Question 1
Do you agree that creating a new national organisation to drive forward digital transformation and system change – beginning with the consolidation of NES and NSS into one organisation – is the right approach to deliver the ambitions set out in Scotland’s Population Health Framework and Service Renewal Framework?
Agree
The College of Optometrists supports, in principle, the establishment of a single national delivery body to lead digital transformation, workforce planning, and service improvement across Scotland’s health and social care system. Consolidating the functions of NES and NSS under a unified structure has the potential to enhance coordination, reduce duplication, and promote consistency of standards and practice at a national level.
For the reform to be effective, NHS Delivery must engage fully with primary and community care sectors, recognising that a substantial proportion of NHS-funded services are already delivered effectively outside hospital settings. Community optometry, alongside pharmacy, dentistry, and general practice, exemplifies how accessible, preventative services reduce secondary care demand and improve patient outcomes.
The College of Optometrists recommends the following:
- Inclusion of primary and community care perspectives in governance and strategic decision-making.
- Prioritisation of digital integration, enabling secure data exchange across primary, community and secondary care.
- Comprehensive workforce planning, encompassing all sectors of the health and social care workforce.
These measures will help NHS Delivery achieve national consistency while preserving accessibility, sustainability, and person-centred care.
The College would welcome the opportunity to support this work and to share evidence on how Primary- and Community-based optometric care supports prevention, early intervention, and improved patient experience.
Question 2 (a)
Do you agree with the proposed strategic objectives for the new organisation (driving innovation, delivering Once for Scotland services, and streamlining structures)?
Agree
The College agrees that focusing on innovation and streamlining organisational structures are appropriate strategic objectives for a national body tasked with system-wide transformation.
However, national coordination must enable, rather than replace, local service delivery. Achieving meaningful improvement relies on collaboration with primary and community care partners who have essential local knowledge.
NHS Delivery should therefore focus on facilitating shared systems, removing inefficiencies, and providing the digital and analytical infrastructure required for high-quality care.
Question 2 (b)
Should the organisation consider additional strategic objectives?
Agree
The College of Optometrists recommends the strategic objectives be expanded to fully reflect the Service Renewal and Population Health Frameworks. In particular:
- Workforce sustainability: Workforce planning and professional development should address the full range of health and care professions, including those in primary and community-based settings, to support recruitment, retention, and skills development.
- Digital inclusion and equity: Digital transformation should ensure equitable access to national systems for all contracted providers.
- Primary and community-based care and equity: Transformation should support care closer to home, prevention, early intervention, and consistent access to high-quality services across all regions and populations.
These enhancements would position NHS Delivery as a unifying, enabling body capable of strengthening system-wide delivery while maintaining local responsiveness.
Question 3
Are there services or functions currently delivered by other organisations (in addition to what NES and NSS already do) that should be delivered only by NHS Delivery to improve consistency and reduce duplication? This includes consideration of capabilities that are perhaps fragmented across multiple bodies, where a clear lead organisation should be identified.
Yes
NHS Delivery could improve national consistency and coordination by providing clearer leadership in certain cross-cutting areas that benefit the whole health and social care system. These include:
- Digital integration across all sectors, ensuring interoperability and secure data sharing.
- Workforce data, planning, and development, supporting a coherent national approach to capacity modelling, education, and professional progression.
- Quality improvement and learning infrastructure, facilitating consistent adoption of best practice across all health and care settings.
Centralising these functions - while maintaining strong professional engagement - would reduce duplication and enhance consistency across Scotland.
Question 4
What areas of national delivery could be improved by NHS Delivery to make services more efficient or better joined-up?
Redesigning how services are planned or improved
Making better use of data and digital tools
Strengthening workforce development and training
The College of Optometrists supports a more joined-up national approach in:
- Redesigning service planning and improvement processes
- Optimising the use of data and digital tools
- Strengthening workforce development and training
A national digital infrastructure that allows information to be shared securely and consistently would significantly improve continuity of care. We also highlight the current variation in information governance practices across health boards; for example, some contractors have access to systems such as Clinical Portal while others do not. A consistent, proportionate national framework is required.
In workforce development, NHS Delivery could enhance coordination across education providers, professional groups, and service leaders - ensuring consistent access to training and development opportunities.
A national approach could provide the oversight needed to ensure that clinical placements, supervision, and workforce pipeline development are effectively planned and appropriately funded across all professions, including those in primary and community eye care. While we recognised the significant limitations imposed on NHS Scotland’s funding a year ago, we were disappointed that Scottish optometrists’ access to Docet’s vital CPD and learning resources was withdrawn, and we hope the Scottish Government will reconsider and reverse this decision. Docet is an important national tool that supports optometrists to maintain and update their skills and knowledge, helping to ensure consistent, high-quality patient care. To achieve a more coherent and resilient system, clinical learning delivery and its associated funding must be coordinated and integrated at national level, recognising the shared responsibilities of both NHS Delivery and Higher and Further Education providers. This would help maintain consistent standards, protect access to high-quality learning resources, and ensure a stable, well-supported workforce.
Overall, a coherent national approach, supported by robust data, would enable both local and national improvement. In strengthening national workforce development, it is essential that the needs of pre-registration education are fully recognised within NHS Delivery’s remit. Currently, there is often an assumption that Universities are funded to deliver the entirety of training, including clinical placement learning, when in practice they are not resourced to manage or deliver clinical placement capacity.
Question 5
Are there any existing services, programmes, or functions currently delivered by NES or NSS that you believe could be stopped, scaled back, or redesigned (or handed over to another organisation) to better align with current priorities and system-wide impact?
No
The College of Optometrists does not believe that any major services currently delivered by NES or NSS should be discontinued at this stage. Both organisations currently deliver essential national functions underpinning service delivery across Scotland. At this early stage, we do not recommend discontinuing any major programmes.
Nonetheless, as NHS Delivery becomes operational, a structured review of existing programmes may be appropriate to ensure alignment with new priorities, reduce overlap, and ensure resources are used proportionately. Such a review should be collaborative and evidence-based to avoid unintended disruption or the discontinuation of essential services.
Question 6
Do you agree that NHS Delivery should lead the development of national digital capabilities (e.g. Electronic Health Records, digital inclusion, data architecture) for Scotland’s health and social care system?
Yes
The College of Optometrists agrees that NHS Delivery should take national responsibility for developing and coordinating digital capabilities across Scotland’s health and social care system. A unified national approach to digital infrastructure will help ensure consistency, interoperability, and improved efficiency across services.
A single, secure, interoperable Electronic Health Record that allows secure information flow across community, primary, and secondary care would represent a major step toward integrated, person-centred care. Engagement with professional bodies – including The College of Optometrists – will be essential to ensure that digital tools are clinically relevant and fit for real-world practice.
Question 7
Should NHS Delivery be tasked with improving data sharing, data access and interoperability across health and social care?
Yes
Improved data sharing and interoperability are central to modern, effective systems. NHS Delivery could provide the national leadership required to standardise governance, ensure consistent access, and facilitate safe information flow across organisational boundaries.
This would support continuity of care, reduce duplication, and strengthen population health insights. NHS Delivery should work closely with partners across primary and community eye care to ensure that data systems are designed around patient pathways that often span multiple providers and settings. Enabling the safe and efficient flow of data between local, regional, and national systems will be essential to delivering a truly integrated, person-centred approach to care.
Eye care increasingly relies on digital imaging, including fundus photography and OCT scans, which are used across primary and secondary care to support diagnosis, referral, and ongoing management. Currently, multiple proprietary systems, purchased by individual trusts or practices, often lack interoperability, leading to inefficiencies, repeated imaging, delays in diagnosis, and avoidable sight loss. Robust, interoperable IT connectivity is therefore essential to enable secure and timely sharing of both patient records and diagnostic images, improving collaborative working and patient outcomes.
The adoption of DICOM (Digital Imaging and Communications in Medicine), an internationally recognised standard for configuring, saving, viewing, and sharing clinical images, offers a practical solution. To address variability in implementation, The College of Optometrists and the Royal College of Ophthalmologists have established a cross-sector DICOM Task and Finish Group, including stakeholders from primary and secondary care, industry experts, and major imaging device manufacturers. The Group is defining a clinically relevant subset of DICOM tags to standardise patient identifiers, file formats, OCT B-Scans, ophthalmic photographs, visual field plots, and other key metadata.
By producing technical recommendations, real-world testing, and audit mechanisms, the initiative will support manufacturers, commissioners, and clinicians in delivering interoperable imaging systems. NHS Delivery’s leadership, alongside engagement with all other devolved nations, will be essential to ensure UK-wide adoption of these standards. Effective implementation will reduce unnecessary imaging, streamline care pathways, enhance patient experience, and enable earlier, more accurate diagnosis and treatment - ultimately helping to prevent avoidable sight loss.
Question 8
Do you believe NHS Delivery should be tasked with the lead national support role in innovation development & adoption, service redesign, change management, improvement, and commissioning?
Partially
The College of Optometrists supports NHS Delivery taking a coordinating role in innovation, change management, and system-wide improvement. National alignment and shared learning can accelerate adoption of best practice.
However, it will be important that this role complements, rather than replaces, the existing leadership and representative functions already held by professional and sector bodies. In areas such as primary and community optometry, policy development and service commissioning are already managed effectively through established national frameworks and direct engagement with the Scottish Government. These arrangements ensure professional input, accountability, and locally responsive delivery.
A supportive, enabling function - providing data, analytics, and improvement methodology - would add value without undermining well-functioning national systems.
Question 9
As NHS Delivery evolves in the longer term, what additional capabilities, functions or bodies should be considered for integration into a single national delivery capability that supports the aspirations of the Service Renewal Framework?
The College of Optometrists recognises that NHS Delivery will already bring together national digital, data, and workforce functions through the merger of NES and NSS. At this stage, further integration would be premature. The initial merger of NES and NSS represents a significant structural change, and its impact should first be evaluated.
Future consideration of additional consolidation should be evidence-led, undertaken through full engagement and consultation with professional and system partners, and based on demonstrable benefit to the wider health and social care system.
Question 10
What principles should guide decisions about future expansion of NHS Delivery’s remit and structure?
The College of Optometrists believes that any future expansion of NHS Delivery’s remit or structure should be guided by clear evidence, transparency, and engagement with those directly affected. Decisions should demonstrate measurable benefit to the health and social care system and be aligned with the ambitions of the Service Renewal Framework.
Future expansion should be guided by:
- Alignment with national strategy and improvement priorities.
- Clear system-wide benefit, supported by robust evidence.
- Co-design with stakeholders, including those in community and primary eye care.
- Avoidance of duplication or disruption to effective existing structures.
- Transparency, accountability, and legislative clarity in any proposed extension of remit.
These principles will help ensure proportionate, purposeful evolution of NHS Delivery over time.
Question 11
What mechanisms should be put in place to review and adapt NHS Delivery’s remit and performance post-launch?
The College of Optometrists supports the establishment of clear and transparent mechanisms to review NHS Delivery’s remit and performance once it is operational. Regular reviews will help ensure the organisation remains effective, proportionate, and responsive to the needs of health and social care.
We recommend:
- An early interim assessment within 6-12 months to identify initial implementation issues.
- A formal evaluation after 12-24 months to assess impact, value, and effectiveness.
- Independent audit or external evaluation to ensure transparency and objectivity.
- Ongoing feedback mechanisms, ensuring routine engagement with professionals and system partners.
Robust review structures will enable NHS Delivery to adapt, respond to emerging issues, and remain aligned with the needs of both professionals and the public.
The College of Optometrists fully supports the establishment of NHS Delivery as a national, enabling body. Its success will depend on collaboration with primary and community eye care, effective digital integration, workforce planning, and robust review mechanisms. By adhering to principles of alignment, evidence, and stakeholder engagement, NHS Delivery can strengthen Scotland’s health and social care system while preserving local responsiveness and high-quality, person-centred care.
The College looks forward to supporting the operational development of NHS Delivery and ensuring that primary and community-based eye care services, including optometry, remain integral to achieving national health priorities.