Not sure.
Whilst we are in favour of this proposal in principle (especially to ensure safe and robust systems and processes, transparency and professionalism), the practicalities of appointing a Head of Optical Practice (HOP) could be challenging, and there could be many deterrents to individuals adopting the role.
While in large optical practices there are often multiple optometrists and dispensing opticians, in some practices there may be only one optometrist, or a practice may solely rely on locums to provide restricted functions. As such, there may not be a suitable individual to meet the requirements to assume the role of HOP. In these circumstances (particularly where the workforce may change daily), it is unclear on what basis a HOP would be identified and appointed.
Our Policy Advisory Panel and Board felt strongly that an additional set of standards (and responsibilities set out in legislation – Paragraph 127) and accountability placed upon the HOP, would be a significant deterrent to registrants wishing to take on the role. It was felt that optometrists and dispensing opticians are already, and robustly, held to account as individual registrants, and additional regulation would be unwelcome. The additional administrative requirements of being the HOP, along with potential additional training required (particularly for locums), could be a deterrent and could reduce their capacity for clinical work. Furthermore, an individual adopting the role of HOP would, understandably, expect additional remuneration from their employer, which if not available could also deter registrants from taking on the role.
We are also concerned that, in order to fulfil the requirement to have a HOP, an individual could be ‘forced’ into the role, and may not have the suitable skills, desire or experience to fulfil it effectively.
We would like to see clarity on what powers the GOC would have should no suitable registrant be available for the role of HOP, or if no employee wishes to take up the role in a particular optical business. More detail would also be needed on the systems, policies and culture referred to in this section of the consultation.
If an HOP model is not adopted, an alternative approach to business regulation could be to strengthen the GOC’s enforcement and inspection powers and to ensure that all registrants are responsible, accountable and confident to raise concerns.