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.