disparities and wealth inequalities, in addition to groups with protected characteristics.

Not sure.

We do not have enough information to inform a view.

However, we support the GOC ensuring they provide an equally high-quality service in the preferred language of their stakeholders. Providing a bilingual service to the public and professionals in Wales is in the interests of public safety.

We also recommend the GOC encourages and makes provision for its staff to learn or improve their Welsh, where it is directly related to their work.

Not sure.

We don't have enough information to answer this question.