We've responded to the All-Party Parliamentary Health Group: Call for Evidence 2026
The Government’s 10-Year Health Plan is a crucial chance to expand and strengthen primary eye care by cutting hospital pressure and tackling inequalities in access across England.
Executive summary
The Government’s 10-Year Health Plan presents an unprecedented opportunity – one we must not miss. Achieving its ambitions requires a system-wide approach that makes best use of the existing primary eye care workforce, modernises commissioning, strengthens integration between primary and secondary care, and shifts focus and spending from hospital-based care to community services delivered through neighbourhood teams.
Many proposals in the Health Plan echo long-standing priorities championed by The College of Optometrists [1]. Primary eye care demonstrates how a highly accessible, prevention-focused service can improve patients’ outcomes, reduce health inequalities, and support long-term sustainability.
However, most citizens in England with low-risk eye conditions do not have access to primary care-based management and monitoring schemes. Despite the potential of primary eye care to alleviate the pressures on hospital eye services, inconsistent commissioning and fragmented approaches have led to a postcode lottery in service availability, perpetuating inequalities in access to care.
Delivering a sustainably accessible, equitable, and responsive primary eye care service will require:
- Optometrists commissioned to practise to the full extent of their training and competence, supported by appropriate workforce planning.
- Access to enhanced, shared care pathways based in primary eye care for all appropriate patients.
- Full utilisation of primary care optometry within neighbourhood health services, supporting prevention and early intervention.
- Routine collection and disaggregation of data on access, outcomes and patient experience to identify and address inequalities.
The College of Optometrists urges the APHG to include the following recommendations, which offer practical policy solutions to deliver lasting improvements in primary care:
- Prioritise sight loss prevention.
- Ensure primary care optometry is recognised as a core provider in commissioning and planning of neighbourhood health services.
- Raise public awareness of optometry-led first contact and specialist services to reduce pressure on GPs and A&E.
- Retain and expand proven, effective enhanced eye care pathways.
Our full response
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Reducing health inequalities and access barriers
Reducing health inequalities and access barriers
1. What patient-centred indicators (experience, continuity, clinical outcomes etc.) should define “good access” across:
a) General Practice,
b) Community Pharmacy,
c) Dentistry, and
d) Optometry?
Primary care optometry provides a national, neighbourhood-based primary care network that is well placed to contribute to the 10-Year Health Plan’s ambition to shift care closer to home, prevent avoidable sight loss, and improve population outcomes.
Key indicators of good access in optometry should include:
Timeliness and access to care:
- timely and equal access to routine eye examinations and community urgent eyecare services, supporting early intervention and prevention of avoidable sight loss
- clear and consistent communication of NHS entitlements, supporting informed patient choice and helping to address inequalities in uptake linked to socioeconomic status
- improved uptake of eye care among underserved and high-risk populations, including people with diabetes, people at high risk of glaucoma, people with learning disabilities, people from ethnic minority communities, and those living in areas of deprivation
- accessible services and reasonable adjustments, enabling people with disabilities, sensory impairment, cognitive impairment or language barriers to access care on an equal basis
Continuity and coordination of care
- continuity of care within primary care optometry, supporting long-term monitoring of eye health and management of low risk, chronic eye conditions
- integrated referral and care pathways between optometry, general practice and hospital eye services, enabling care to be delivered in the most appropriate setting and reducing unnecessary hospital attendances
- effective information sharing, supporting joined-up care, that is enabled by digital connectivity
Clinical quality and outcomes
- early detection and ongoing management of low-risk eye disease, including glaucoma, diabetic eye disease and age-related macular degeneration, contributing to prevention and improved long-term outcomes
- reduction in avoidable sight loss, including fewer late presentations to secondary care, supporting both patient outcomes and system sustainability
- safe and effective management of minor and urgent eye conditions in primary care, releasing capacity in hospital eye services and contributing to a more efficient use of NHS resources
Patient experience and confidence
- positive patient-reported experience, including feeling listened to, informed and involved in decisions about their care
- patient understanding of eye health, supporting self-care and appropriate future use of primary eye care services
- public confidence in primary care optometry as a first point of contact for eye health, supporting appropriate system navigation
2. What population groups remain under-represented or face significant barriers in accessing primary care services, why do these barriers occur and in which regions are they most prevalent? Please outline the contributing factors, together with any evidence of effective approaches that have improved access for these groups.
There are over 7,000 primary eye care practices across England [2], most of which are situated in the heart of neighbourhoods. However, access to primary eye care is not equally experienced across the population. Several groups face specific barriers that limit engagement, uptake, and outcomes, and these challenges are often compounded by geographic, socioeconomic, and structural factors.
- Socio-economic deprivation is associated with more advanced eye disease at diagnosis and lower uptake of services. People living in areas of higher deprivation [3] often experience financial concerns and misunderstandings about NHS eligibility for eye examinations and help with spectacle or contact lens costs. Competing life priorities, lower health literacy, and reduced engagement with healthcare services further restrict uptake. Optometry is frequently perceived as primarily a retail service rather than a core NHS primary care provision. Effective approaches to overcome these challenges include locally commissioned urgent and enhanced eye care services, which allow patients to access NHS-funded assessment and management for acute conditions within primary care optometry settings, while targeted communications on NHS eye care entitlements raise awareness and engagement.
Research [2] indicates that there are fewer optometric practices per 100,000 of population in the more deprived areas of England than affluent areas. There is also some evidence that more optometric practices have closed in the most deprived areas. This appears not to be the case in Scotland [4], where NHS-funded sight tests are available to the whole population, indicating that the Scottish funding model is a factor to improving service availability.
- People from ethnic minority communities may have lower awareness of eye health risks and the importance of routine eye examinations. Certain eye conditions (such as glaucoma) are more prevalent in these populations, yet uptake of eye care services is often lower, particularly in ethnically diverse urban areas such as London and the West Midlands [5]. Effective interventions include commissioned primary care optometry pathways that support early detection and referral, especially for conditions such as glaucoma and diabetic eye disease. Integrating optometry within wider long-term condition pathways enhances engagement and continuity of care. Using disaggregated population data informs commissioning and ensures services are responsive to community needs.
- People with learning disabilities [6] face barriers related to communication difficulties, sensory sensitivities, and anxiety in clinical environments. Limited availability of longer appointment times and other reasonable adjustments, combined with reliance on carers or support networks, may further restrict access. These challenges exist across all regions. Effective approaches include targeted NHS eye examination schemes delivered through primary care optometry and flexible appointment scheduling, including familiarisation visits and adapted testing approaches. In some areas of the country there have been efforts to improve access to eye care for people with learning disabilities, notably in Cheshire and Merseyside, Greater Manchester, Durham and Sutton. NHS England special schools eye care service has been running as a proof of concept since 2021 and is currently being expanded into all special school settings since 2024 [7].
- Older people, particularly those who are housebound or living in care settings, often encounter mobility issues, frailty, and transport challenges that limit access. Awareness of domiciliary eye care services is low, and fragmentation between health and social care provision further hinders engagement. Effective strategies include commissioned domiciliary eye care services for people unable to attend high street practices and enhanced eye care provision within care home settings to support routine monitoring and early detection of eye disease.
By addressing these barriers and implementing proven, targeted approaches, primary eye care can become more equitable, accessible, and responsive, helping to reduce health inequalities and improve outcomes across the population.
3. What single policy change would most immediately improve patients’ ability to be directed to the right primary care professional at their first point of contact, without the need for multiple appointments or repeated assessments and what evidence supports this?
Optometrists, given their accessibility, expertise, and integration into local health systems, are ideally placed to alleviate the pressures on GPs and A&E by delivering more care in primary care settings.
Establish optometrists as the first port of call
Primary care optometrists can help manage the growing demand for eye care in a sustainable way, reducing pressure on the hospital eye service and benefiting patients and the wider NHS. Many patients with eye conditions can be appropriately managed within primary care optometry and only referred to the hospital eye service if clinically necessary. They are best placed to provide prompt accurate assessment, diagnosis and management that would reduce GP and A&E appointments and avoid unnecessary referrals into secondary care. This will ensure patients can receive the right care they need quicker, closer to home, and will free up capacity in GP and NHS hospital services.
Optical practices are accessible, well-equipped, and staffed by skilled professionals, making them ideal as the first point of call for eye health concerns. They can complement Neighbourhood Health Centres without relocation. To achieve this, urgent primary eye care services must be consistently commissioned across England, with Independent Prescribing optometrists provided with FP10s so that they can write NHS prescriptions.
Services like the Minor Eye Conditions Service (MECS) and the Community Urgent Eyecare Service (CUES) allow urgent eye problems to be managed safely in primary care settings [8, 9]. Patient outcomes are excellent, and satisfaction is very high, as patients receive immediate specialist attention while reducing GP and A&E visits. These schemes require no additional qualifications beyond standard optometry training.
However, awareness of the role of optometrists is low within the general population. A recent survey by the General Optical Council [10] showed that only 33% of the adult population would speak to an optometrist first if they experienced a sudden eye problem. 28% said they would visit their GP and 14% said their pharmacist, but neither of these settings will have the equipment required for a thorough examination of the eye and to rule out more serious eye conditions that can cause vision loss. Awareness of the role of optometrists in providing urgent eye care was much higher in the other UK nations, where there is national provision of urgent primary eye care services. Commissioning of such services must therefore be accompanied by public awareness-raising programmes to ensure public know where to seek help. Similarly, staff in GP surgeries and pharmacists need to be made aware of where to signpost patients who present with an eye problem.
Case study: Optometry-led urgent and emergency eye care services
Optometry-led urgent and emergency eye care services – exemplified by the Minor Eye Conditions Service (MECS) and COVID-19/Community Urgent Eyecare Service (CUES) – enable patients with urgent ocular problems to be seen promptly by primary care optometrists in some pathways, with the necessary expertise and equipment. Evidence from across England shows that optometrists can safely manage the majority of acute eye cases in the community, delivering timely care while reducing unnecessary hospital visits [11,12]. Comprehensive evaluations of locally commissioned MECS and CUES schemes in England show that between 75% and 97% of acute eye cases are fully managed by optometrists in primary care, without need for onward referral [13 - 18].
Despite their proven benefits, MECS and CUES are not yet uniformly commissioned across all regions, and awareness among the public and some health professionals remains limited. By using the existing primary eye care workforce and scaling up these services, policymakers and commissioners can alleviate pressure on GPs and hospital eye departments, reduce health inequalities in eye care access, and improve patient safety and experience.
Commissioners across England must recognise and utilise the full core skills and competences of primary care optometrists, as well as those with independent prescribing and higher qualifications, to reduce unnecessary referrals to secondary care, and increase capacity to manage more patients with acute, urgent eye conditions outside of the hospital.
4. a) What practical steps are needed to ensure that digital booking, triage, and record-access systems (including the NHS App) deliver equitable access across GP, pharmacy, dentistry, and optometry services particularly for digitally excluded individuals, non-English speakers, older people, and visually impaired patients? Please include any case studies of effective practice.
Improving equitable digital access to eye care requires a multi-faceted approach that prioritises inclusivity, alternative access routes, targeted support for vulnerable populations, and seamless integration with primary care optometry services.
Targeted support for vulnerable groups
Specific interventions can address barriers faced by patients at risk of digital exclusion. Visually impaired individuals should have access to large-print instructions, screen-reader-compatible forms, and audio tutorials to navigate NHS digital tools. Digital platforms, including booking systems, triage, and record access, should meet recognised accessibility standards and support screen readers, magnification tools, high-contrast modes, and keyboard navigation. Multilingual support and intuitive, user-friendly interfaces with clear guidance for appointment booking and results retrieval are essential. By prioritising simplicity and accessibility, digital tools can serve a broader range of patients effectively.
Alternative access routes
Equitable access also requires maintaining non-digital options for patients unable or unwilling to use online systems. These include telephone booking, in-person appointments at local practices, and postal communication. Patients using these routes should receive the same level of triage and care as digitally engaged patients. Hybrid models must therefore maintain both digital and analogue channels, giving patients genuine choice without compromising service quality or speed.
Integration with primary care optometry services
Digital systems should facilitate direct appointment scheduling with primary care optometrists for both urgent and routine eye care. Digital triage should align with enhanced primary care optometry pathways, directing patients to the appropriate service at first contact and minimising unnecessary GP or hospital visits. Secure sharing of core health records across optometry, general practice, and secondary care is crucial to avoid duplication and ensure continuity of care. Currently, optometrists do not have access to shared patient care records.
4. b) What hybrid access models are required to ensure digital systems and the shift from analogue to digital do not contribute to a two-tier model of access?
See our response to Q4a above for detailed measures on digital inclusion, alternative access routes, and integration with optometry.
5. With the proposed abolition of 153 local Healthwatch across the country, as well as the national body Healthwatch England, what mechanisms should be put in place to ensure meaningful patient voice and feedback are embedded in the design, delivery, and evaluation of neighbourhood health hubs and wider access reforms? What specific metrics and accountability frameworks should be developed to monitor and proactively respond to regional disparities in access to primary care?
The College of Optometrists recognises that patient voice and feedback are fundamental to ensuring that primary care services, including optometry, are equitable, responsive and truly patient-centred. Embedding patient experience and outcomes into service design and evaluation is essential if Integrated Care Systems (ICSs) are to reduce health inequalities and improve access to care.
Collaboration with primary care optometry practices
Primary care optometry practices could play a vital role in capturing patient insight. Practices should be appropriately commissioned to collect patient-reported experience measures (PREMs) and patient-reported outcome measures (PROMs), with this information feeding directly into ICS-level evaluation and service planning.
This would ensure that the lived experiences of patients using optometry services are systematically captured and meaningfully incorporated into commissioning decisions. Importantly, this would allow ICSs to identify disparities in access, experience or outcomes across different population groups.
The benefits of data sharing in improving patient access and experience.
There is an urgent need to improve and streamline the collection, standardisation and sharing of eye care data across NHS systems. At present, there is no consistent national approach to what eye care data is collected, which metrics are most meaningful, or how that data should be used for performance monitoring, evaluation and research.
High-quality, consistent data across eye care pathways is essential. It enables commissioners to:
- understand local demand for services
- identify unmet need
- detect variation in utilisation
- monitor inequalities in access and outcomes
Without robust data, efforts to innovate in preventing sight loss and reducing avoidable vision impairment are significantly constrained.
An accurate understanding of population need is fundamental to planning effective and appropriate eye care services. Existing datasets within General Ophthalmic Services (GOS) payment systems and hospital clinical systems should be better collated, linked and analysed to inform ICS planning and commissioning. Over time, this should evolve into more comprehensive and higher-quality data collection at ICS level, capable of informing both local service redesign and national primary care policy.
Workforce intelligence and future planning
Alongside service utilisation data, there is an urgent need to understand current and future workforce requirements in eye care. Effective workforce planning is critical to meeting patient need, reducing inequalities and improving long-term outcomes.
As part of its Workforce Vision, The College of Optometrists, in partnership with sector stakeholders, has developed a UK Eye Care Data Hub [19]. This tool estimates:
- the size and distribution of the current eye care workforce
- prevalence and incidence of eye disease
- projected future demand trends
The Data Hub is designed to support commissioners and service planners in identifying future population eye care needs and optimising the existing workforce. It provides an evidence base to:
- align workforce supply with population demand
- identify priorities for education, training and professional development
- support the development of new and sustainable models of care
Together, improved patient feedback mechanisms, stronger data infrastructure and robust workforce intelligence will enable ICSs to design eye care services that are equitable, efficient and responsive to population need - while protecting and strengthening primary eye care pathways.
6. What lessons or evidence can be drawn from local or regional models that have successfully improved access for underserved populations and what policy measures should be included in the 10-Year Health Plan to embed these approaches and reduce health inequalities?
To ensure equitable access to eye care and reduce health inequalities, the following policy measures should be incorporated into the 10-Year Health Plan:
National commissioning of urgent and enhanced primary eye care services
Primary eye care services should be nationally commissioned to provide consistent, high-quality urgent and enhanced eye care across all regions. Enhanced services – urgent and minor eye conditions, cataract pre- and post-operative checks, and low risk glaucoma monitoring – exist in many locations and could be scaled nationally, reducing pressure on GPs and hospitals while improving patient convenience. This ensures timely access to appropriate eye care, reducing avoidable sight loss and relieving pressure on secondary services.
Formal inclusion of optometry in neighbourhood multidisciplinary teams
Optical practices are already located in the heart of neighbourhoods. Optometrists should be formally integrated into neighbourhood-level multidisciplinary teams. Their inclusion facilitates early detection, triage, and management of eye conditions within the community, improving care coordination and patient outcomes.
Consistent digital interoperability across primary care
Digital systems should be interoperable across all primary care settings, enabling secure sharing of patient eye health records between optometry, general practice, and secondary care. This reduces duplication of diagnostic tests, streamlines referrals, and ensures patients are directed to the right professional at first contact.
Targeted investment in underserved communities
Resources should be directed to communities with historically poor access to eye care. Investment should focus on infrastructure, community outreach, and support services to address socioeconomic, geographic, and digital barriers. See answer to Q1 for more detail.
Full integration of primary care optometrists into NHS workforce planning
Despite clear evidence of the valuable contribution primary care optometrists make to preserving the nation’s sight, the 2023 NHS Long Term Workforce Plan omitted specific provision for optometrists, representing a missed opportunity to leverage their expertise for the benefits of patients and the NHS. Commissioners and other health care professionals do not always have good knowledge of optometrists’ core knowledge, skills and competences.
We hope that the forthcoming 10-Year Workforce Plan will acknowledge, incorporate, and fully leverage the skills and competencies of optometrists to support integrated, cost-effective care and to facilitate the effective implementation of the 10-Year Health Plan for England.
- There are almost 15,000 optometrists in England, 80% of whom work in primary eye care settings [20]
- They are registered health professionals and a core pillar of NHS primary care, acting as the “front door” of the NHS for most patients with eye concerns [21]
- Primary care optometrists conduct over 13 million NHS sight tests annually through over 7,000 local practices equipped with modern diagnostic tools [2,22]
- They detect eye problems and general health conditions, provide vision assessments, prescribe corrective lenses, and manage a wide range of eye diseases
Optometrists are a critical part of the NHS workforce, bringing advanced clinical skills and patient-centred expertise to modern eye care. They represent a flexible and highly trained workforce capable of delivering safe, timely care in primary care settings. Commissioners should make full use of the optometric workforce to reduce unnecessary referrals to secondary care and to manage low-risk, long-term eye conditions outside hospital settings.
Through continuing professional development (CPD), higher qualifications and advanced clinical training, optometrists are increasingly managing a wider range of conditions in primary care. Shared care pathways with hospital eye services improve patient outcomes. Evidence from audits and service evaluations confirms that such initiatives enhance access, reduce waiting times, and maintain high-quality care [11 - 18]. Investing in optometry workforce development is essential to deliver sustainable, equitable, patient-centred care closer to home.
Recognising avoidable sight loss as a health inequality priority
Reducing avoidable sight loss should be explicitly recognised as a national health inequality priority. This can be achieved through both earlier detection (via better uptake of routine sight tests) and in moving care of patients with low-risk eye conditions from the hospital to primary care optometrists, freeing up hospital capacity for more complex or high-risk cases. Addressing disparities in eye care access, uptake and outcomes is critical to improving population health, supporting independent living, and reducing long-term societal and economic costs.
Harnessing digital transformation and system integration
Harnessing digital transformation and system integration
7. a) What are the key structural or digital barriers that primary care providers face in achieving joined-up working and system integration, and what policy changes, innovations, or practical solutions would best support seamless and collaborative primary care?
If primary eye care is to deliver its full potential within integrated care systems, digital inclusion must be treated as essential infrastructure, not optional enhancement. National standards for electronic records and imaging, universal two-way connectivity, funded integration of optical practices into NHS digital architecture, and a coordinated approach to referral and image-sharing platforms are practical, deliverable solutions. With the right policy support and investment, optometrists can help deliver earlier diagnosis, safer shared care, reduced hospital demand and improved patient experience.
Digital/IT connectivity is a key enabler to transform eye care service delivery, but a major barrier to achieving this is a lack of IT connectivity provided to primary eye care practices. Primary eye care remains structurally and digitally disconnected from the wider health system. Optometrists are frequently excluded from core NHS digital infrastructure, lacking access to NHS.net, shared care records and interoperable referral systems. This is a fundamental barrier to system integration, multidisciplinary collaboration, and delivery of the Government’s ambitions for prevention, community-based care and digital transformation.
Optometry is well placed to lead digital transformation. Tools such as Optical Coherence Tomography (OCT) enhance diagnostic accuracy, while collaborations like Moorfields Eye Hospital and DeepMind Health show AI’s potential for early disease detection [23, 24].
However, fragmented, costly and complex NHS IT systems create barriers to making the most of all that primary eye care has to offer.
Digital connectivity must be improved to speed up diagnosis and treatment
Good patient care requires effective communication between and within primary, community and secondary care to support improved patient experience and outcomes, to enable effective referrals and to facilitate shared care provision and two-way communication. Poor connectivity delays diagnosis and treatment, increasing unnecessary costs for the NHS, and limits multidisciplinary collaboration.
There is an urgent need for a joined-up, national approach to electronic referral systems across eye care. This must be implemented in a planned and systematic fashion with appropriate levels of funding to ensure roll-out is safe and effective and does not put patient safety at risk. These risks include potential digital isolation of patients and practitioners and lack of safety-netting – which is essential in case of IT failure.
The College of Optometrists, in partnership with The Royal College of Ophthalmologists and other key organisations, has raised its growing concerns around inconsistent and incompatible digital systems across primary, secondary, NHS, and independent care settings. Without a coordinated approach, efforts to deliver integrated eye care and implement the three shifts of the 10 Year Health Plan for England will continue to face significant barriers. We call for national standards in electronic health records (EHRs) used in eye care [25] that support continuity of care across settings.
There are some electronic eye-care referral systems (EeRS) in various regions that link primary, community and hospital eye-care services. However, it is unclear how these will link into the national electronic referral system (eRS) programme that NHS England is developing.
Upgrading core IT systems and data infrastructure is vital. The College of Optometrists calls for NHS-funded integration of optical practices into NHS digital systems. To fully realise the benefits of digital transformation, we recommend:
- investment in universal IT connectivity between optometry, GP, and hospital systems
- national rollout of e-referral and image-sharing platforms
- access to shared care records for all primary care optometrists
Imaging standardisation
Clinical images are increasingly offered in primary and community eye care settings to detect and monitor eye disease. They can also help improve referrals to secondary care, reducing unnecessary appointments via advice and guidance pathways.
However, multiple platforms are used across hospitals and optical practices, and the absence of agreed imaging standards means images often cannot be shared. This leads to patients undergoing repeat imaging following referral, delays in diagnosis, and a higher risk of preventable sight loss, generating unnecessary costs for the NHS.
To address this, an Eye Care Interoperability Steering Group has been established to accelerate the adoption of consistent imaging standards across the eye care sector so diagnostic images can be saved, viewed and shared seamlessly and consistently between all primary and secondary eye care practices [26]. Co-chaired by The College of Optometrists and the Royal College of Ophthalmologists, with work funded by the Optical Suppliers Association, the group will be informed by representatives from across the eye care sector and major ophthalmic imaging device manufacturers.
The work will inform investment, training and device procurement decisions across the eye care sector, leading to better patient experience and clinical outcomes in future.
Adoption of these standards by NHS England and device manufacturers will improve collaborative working and enable faster, more accurate diagnosis and treatment decisions. Improving digital image standardisation is critical for ensuring more eye care can be delivered at the right place and at the right time for patients, to prevent delays that lead to avoidable sight loss.
7. b) What are the most significant barriers to interoperability across NHS digital systems and how can suppliers be better supported or required to enable real-time data exchange across all primary care providers?
Delivering integrated, patient-centred care depends on the ability of primary care providers to exchange clinical information securely and in real time. For eye care in particular — where imaging, diagnostics and shared decision-making are central — interoperability is critical.
To fully realise the benefits of digital transformation, we recommend:
- investment in universal IT connectivity between optometry, GP, and hospital systems
- national rollout of e-referral and image-sharing platforms
- access to shared care records for all primary care optometrists
To enable safe, efficient and coordinated care across primary care services, the following measures are also required:
Mandated adoption of national interoperability standards
A consistent national approach to interoperability must be established. All primary care digital system suppliers should be required to implement DICOM-approved standards for ophthalmic imaging (once agreed), to enable structured and consistent data exchange.
Interoperability should be embedded as a core requirement within system accreditation and procurement processes. New and updated digital platforms must demonstrate compliance with real-time data exchange standards as a condition of approval. Without mandated standards, variation will persist, limiting integration and undermining patient care.
Financial and technical support for implementation
Mandating standards must be accompanied by practical support. Smaller suppliers and primary care optometry systems may face resource and infrastructure constraints in implementing interoperability requirements. Targeted funding, technical guidance and centralised implementation support should therefore be provided to ensure equitable compliance. Shared development resources or open-source frameworks could further reduce duplication, lower costs and accelerate progress across the sector.
8. How should transparency, safety, and public trust be maintained when deploying AI or virtual tools in primary care, and what governance and regulatory safeguards are required?
The College of Optometrists welcomes the recognition of the impact of technology on the NHS workforce and the delivery of care, including the use of artificial intelligence (AI) in the 10-Year Health Plan. As technology advances, optometrists are increasingly able to deliver more care in new ways. Advances in diagnostics and treatments will enable earlier detection, better disease management, and improved outcomes for patients. Digital transformation – including telemedicine, AI, and remote monitoring – will further support accessible, primary-based eye care, but investment is required to overcome barriers to implementation.
AI and virtual tools have the potential to support earlier detection, improved triage, and more efficient use of the primary care workforce, including in primary care optometry. AI-enabled tools are increasingly being explored for image analysis, risk stratification, triage support, and workflow optimisation. However, to ensure that these technologies contribute to equitable, safe and sustainable care, transparency, robust governance and public trust must be embedded from the outset.
The College of Optometrists has taken proactive steps to ensure that optometrists are equipped to use AI and technology safely and effectively in clinical practice through the publication of its Interim Position on the Use of Artificial Intelligence in Eye Care [27]. This guidance recognises that AI tools, including AI as a Medical Device (AIaMD), decision-support systems, and ambient voice technologies, are already entering clinical workflows. The guidance makes clear that AI outputs must be critically appraised within the full clinical context and that AI must not exacerbate inequalities through biased data or exclusionary training sets. The guidance emphasises data governance, patient consent, cybersecurity, record keeping, and transparency in patient communication as well as the need for good AI literacy amongst the clinical workforce. Consideration should also be given to the environmental and resource implications of AI technologies.
Clear lines of clinical accountability must be maintained, with clinicians retaining responsibility for all care decisions.
Workforce training is essential. Clinicians need strong AI literacy to understand when AI is being used, how it functions, and its benefits, risks and limitations. Confidence in critically evaluating AI tools is key to safe and effective use. The College’s CPD Hub includes AI-focused courses such as Artificial Intelligence in Optometry. These accredited programmes support safe and effective integration of technology into practice.
Research
The College has set up an AI Expert Advisory Group to bring together eye care professionals, researchers, AI experts, patient representatives, and sector bodies. This group has contributed to a consensus exercise that will identify further requirements for training, regulation, guidance, integration, and ethical implementation. Results and supportive guidance will be published in 2026.
9. a) What national-level infrastructure, policy reforms or regulatory levers are required to ensure the implementation of shared patient records across GP, pharmacy, dentistry, and optometry services? Which governance bodies should oversee data sharing and record access?
The effective implementation of shared patient records across primary care is a key enabler of the Government’s 10-Year Health Plan, supporting integrated, neighbourhood-based care, first-contact resolution, and prevention. Optometry must be embedded within shared digital systems on the same footing as other primary care providers to ensure integrated, patient-centred care.
National-level infrastructure requirements
A unified, standards-based shared care record architecture is essential. A nationally mandated framework should explicitly include primary care optometry alongside general practice, pharmacy and dentistry. The architecture must support real-time, two-way data exchange, enabling optometrists not only to access clinically relevant information but also to directly update with diagnostic findings, treatment decisions and referral information. Interoperability must reflect the increasing clinical and diagnostic role of optometry within primary care pathways.
Mandatory adoption of national data and messaging standards across all primary care systems is critical. This includes DICOM for ophthalmic imaging such as OCT and retinal imaging. Without DICOM-compliant infrastructure, imaging data cannot be reliably or safely shared across care settings, undermining both clinical integration and patient safety, and also leading to duplication of tests if images cannot be read.
Interoperability must be designed into national infrastructure rather than dependent on inconsistent local integration efforts.
Policy reforms and regulatory levers
Infrastructure alone is insufficient without aligned policy and regulatory frameworks. Interoperability should be a mandatory condition of NHS system approval, procurement and contract renewal. This requirement should apply equally to clinical record systems, imaging platforms and AI-enabled diagnostic tools. Embedding interoperability as a regulatory requirement ensures that digital and AI systems operate within integrated, auditable care pathways rather than as standalone technologies.
Commissioning and contractual frameworks must explicitly support optometry’s inclusion in data sharing and record access systems. Optometry contributes significantly to urgent eye care, long-term condition monitoring and prevention. Exclusion from shared records undermines continuity and patient-centred care. Commissioning levers should therefore incentivise and support optometry full participation.
Governance and oversight
At national level, NHS digital and data governance bodies should oversee shared care record standards, including interoperability compliance, clinical safety assurance, and monitoring of data quality and equity impacts. National oversight provides consistency and assurance that digital integration supports patient safety and reduces, rather than exacerbates, inequalities.
At ICS level, local implementation and assurance should ensure that all primary care providers — including optometry — are connected to shared records. ICS governance arrangements should ensure proper access controls, high-quality complete data, and the safe use of imaging and AI-enabled pathways.
Clinical and professional input is vital at every level. Governance structures should include representation from primary care optometry to ensure that shared records reflect real-world clinical practice and support the safe use of advanced imaging and AI-enabled tools. This professional involvement reinforces accountability, strengthens system design and maintains public trust.
7. b) Which regions or Integrated Care Systems (ICSs) are furthest ahead in developing shared primary care records and what common enablers and pitfalls should inform national scaling?
Progress in developing shared primary care records varies across England. A number of ICSs have extended access to shared care records beyond general practice to primary eye care services.
The following examples highlight how digital innovation has enhanced patient care and service delivery in eye health. These initiatives have led to demonstrable improvements in patient outcomes and system efficiency by shifting care closer to home, reducing demand on hospital services, and enabling more timely interventions.
Integrated digital referral and imaging pathways
Structured digital referral systems allow optometrists to submit comprehensive clinical information including patient history, visual acuity and imaging directly to ophthalmology departments. These systems improve triage and advice and guidance, reducing unnecessary hospital referrals, enabling optometrist-led care closer to home. While they are not case studies on full access to electronic shared care records, they illustrate how digital connectivity can be scaled.
The NHS Gloucestershire Community Ophthalmic Link, launched in 2022, demonstrates how digital technology supports shifting care from hospital to community. This ICB-commissioned software is a direct link into the ophthalmology records of the hospitals within Gloucestershire Hospitals NHS Foundation Trust. It allows optometrists in the community to see any imaging that a patient has had done. Optometrists also have access to GP letters, and anything else that is electronically stored. The scheme:
- involves 66 optometry practices and 250 clinicians
- prevented 998 hospital referrals
- reduced hospital eye care waiting lists by 14%
- managed 264 patients entirely in primary care
- improved the quality of 859 referrals
- recorded 3,303 instances of better patient education
- delivered estimated annual savings of £250,000 for the NHS [28]
It received national recognition for its impact [29] and cited in the 10-Year Health Plan for England as a best practice example [30].
In NHS Fife between 2020 and 2022, a digitally enabled pathway for 2,276 glaucoma patients:
- resulted in 714 patients fully managed in primary care
- 482 patients discharged to routine primary eye care-based monitoring under the General Ophthalmic Services contract
- fewer than half required ongoing hospital follow-up
- reduced hospital workload while maintaining clinical safety [31]
Successful national scaling requires interoperable digital infrastructure, clinician engagement, high-quality data, and robust governance, while avoiding fragmented systems, inequitable access, and overreliance on technology.
10. How adaptable are neighbourhood digital models to rural, coastal, or highly deprived communities and what modifications are required to ensure equitable digital access?
Optical practices are critical to delivering neighbourhood digital eye care, particularly in rural, coastal, and socioeconomically deprived communities. For many people, primary care optometrists are their only regular healthcare contact.
Optometrist practices can offer extended opening hours, staffed by highly trained clinicians and equipped with appropriate tools to provide high quality imaging. By establishing primary care optometrists as the first point of call for eye health concerns, and commissioning and rolling-out enhanced eye care pathways across England, optical practices can play a central role in ensuring that services remain accessible, inclusive, and responsive to local needs. They can act as local hubs for clinical information, imaging, digital triage, and referral management, and managing low risk patients. This enables high-quality care to reach patients in rural, coastal, and socioeconomically deprived communities, reducing unnecessary travel to hospital eye services and supporting timely treatment.
Better use of the existing primary eye care estate, facilities and imaging can mean that patients requiring regular tests to inform their hospital care could access these at their local optometrist practice, which is more likely to be within their local community. Equipping practices with reliable digital connectivity and interoperable systems is essential to achieve this. Access to subsidised imaging devices or portable diagnostic tools can expand high-quality care services and specialist expertise in these communities.
Adaptability in diverse communities
Optical practices can tailor digital pathways to local populations through flexible service delivery. Home visits, extended hours and remote consultations ensure access where travel or infrastructure is limited.
Equity and patient engagement
Optical teams play a key role in reducing health inequalities. By identifying patients at risk of digital exclusion, offering alternative access options, and providing community-care, practices ensure that rural, coastal, and deprived populations are not left behind.
Prevention and public health impact
Optical practices can integrate into broader neighbourhood digital networks alongside GPs, pharmacies, and social care services. Beyond eye health, they contribute to public health by delivering lifestyle advice, health checks, and signposting for systemic conditions. This positions optical practices as frontline preventive care providers, supporting broader NHS goals around prevention, early detection, and reducing avoidable health inequalities.
See also our answer to Q4b on supporting digital access.
11. As the NHS App expands to include more sensitive clinical information and referral tools, what governance, consent, and accountability mechanisms are needed to protect patient trust, particularly where AI or third-party systems are involved?
See responses to Q8 for AI governance, and Q7/Q9 for digital systems and shared records.
12. a) What digital exclusion and digital literacy barriers are patients encountering as primary care services become increasingly digital?
See our responses to Q2 and Q4a.
12. b) What national policy frameworks, funding mechanisms, accountability arrangements, or system-wide interventions are needed to address these barriers and ensure that digital transformation enhances rather than restricts equitable access to primary care services?
See our responses to Q2, Q3, Q4a, Q4b, Q6, Q7, Q8 and Q9.
Securing long-term sustainability in primary care funding
Securing long-term sustainability in primary care funding
13. a) What are the main funding challenges affecting primary care service provision, including issues of allocation, timing, and stability. How do these challenges affect quality of service provision and workforce capacity?
Primary eye care is a cornerstone of community-based health services, providing NHS sight testing, early detection of ocular and systemic disease, urgent eye care, and monitoring of long-term conditions. These services prevent avoidable sight loss and reduce pressure on hospital ophthalmology services. However, funding challenges are limiting the sector’s ability to provide more high-quality care, expand NHS capacity, and fully utilise its skilled workforce.
An ageing population, increasing prevalence of long-term eye conditions, and growing clinical complexity are increasing workload in primary eye care. Yet General Ophthalmic Services (GOS) sight test fees in England have not matched inflation and do not cover the actual costs of delivering eye examinations. This underinvestment constrains reinvestment in workforce, premises, equipment, and digital infrastructure and risks practices closing in more deprived areas, where the population is less likely to afford private eye care.
Funding instability further exacerbates the problem. Enhanced eye care services - including urgent eye care (CUES/MECS), glaucoma monitoring, and post-operative cataract care - are frequently commissioned by ICBs on short-term or pilot bases rather than as permanent, universal services. While these services are clinically effective, uncertainty about future funding limits long-term planning, workforce recruitment, and capital investment. Practices cannot safely expand NHS capacity when service continuity is unclear. Regional variation in commissioning also creates a postcode lottery, with patients in some areas benefiting from community-based NHS pathways while others must rely on overstretched hospitals or have to pay for private care.
Impact on equitable access to enhanced primary care services across England
The lack of universal commissioning and adequate funding for Community Urgent Eye Care Services (CUES) and Minor Eye Conditions Services (MECS) is creating significant inequity in access to primary eye care across England. Currently available in only 73% of regions [32], these services are subject to a postcode lottery, meaning patients’ access to timely, community-based urgent eye care depends on where they live. This contrasts with universal provision of urgent primary eye care services in Scotland, Wales and Northern Ireland.
Failure to secure sustainable funding threatens further widening of regional disparities, particularly in the context of the Westminster government’s 10-year health plan. We must rebalance NHS expenditure to correct historic underinvestment in primary eye care. Without sustainable funding, patients will continue to experience avoidable harm due to over-reliance on inefficient hospital models leading to long waiting times and avoidable sight loss. Funding must cover the actual costs of the NHS eye testing service and be made available to commission enhanced services and the IT solutions required to enable practices to meet local needs effectively.
13. b) What opportunities exist to use current resources more efficiently across the primary care sectors and what are the likely impacts of such changes? Please include case studies using the template provided and outline any system-level adjustments required.
Significant efficiencies could be achieved by shifting more care from hospital and GP settings into primary care optometry.
Optometrists working in primary care are well-placed to provide routine, enhanced and shared eye care services closer to home, and to reduce the backlog of delayed outpatient appointments, without additional training. With higher qualifications, they can offer an even wider range of specialist eye care services and treatments for managing patients with more complex needs without referral to secondary care. Likewise, those working in secondary care can provide specialised eye care and treatments that increase the capacity of outpatient clinics.
In order to improve eye care services and patient outcomes, we believe that health services must utilise the full core skills and competences of optometrists (both in primary and secondary care). Services which make full use of the higher and independent prescribing qualifications that many optometrists hold must also be commissioned and funded.
Patients with eye symptoms typically visit their GPs, yet most GPs lack specialist ophthalmic training and equipment. Ophthalmology has the most outpatient appointments within the NHS, accounting for nearly 9% of all outpatient appointments in England, where long waiting times can lead to avoidable sight loss. It’s estimated that the national roll-out of community minor and urgent eye care services in England can reduce hospital eye services appointments by at least 200,000 per year and over 400,000 GP appointments per year [8], while also realising financial benefits to the NHS. Up to 70% of eye-related A&E cases could be managed in primary care by optometrists, providing a significant opportunity to shift care closer to home [8].
For these services to succeed and be sustainable, they must be appropriately funded and resourced. Tariffs should reflect the complexity of urgent eye examinations and include funded follow-up appointments where necessary, which has been shown to improve outcomes and reduce onward referrals. NHS commissioners should also enable optometrists to prescribe treatments by providing FP10 pads, preventing the need for GP involvement.
13. c) What changes to GP funding models are needed to improve patient access to primary care, and how can additional investment be targeted, structured, and monitored to ensure it delivers measurable improvements in access, capacity, and outcomes for patients?
N/A
13. d) Aside from funding, what system-wide reforms or policy levers would have the greatest impact on improving access to primary care and which should be prioritised?
The most impactful reforms and policy levers include:
- national commissioning of urgent and enhanced eye care pathways – see our responses to Q3 and Q6
- shared patient records between all primary care professions, including optometry, and secondary care - see our responses to Q7a and Q7b
- interoperable digital imaging and digital referral systems - see our responses to Q7a, Q7b and Q9b
- supporting upskilling of the optometric workforce through providing funding for higher qualifications and independent prescribing and reducing barriers to optometrists accessing clinical placements to achieve these qualifications
- stronger prevention focus, including sight loss prevention (though raising awareness of the importance of regular sight tests, improved GOS funding and moving the care of low-risk patients from hospitals to primary eye care) as a health inequality priority
Commissioning & contract reform
Commissioning & contract reform
14. a) The inquiry has heard concerns about ‘competitive silos’ across primary care. What commissioning approaches would most effectively promote collaboration, shared triage, and multidisciplinary working across GP, pharmacy, dentistry, and optometry services, rather than competition for activity and income? Please outline any evidence or examples that demonstrate how commissioning reform could support more integrated, patient-centred models of care.
Commissioning that aligns incentives, provides multi-year stability, invests in digital infrastructure, and supports shared training enables primary care professionals to collaborate effectively. Primary eye care already has the infrastructure and expertise to deliver more care in the community, prevent avoidable hospital attendance, and improve patient outcomes. By encouraging shared responsibility rather than activity retention, GP, pharmacy, dentistry, and optometry services can deliver faster, more coordinated, and cost-effective care.
Outcomes-focused, pathway-based commissioning
Commissioning should move beyond isolated service specifications to whole-pathway models spanning primary and secondary care. For example, urgent eye care, long-term eye condition monitoring, and preventative services should be commissioned as integrated pathways with clear roles for each profession in every setting. Shared outcome measures – such as reduced GP and hospital referrals, shorter waiting times, and earlier diagnosis – would encourage collaboration.
Pathway-based commissioning enables optometry to contribute fully to both urgent and chronic eye care, ensuring patients are seen by the most appropriate professional at first contact and reducing unnecessary GP and secondary care demand. Evidence from locally commissioned urgent eye care schemes demonstrates that when optometrists are integrated into referral pathways, hospital attendances for eye conditions fall and patient experience improves [8].
Blended and aligned payment mechanisms
Activity-only payment models can incentivise retention of patients or services within a single provider, undermining collaboration. Blended approaches, combining core funding, pathway-based payments and outcome-based incentives would support joint working. Activity-only payments can incentivise retention of patients within a single provider. A single payment for all services related to a patient’s care episode or condition is an incentive for providers to deliver care efficiently and collaboratively, reducing duplication and unnecessary hospital use. Pooling or shared budgets supports innovation and reduces duplication in care planning.
Work by the NHS North West London Integrated Care System toolkit notes that pooled budgets can create flexibility for providers to invest in services that best meet local needs, support innovation and reduce duplication - for example by funding a multidisciplinary team instead of separate service lines for each provider. Pooled funds have been associated with closer working relationships and potential efficiencies in how services are delivered across health and social care [33]. NHS England Strategic Commissioning Framework published in November 2025 [34] rightly promotes outcomes‑based payments to support integrated care and improve population health.
Integrated digital infrastructure
See our responses to Q7a, Q7b, Q9a and Q9b. Effective multidisciplinary working depends on interoperable IT systems. Commissioning must fund shared digital platforms that allow:
- two-way referral and feedback between professions
- read-write access to relevant elements of the patient record
- shared care plans and structured communication
Without digital integration, collaboration relies on informal, manual processes that are inefficient and delay patient care.
Primary and community care representation at ICB level
There is a lack of representation and effective involvement of the full range of primary and community healthcare professions, including optometrists, at ICB level to inform commissioning decisions. This is another major barrier preventing improved integration between primary and secondary eye care. As the Fuller stocktake report recognised, a major delivery challenge for ICBs is how to actively involve primary care in strategic service planning [35]. All primary care providers, including optometrists, should be directly involved in the design, delivery and leadership of more integrated services for local populations.
Having optometric representation would ensure all patients’ needs are considered, eye health is effectively included in general health decisions and improve opportunities for more integrated and mutually supportive services. It would also ensure the entire eye care workforce is recognised and their skills effectively used to increase capacity across systems.
Workforce development
Building local primary care networks, where shared learning can take place, should also help to build trust, understanding and knowledge across primary care professions. This can improve relationships between professionals and support shared patient care and signposting or referral to the most appropriate primary care profession. In England, optometrists are not generally included in Primary Care Networks.
14. b) How do current GP, dentistry, pharmacy, and optometry contracts encourage or inhibit expansion of NHS care particularly in underserved communities and what changes would mitigate postcode lottery access disparities?
In optometry, activity-based and under-valued core NHS contracts fail to reflect the true complexity, workload, or cost of delivering modern eye care. GOS sight test fees in England have not consistently kept pace with inflation or rising clinical expectations. Where reimbursement falls below delivery cost, practices must cross-subsidise NHS activity or limit service expansion to remain viable. This disproportionately affects underserved communities where fewer patients will be able to afford private eye care. The result can be reduced availability of NHS appointments, difficulty recruiting or retaining professionals, and slower growth in capacity where it is most needed. Short-term and locally variable commissioning further exacerbates inequity, if services are not maintained.
Enhanced eye care services - including urgent eye care, glaucoma monitoring, and post-operative cataract care - are not consistently commissioned across England. This creates a postcode lottery, where patient access depends on local commissioning priorities rather than clinical need. Short-term funding also discourages investment in the required workforce, premises, diagnostic equipment and digital infrastructure, particularly in areas with tighter financial margins.
- Core contracts must reflect the true cost of delivering safe, modern care. In optometry, appropriate uplift of NHS sight test fees would support expansion of capacity. Across primary eye care, funding formulae should better weight deprivation, rurality, and unmet need.
- Enhanced services should be commissioned to consistent national specifications, removing unnecessary barriers such as accreditation for core competences, with local flexibility to meet population needs. This approach reduces unwarranted regional variation while ensuring baseline equity.
- Multi-year commissioning provides stability, enabling investment in workforce, premises, and digital infrastructure. Stability is particularly critical in underserved communities, where financial resilience is lower.
- Capital grants, transformation funding, workforce incentives, and support for mobile or domiciliary services can help expand NHS provision where demand is highest and health inequalities are greatest.
- Aligning contracts at neighbourhood level enables coordinated planning across GP, pharmacy, dentistry, and optometry. Joint commissioning ensures gaps in one sector do not exacerbate pressure elsewhere and facilitates shared pathways for patients.
- Interoperable IT systems and shared referral platforms reduce fragmentation and improve navigation for patients. Remote consultations and digital triage can enhance access in underserved areas, enabling optometrists and other primary care providers to deliver assessment, monitoring, and follow-up efficiently without requiring patients to travel long distances.
Primary eye care practices are already embedded in communities and well placed to expand high-street and domiciliary services where need is greatest. With sustainable funding, coordinated and effective commissioning, and digital integration - including remote care - NHS services can reach more patients equitably, reduce postcode lottery disparities, and prevent avoidable harm caused by delayed or inaccessible care.
15. Optometry and community pharmacy have one of the most geographically accessible networks in primary care. What lessons from its access and delivery model could be applied across other primary care sectors to improve integration, prevention, and first-contact care?
Optometry delivers widespread local access through highly accessible high-street practices with extended opening hours, reducing travel barriers and improving timely access to care. There is also provision of domiciliary eye care direct to people’s homes and care homes.
Embedding primary eye care services formally within local care pathways and commissioning skilled clinicians close to where people live and work would extend reach, particularly in underserved and rural communities.
Optometrists undertake routine sight testing, manage urgent eye conditions, and monitor long-term eye disease, working closely with general practice and hospital eye services. Clearly establishing optometrists as first point of care for eye conditions, supported by structured referral system and effective communication channels, would improve patient flow and reduce unnecessary secondary care attendance. When patients are directed to the most appropriate professional at first contact, system efficiency improves and duplication of assessment is reduced.
Prevention is embedded within routine optometric care. Sight tests enable early detection of ocular conditions such as glaucoma and macular degeneration, as well as systemic disease including diabetes and hypertension. Delivering preventative assessment during community-based encounters reduces downstream demand on hospitals and supports earlier intervention, improving long-term population health outcomes.
Optometry also demonstrates the value of responsive first-contact services. Practices can often see patients quickly for low-complexity or urgent eye problems, preventing avoidable GP appointments or hospital visits [8]. This model of rapid-access, condition-specific first contact could be applied more broadly across primary eye care to relieve pressure on general practice and emergency services.
Optometry illustrates effective deployment of highly trained clinicians in community settings. Optometrists are increasingly gaining higher qualifications in enhanced clinical roles, including independent prescribing and advanced disease management. Commissioning models that enable clinicians to operate at full scope maximise workforce capability and strengthen primary care resilience.
Digital infrastructure would further support integration. Wider adoption of interoperable digital systems across primary and secondary care would enhance communication, shared decision-making, and continuity of care, while reducing administrative burden and duplication.
The optometry model demonstrates how accessible community networks, clear first-contact roles, embedded prevention, full utilisation of clinical skills, and digital integration can strengthen primary care. Applying these principles more consistently across the eye care sector would support more integrated, efficient, and patient-centred services.
However, the existing network of practices should not be taken for granted. The continual under-funding of NHS sight tests and patchy commissioning of extended services risks practices closing, or being unable to provide NHS care in order to remain viable, which would reduce access for people in the most vulnerable communities.
16. a) How can we integrate dental services more effectively with other primary care providers to support holistic patient care? Would co-location in hubs or improved GP–dentistry referral pathways support this? Please outline practical steps or incentives.
N/A
16. b) Given wide regional variation in access to NHS dentistry, what policy levers are most urgent to reduce inequalities and ensure consistent provision across England?
N/A
Estates
Estates
17. a) How can the primary care estate be developed or used to improve access to care, particularly as services shift toward a neighbourhood model with an increased emphasis on community-based delivery?
As primary care shifts towards a neighbourhood model with greater emphasis on community-based delivery, it is essential that estate strategy builds on existing infrastructure rather than duplicating it. In eye care particularly, substantial private and professional investment has already been made in high-street optometry practices across England.
Primary care optometry operates from a geographically widespread estate embedded within local communities. Practices are equipped with advanced diagnostic technology, including optical coherence tomography (OCT), digital retinal imaging, visual field analysers and other ophthalmic imaging tools. This diagnostic capacity is already in place, distributed at scale, and supported by clinicians with the core skills to interpret findings and manage care appropriately.
Developing separate ophthalmic diagnostic hubs to manage patients within secondary care risks replicating existing capacity. Commissioners should focus on enabling fuller use of the established optometry estate. With effective digital integration, interoperability and secure data sharing, community optometry practices can function as neighbourhood-based diagnostic centres within integrated pathways. This approach would avoid unnecessary capital expenditure, accelerate service transformation, and deliver care closer to home.
Furthermore, moving low risk patients out of hospital eye services to be managed and monitored within commissioned shared care pathways in primary care would help ensure more care is provided closer to home. This would also free up hospital capacity to reduce waiting times for patients at highest risk of sight loss.
A key barrier to optimal use of existing infrastructure is not physical space, but digital fragmentation. Secure, interoperable IT systems that enable two-way referral, image sharing, access to relevant patient records, and structured feedback between optometry, general practice and hospital ophthalmology are essential. With digital interconnectivity in place, diagnostic information generated in community settings can seamlessly inform specialist decision-making without requiring patients to travel unnecessarily.
The existing optometry estate includes capacity for domiciliary services and outreach care for care homes and housebound patients. As neighbourhood models develop, commissioners should support flexible deployment of clinicians and equipment to reach underserved populations, rather than relying solely on fixed-site hubs.
While much investment has already been made, targeted capital grants could further enhance diagnostic capability in high-need or underserved areas. This would be more cost-effective than establishing entirely new facilities and would help reduce geographic inequalities in access.
The development of the primary care estate should prioritise integration and optimisation of what already exists. Community optometry practices represent a ready-made, technologically equipped diagnostic network embedded within neighbourhoods. With sustainable funding, digital interoperability and inclusion in local pathway planning, this infrastructure can play a central role in delivering accessible, community-based eye care.
17. b) How can local systems better repurpose void space within GP and primary care estates, and what examples of best practice already exist?
N/A
18. a) What are the main barriers to investment in the primary care estate (including ownership models, funding constraints, or maintenance liabilities), and what policy or system-level measures would be most effective in overcoming these obstacles?
See our responses to Q13a, Q13b, and Q14.
18. b) How can capital allocations for primary care be better prioritised, protected, or expanded to ensure the estate is able to meet the ambitions set out in the 10-Year Health Plan, including co-location of services and modernisation of existing premises?
See our responses to Q13a, Q13b, and Q14.
Workforce
Workforce
19) a) What evidence-based staffing models or multidisciplinary workforce compositions best enhance primary care capacity, improve outcomes, and reduce pressure on GPs?
Evidence from across the UK indicate that primary care models which deploy optometrists at their full scope of practice, with clear first-contact roles, are most effective in enhancing capacity, improving outcomes, and reducing pressure on GPs and secondary care. There is strong service-level evidence – particularly from Scotland – that structured use of optometrists as first point of contact for eye conditions delivers measurable system benefits.
The Scottish General Ophthalmic Services (GOS) model, under NHS Scotland, enables community optometrists to provide comprehensive eye examinations, supplementary testing, and management of acute eye conditions as part of a nationally commissioned contract. Patients can self-refer directly to optometry for urgent eye problems, without first consulting a GP [36, 37].
Evaluations of this model have demonstrated:
- significant reduction in GP consultations for eye-related conditions [38]
- high rates of management within primary care without onward referral [38]
- earlier detection of ocular disease [39]
- reduced pressure on hospital ophthalmology services [39, 40]
This approach illustrates the value of assigning clear first-contact responsibility to the clinician with the most relevant expertise.
Eye conditions account for a substantial number of GP and hospital eye service appointments in England; many of these could be more appropriately managed in primary care optometry from the outset [8]. A model that positions optometrists as the default first contact for eye problems (and signposts patients from other primary care settings before they make an appointment) would reduce duplication, shorten patient pathways, and allow GPs to focus on complex medical care.
The evidence suggests that primary care capacity is enhanced when:
- first-contact access is aligned with clinical expertise [36 - 40]
- professionals operate at the top of their licence [37 - 39]
- referral pathways are structured and digitally enabled
- commissioning supports multidisciplinary collaboration rather than activity retention within professional silos
Models of care that recognise and embed optometrists as first-contact practitioners for eye conditions, supported by integrated digital systems, demonstrate clear potential to improve outcomes and reduce GP and secondary care workload. Scotland provides the most established example of this approach, and its principles are transferable across England within a neighbourhood-based, multidisciplinary primary care framework.
19. b) What role should accelerated training pathways and expanded scopes of practice (e.g. prescribing pharmacists, advanced nurse practitioners, dental therapists, independent prescribing optometrists) play in strengthening GP primary care?
Optometrists are ideally positioned to strengthen primary care capacity through expanded scopes of practice, reducing pressure on GPs and secondary care while improving patient access to timely eye care. Workforce models that support advanced practice and independent prescribing further strengthen primary care capacity. Increasing numbers of optometrists in Scotland now qualify as independent prescribers, enabling them to manage a wider range of acute and chronic eye conditions without GP involvement [36, 37].
Primary care optometrists should consistently deliver enhanced eye care services – such as Minor Eye Conditions Services (MECS) and Community Urgent Eyecare Services (CUES) - across England, providing a clear first-contact point for patients with urgent eye problems. Public awareness campaigns and pathway design could redirect patients from GP practices and A&E departments to these services, reducing unnecessary demand on general practice and hospital services. Importantly, many of these services can be delivered by optometrists using core competencies without the need for additional qualifications.
Optometrists with independent prescribing (IP) qualifications, or higher qualifications in glaucoma or medical retina, can manage a wider range of ocular conditions entirely in primary care, further reducing unnecessary demand on general practice and hospital eye services.
By utilising optometrists’ full skillsets – core competencies as well as those with independent prescribing and specialist higher qualifications – primary eye care can provide timely, closer to home management of urgent and chronic eye conditions. This would:
- reduce GP workload by diverting eye-related consultations to the most appropriate clinician
- minimise unnecessary GP and hospital attendance for routine or urgent eye conditions
- enhance continuity of care by keeping patients within integrated community pathways
- maximise the use of highly trained professionals working at full scope of practice
20. How can reception and administrative staff in general practice, including those involved in NHS 111 and GP redirection, be better trained and supported to act as effective first points of contact and triage as digital access expands? What policies, training frameworks, or support systems are needed to help them guide patients through digital tools, care navigation, and appointment systems?
We often hear that patients are given a nurse or GP appointment for an eye condition, only to be told by the health professional that the practice doesn’t have the equipment to examine the eye, and they should see an optometrist. This wastes both patient and professional time and could be easily resolved by appropriate and accurate signposting to primary care optometry at the point of the appointment request. For example, patients presenting with acute eye symptoms should be directed to commissioned primary care optometry services (e.g. MECS or urgent eye care services).
Reception and administrative staff will play an increasingly important role as first points of contact. To be effective, they require structured training, clear triage frameworks, effective information on appropriate local services and digital systems that enable safe and accurate navigation to the most appropriate clinician first time.
Digital appointment booking systems must also be configured to effectively recognise a request related to an eye problem and refer appropriately to primary eye care.
Receptionists, call handlers and digital systems should be able to signpost, and – where appropriate – book appointments directly with the relevant provider within the same patient interaction. Training should explicitly include understanding of primary eye care services and referral pathways. Many eye-related conditions can be safely and effectively managed by community optometrists without GP involvement; awareness of this capability is essential to avoid unnecessary diversion to general practice.
Administrative staff can only triage effectively if supported by interoperable digital infrastructure allowing:
- real time visibility of available local services across all primary care sectors
- direct booking functionality where appropriate
- secure referral with structured information sharing
- access to relevant elements of the patient record
To enable effective first-contact triage as digital access expands, policy should:
- mandate inclusion of optometry and other primary care services within digital triage pathways
- support national standards for care navigation training
- invest in interoperable booking and referral systems
- promote public awareness of the appropriate first-contact service for common conditions
21. a) Which policies, practices, or initiatives have been most effective in recruiting, retaining, and supporting the primary care workforce across GP, dentistry, pharmacy, and optometry? Please provide case studies using the template provided. (You can also provide examples from international systems, other UK regions or non-health sectors including evidence around their effectiveness and transferability in workforce development).
See our response to Q14 and Q19a, Q19b.
Sustainable recruitment and retention across primary care depend not only on expanding training numbers, but on creating supportive professional environments, clear development pathways, and strong professional identity.
Staff retention and wellbeing
Staff wellbeing is central to workforce performance, patient safety and long-term retention. High workload pressures, increasing clinical complexity and system change can contribute to stress and burnout across all primary care professions. Addressing this requires structured and visible support.
Embedding wellbeing into professional practice helps clinicians identify early signs of stress and adopt preventative strategies before burnout occurs. The College provides a range of wellbeing resources to optometrists, promoting mental health awareness, resilience, and healthy work-life balance [41]. These resources support clinicians in safeguarding their own health while continuing to deliver safe, effective care.
Career and leadership development and professional values
Retention is strongly linked to workplace culture and professional value. Clinicians are more likely to remain in practice when they feel respected, empowered, and able to influence service development.
The College of Optometrists’ Guidance for Professional Practice [42] underpins this learning by setting clear expectations around professionalism, inclusivity, collaboration and patient-centred care. Leadership development is not confined to formal managerial roles; it is embedded across all stages of practice, encouraging reflective learning, ethical decision-making and service improvement.
Clear career progression pathways are essential to retention. Clinicians are more likely to remain in practice when they can see opportunities to be involved in new services, develop advanced skills and/or take on enhanced responsibilities. The College supports leadership and professional development through a comprehensive CPD portfolio [43] of webinars, online modules and guidance to ensure professional values are embedded in clinical and organisational practice, leadership, education and research.
In optometry, structured higher qualifications and expanded scope pathways support clinicians to extend their scope of practise. However, access to learning must be supported by protected time, appropriate funding and access to clinical placements.
Collectively, these resources ensure that optometrists are well-prepared to lead with integrity, uphold professional values, and deliver safe, inclusive, and patient-centred care across community and integrated care settings. This supports the objectives of the 10 Year Health Plan for England, continuously upskilling the workforce to meet future demands while maintaining high standards of care, inclusivity, and patient safety.
Recruitment and early careers engagement
Workforce sustainability begins with recruitment. There is a need for improved careers advice and earlier engagement in schools to raise awareness of primary care professions beyond medicine. Outreach from practising professionals — beginning as early as Year 6 —can broaden understanding of career options in optometry, support widening participation, and strengthen long-term workforce supply. Early exposure to professional role models positively influences career aspiration and diversity within the workforce.
Additional considerations
Additional considerations
22. Has the Government overlooked any significant issues in its approach to improving access to primary care? What additional priorities should be considered to ensure the 10-Year Health Plan is effective?
While the Government’s proposals address many important challenges in improving access to primary care, several significant issues require greater emphasis to ensure the 10-Year Health Plan delivers sustainable, equitable and effective reform.
Inclusion of optometry as a core primary care provider
Primary eye care is often underrepresented in NHS planning and commissioning frameworks, despite being one of the most geographically accessible and clinically capable first-contact services. More systematic inclusion of optometry within urgent care pathways, long-term condition management and prevention strategies would reduce unnecessary GP and hospital appointments. Embedding optometry fully within neighbourhood-based primary care models would improve patient flow and ensure people are seen first by the clinician best placed to manage their condition.
Equity in access to enhanced primary eye care services
There remains substantial regional variation in the commissioning of enhanced eye care services such as urgent eye care, low risk glaucoma monitoring and post-operative cataract pathways. This creates inequity in access and a postcode lottery in both urgent and routine eye care provision. Digital exclusion compounds this challenge.
As access models increasingly rely on online triage and booking systems, patients without digital access or literacy may face barriers to appropriate care. The 10-Year Health Plan should prioritise consistent national commissioning frameworks for enhanced services, supported by interoperable digital systems, to ensure equitable access regardless of geography.
Prevention as a central pillar of primary eye care
Sight loss prevention - including early detection of glaucoma, age-related macular degeneration and diabetes-related eye diseases - should be recognised as a core population health priority. Routine sight tests offer a valuable opportunity to detect both ocular and other systemic disease at an early stage. Strengthening preventive pathways within primary eye care can reduce long-term treatment costs, prevent avoidable sight loss, and address health inequalities that disproportionately affect underserved communities.
Workforce planning and scope expansion
Workforce reform should focus not only on expanding GP numbers but on maximising the capability of the wider existing primary care workforce. Optometrists are able to manage a wide range of conditions safely and effectively within the community, and this can be expanded through the use of optometrists with independent prescribing qualifications or higher qualifications. Greater use of advanced practitioners would relieve pressure on GPs and hospital eye services while increasing patient choice and reducing waiting times. Workforce planning should therefore include funded pathways for advanced practice, clear commissioning routes for enhanced services, and formal inclusion of optometry in neighbourhood workforce strategies.
Sustainable funding and infrastructure
Although the Government recognises the importance of primary-based care, insufficient attention has been paid to sustainable funding models for primary eye care.
Underinvestment in core services undermines capacity expansion and disproportionately affects practices in areas of high deprivation. To ensure long-term effectiveness, the 10-Year Health Plan should align funding with population need, support multi-year commissioning stability for enhanced eye care pathways and invest in digital interoperability to enable integrated care.
To deliver meaningful improvement in access, the 10-Year Health Plan must move beyond a GP-centric model and fully embrace the multidisciplinary nature of primary care. Greater inclusion of optometry, consistent commissioning of enhanced services, prioritisation of prevention, and strategic workforce expansion are essential to reducing pressure on general practice and hospitals while improving patient outcomes. By recognising and utilising the full capability of primary eye care, the NHS can deliver faster, more equitable and more cost-effective care over the coming decade.
23. What opportunities exist to integrate voluntary, community, and social enterprise (VCSE) organisations into prevention and primary care pathways and what case studies demonstrate successful practice?
See our response to Q24.
24. How should the Government ensure that the public are aware of the range of specialist services available to them in primary care to avoid over reliance on the current overburdened services, and to help them access care more quickly.
See our responses to Q10, Q15, Q20 and Q22.
Ensuring that the public understand the full range of specialist services available within primary care, including optometry, is essential to reducing over-reliance on GP practices and A&E departments, improving patient flow, and enabling faster access to appropriate care. Greater public awareness must form a principal component of primary care reform.
National public education campaigns
The Government should deliver sustained public education campaigns promoting primary eye care services as first-contact providers for eye conditions. Many patients are unaware that primary care optometrists can manage routine and urgent eye problems, monitor long-term conditions and detect early signs of serious disease. Clear messaging that optometrists are the appropriate first point of contact for eye symptoms would reduce avoidable GP consultations and unnecessary hospital attendance, where relevant services are commissioned. Campaigns should be consistent, nationally coordinated and aligned with commissioning policy so that public messaging reflects available local services.
Clear explanations of what services provide, who they are for, and how to access them will reduce confusion and inappropriate self-referral to overburdened services.
Collaboration with VCSE and community organisations
Partnership working with voluntary, community and social enterprise (VCSE) organisations is particularly important in underserved communities. Trusted local networks can improve understanding of available services, support health literacy, and encourage earlier presentation. Targeted outreach is essential to address health inequalities in conditions such as glaucoma and diabetes-related eye disease, where delayed access can result in avoidable sight loss.
25. What role should local authorities play in neighbourhood health systems and preventive public health within primary care?
See our response to Q24.
26. What successful approaches to joined-up working, rapid access, or integrated service delivery during the COVID-19 pandemic should be re-adopted or scaled today? Please include case studies where relevant.
The COVID-19 pandemic required rapid redesign of primary eye care services, leading to innovative, collaborative and digitally enabled models of care. Several of these approaches demonstrated clear benefits in terms of access, patient flow and system resilience, and should be retained or scaled as part of future reform.
COVID Urgent Eye Care Services / Community Urgent Eye Care Services (CUES)
Community Urgent Eyecare Services (CUES – originally called COVID Urgent Eye Care Services) were rapidly established during the pandemic to provide a structured, primary care-based pathway for acute eye conditions. These services enabled patients to access timely assessment by optometrists, often following remote triage, without first attending GP practices or hospital emergency departments.
CUES demonstrated that:
- the majority of urgent eye presentations can be safely managed in primary care
- structured referral protocols improve patient flow
- hospital and A&E demand can be significantly reduced
Where commissioned consistently, CUES provides a scalable model of first-contact, primary-delivered urgent care [8].
Tele-optometry and remote triage
During the pandemic, remote consultation and triage became essential. Telephone and video assessment allowed optometrists to:
- identify red flag symptoms requiring urgent escalation
- provide advice and reassurance
- determine whether face-to-face examination was necessary
This model ensured that patients continued to receive essential eye care during lockdown periods by using digital-first triage supported by in-person care when necessary. Retaining a hybrid approach combining remote triage with primary care-based examinations can enhance service efficiency, reduce unnecessary appointments, and increase convenience, particularly for patients with mobility challenges.
Outreach to care homes and vulnerable populations
Targeted outreach services ensured continuity of essential eye care for care home residents and shielding patients during periods of restricted movement. Domiciliary and outreach models protected high-risk populations from avoidable deterioration, including preventable sight loss. These approaches highlighted the importance of flexible deployment of primary-based clinicians and reinforced the value of bringing services to patients where barriers to access exist.
The pandemic demonstrated that consistent commissioning, rapid pathway redesign, and digitally enabled triage can be implemented at pace when supported by national leadership and clear funding mechanisms.
Key features that should be retained include:
- clear first-contact community pathways for defined conditions
- hybrid digital and face-to-face models
- rapid communication and referral systems
- inclusion of optometry within urgent and neighbourhood care planning
The COVID-19 response showed that community-based, digitally enabled and multidisciplinary models of care can improve access, enhance equity, reduce pressure on overburdened services, and support a more integrated, prevention-focused model of primary eye care.
References
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