We have responded to the GOC's consultation on testing of sight and delegation

Sight testing is likely to evolve through a combination of technological development, changing workforce roles, improved connectivity, artificial intelligence, advanced imaging and greater integration between primary and secondary eye care.

The College supports innovation where it improves patient care, access or experience without compromising clinical quality or professional judgement. Technology may enable some components of the sight test to be undertaken more efficiently, such as visual fields, intraocular pressure measurements, autorefraction and retinal imaging. This may include delegation of clearly defined activities to appropriately trained individuals, provided that these activities are appropriately governed and an optometrist retains responsibility for clinical interpretation and decision-making.

The GOC’s 2026 public perceptions research [1] provides a useful baseline for considering how future changes to sight testing might affect patient confidence and experience. Among participants who had undergone a sight test or eye examination in the previous two years, 92% were satisfied with the optometrist who carried out the examination, and 91% were satisfied that information had been provided in a way they could understand. Overall confidence in receiving a high standard of care from an optometrist was 94% among all participants, compared with 93% in 2025 and 92% in 2024. The College considers these high levels of confidence and satisfaction important assets that future models of care should preserve.

The research also highlights differences between groups. Satisfaction with the optometrist was lower among 16–34-year-olds than among those aged 65 and over (86% versus 98%), and among ethnic-minority participants compared with White participants (88% versus 93%). Although these findings do not, in themselves, establish how particular models of sight testing would affect patient experience, they underline the importance of ensuring all demographic groups benefit via accessibility, clear communication, appropriate patient selection and monitoring for inequalities, if new models are introduced.

Remote and technology-enabled care may have a role in particular circumstances, especially where it improves access for patients in remote or underserved areas. However, the College considers that remote sight testing should continue to be a real-time interaction between the patient and the optometrist, rather than routine asynchronous review of results without direct clinical interaction. The suitability of remote approaches should be determined by the needs of the patient and the clinical requirements of the examination, with appropriate safeguards to maintain quality and continuity of care.

Future models may also incorporate more personalised, risk-based approaches to care. The GOC’s research on a risk-based framework for the testing of sight identified potential benefits from tailoring care to individual patients’ risk, while also recommending further research to establish whether such approaches are effective and cost-effective. The College considers that any move towards risk-based testing should therefore be supported by robust, published clinical evidence and appropriate safeguards for patients.

The intelligence we have gathered from our members reinforces the need for a cautious, evidence-led approach. Members indicated that appropriately trained non-registrants could undertake specified elements of the sight test, provided that these activities were clearly defined and appropriately governed. However, this support does not extend to the routine fragmentation of the sight test. Members raised concerns about different components being delivered by multiple optometrists, at different times or in different locations, including remotely, given the potential risks to clinical coherence and patient safety. Members also expressed strong concerns that greater degrees of separation, delegation or remote delivery could adversely affect public confidence in, and understanding of, the comprehensive sight test and the optometrist’s role.

Feedback from our Patient and Public Reference Group, alongside the GOC’s public perceptions research, indicates broad support for responsible innovation and the delegation of some clearly defined technical aspects of the sight test, subject to appropriate training, supervision and accountability. These include intraocular pressure checks, visual field tests, autorefraction and retinal photographs/scans.  However, there is less agreement about the extent to which the clinical components of the sight test can be separated safely and routinely across different registrants, appointments or locations.

Our members expressed concerns about dividing the sight test between different optometrists because this could make it more difficult to maintain a coherent understanding of the patient’s history, symptoms and clinical findings across the examination. Where different practitioners assess separate components, there is a risk that important connections between findings may be overlooked or that responsibility for interpreting and integrating those findings becomes less clear.  If there is a delay between the two assessments, a change in the patient’s ocular health could be missed, referral or management of significant findings could be delayed, or a patient may not return to complete the full sight test.

Members were concerned that this could undermine the continuity and holistic clinical judgement needed to deliver a comprehensive sight test. Patient and public feedback similarly emphasised continuity, clinical context and confidence in the comprehensive nature of the examination.

We do not believe there is any good justification for routine separation of the sight test as a population-level model. It is important to distinguish delegation of defined technical activities from separation of the clinical assessment itself, and to assess each proposed model according to its risks, evidence base and demonstrable benefit to patients.

The College therefore supports the evolution of sight testing where changes demonstrably benefit patients, but distinguishes between the appropriate delegation of defined technical activities and the fragmentation of the wider clinical process. Delegation within a clear governance framework may help improve efficiency while preserving professional oversight; by contrast, routinely separating components of the sight test risks weakening the coherence of the patient journey and creating uncertainty about the comprehensive nature of the examination and the optometrist’s responsibilities.

Improvements in capacity and access should consequently be pursued through a combination of appropriate technological innovation, effective commissioning, adequate funding, workforce planning and service redesign. The objective should be to develop services that meet changing patient needs while maintaining clinical quality, professional accountability and public confidence in the comprehensive sight test.

[1] General Optical Council (2026), Public perceptions research

The College supports responsible innovation where there is robust evidence that it improves patient care, access or experience without compromising clinical quality or professional judgement. There may be circumstances in which separating components of the sight test by time, person and/or place provides benefits for individual patients, depending on their needs and if it is in their best interests. However, there is no good evidence that separation of the sight test benefits patients on a population level.

It is also important to distinguish between operational efficiency for a service and benefit to the patient. Although separation may create efficiency benefits, the over-riding reasons for changing the established sight test should only be clinical. Requiring a patient to attend more than once can be a significant burden, particularly for disabled patients or those who find travel and repeated attendance difficult. 

The College recognises that separating components of a sight test by time may provide additional flexibility for some individual patients. For example, a patient may be unable to complete all elements of a sight test during a single appointment because of disability, health needs, fatigue, communication needs or other individual circumstances. In such cases, completing the test over more than one appointment may be in the patient's best interests.

However, the College does not currently consider that there is sufficient published, peer-reviewed evidence to support routine separation by time as a population-level model. The longer the interval between components, the greater the potential for the patient's clinical circumstances or symptoms to change and for continuity of care to be affected. There is also a risk that patients may perceive an individual component, such as a refraction, as constituting a complete sight test and therefore not returning for the rest of the examination.

The College recognises that some activities contributing clinical data to inform a sight test can appropriately be undertaken by other suitably trained individuals. This can include technical investigations such as intraocular pressure measurement, visual field testing, autorefraction and retinal imaging, which are usually undertaken prior to the sight test (“pre-test” or triage). These activities may be delegated, provided these are undertaken within an agreed framework for delegation, supported by appropriate training and competency assessment. This includes clear protocols defining the scope and limits of delegated activities, robust clinical governance, including arrangements for quality assurance, escalation of abnormal or unexpected findings and clear lines of accountability. Where these activities are delegated, they should be undertaken synchronously with the remainder of the sight test, so that findings can be considered in the context of the patient’s current history, symptoms and other clinical findings.

There may be benefits from making effective use of the wider optical workforce, including improved capacity and better use of professional skills.  However, the College considers that this should not be interpreted as meaning that the clinical components of the sight test are interchangeable. Refraction, ocular health assessment and binocular vision assessment are clinically interdependent and should be brought together and interpreted by a single optometrist responsible for the sight test.  As stated in the College’s Guidance for Professional Practice, if an optometrist delegates patient care, or supervises others, they are still responsible for the patient and the clinical findings.

As set out above, there may be instances when a patient may be unable to complete all elements of a sight test during a single appointment. If they return for the rest of their sight test, it may be unavoidable that it is completed by a different optometrist – for example, where a locum optometrist is not returning to work at that practice within an appropriate timescale or at all; a transfer of care (and responsibility) should be made via internal referral to another optometrist to complete this episode of care. In such circumstances, the College’s Guidance for Professional Practice [1], particularly guidance on patient records, the routine eye examination or sight test, and working with colleagues, provides a relevant framework for supporting continuity of care.

An effective handover should ensure that the optometrist completing the examination has access to clear and accurate records of the assessments undertaken, the findings and any concerns identified, and the elements that remain outstanding. They should review this information alongside the patient’s history and current presentation, exercise their own professional judgement about any further assessment required, and ensure that the examination is completed in a way that supports a coherent overall clinical assessment. The patient should also understand the arrangements for completing the examination and who to contact if they have concerns.

The College recognises that remote, synchronous delivery may improve access to eye care in particular circumstances, including for patients in remote or underserved areas and where specialist professional input is not otherwise readily available.

Real-time teleoptometry, in which the optometrist and patient interact directly through video or equivalent technology, may have a role where it is in the patient’s best interests and appropriate technology, testing environment, clinical safeguards and governance arrangements are in place.  Optometrists should use their professional judgement to decide whether it is in the patient's best interests to offer remote consultations.

There is no good evidence on the efficacy, safety and risks of sight testing models in which the components of the sight test are undertaken in one location and subsequently reviewed in a separate location, particularly where this involves multiple transfers of clinical information, interpretation or responsibility. Such arrangements may make it more difficult to maintain a coherent clinical assessment and ensure that relevant findings are considered in the context of the patient’s overall needs.

Insights from the College’s Patient and Public Reference Group, which brings together patient and public perspectives from across the UK, reinforce the importance of these considerations. Patients expressed limited confidence in undergoing a full sight test without the optometrist being physically present. They raised concerns about the ability to undertake a comprehensive physical and clinical assessment, identify other conditions and provide the reassurance associated with face-to-face interaction. They also highlighted practical challenges relating to technology and connectivity, accessibility, patient positioning and the possibility of important clinical observations being missed.

This feedback underlines the importance of grounding decisions about remote sight-testing models in patients’ experiences, expectations and concerns, alongside evidence of clinical effectiveness and safety. The College considers that any such models must have robust safeguards appropriate to the setting and the needs of the patient, while preserving clinical quality, patient safety and public confidence in the comprehensive sight test as a single episode of care and the optometrist’s role.

Potential benefits of separating components of the sight test by time, practitioner or place include:

• improved access to care in remote, rural or otherwise underserved areas
• greater flexibility for patients who cannot readily complete a conventional appointment in a single episode
• appropriate use of the skills of different members of the multidisciplinary workforce
• potential increases in service capacity where there are workforce constraints
• reduced travel for some patients where remote care is clinically appropriate

The GOC’s 2026 qualitative research into patient views of teleoptometry [2] provides further insight into these potential benefits. Participants saw particular value in remote care where access to optometrists is limited, including in rural, coastal and underserved areas; for people with mobility difficulties; for working people who may benefit from more flexible appointments; where specialist optometrists or second opinions are needed; and where an on-site optometrist is unavailable. Convenience, speed and reduced travel were also identified as potential advantages.

However, the research suggests that these benefits are conditional rather than universal. Some participants questioned whether teleoptometry would materially improve access where patients would still need to attend an optical practice to have the required tests. Others perceived that the principal efficiency and cost benefits might accrue to businesses rather than directly to patients. These findings support the College’s position that operational efficiency should not be prioritised over patient benefit.

Some of our members identified potential benefits such as improving patient access, increasing service capacity and making better use of the wider optical workforce. Taken together, these perspectives suggest that appropriate delegation of specific tests may offer genuine benefits, provided they are supported by clearly defined activities, appropriate governance, continuity of care and clear clinical accountability.

The College recognises the potential value of developing and evaluating alternative models of care. However, there is currently insufficient evidence to demonstrate that routinely separating the sight test by time, practitioner and/or location improves population-level outcomes, access or service sustainability compared with a comprehensive, in-person sight test delivered as a single episode of care. Potential benefits should therefore be assessed against demonstrable outcomes for patients, taking account of clinical quality, continuity, accessibility, patient choice and public confidence. Any new models should be supported by appropriate safeguards, clear communication and robust peer-reviewed, published evaluation to establish whether they deliver meaningful benefits without compromising the coherence of the comprehensive sight test as a single episode of care or confidence in the optometrist’s role.

[1] The College of Optometrists (2023) Guidance for Professional Practice

[2] General Optical Council (2026), Patient views on teleoptometry: Research report

The College's main concern is that separation of the sight test may disrupt the holistic clinical assessment and synthesis that enables an optometrist to consider refractive error, binocular vision and ocular health together.

The nature of the risk depends on whether components are separated by time, person, place or a combination of these.

Separating components by time may result in:

• missed changes in the patient's symptoms or clinical status between appointments
• failure to recognise relationships between findings obtained at different appointments
• reduced continuity of care
• incomplete transfer of clinical information
• duplication of assessments and therefore additional time required for the patient to attend appointments
• delays in diagnosis or referral
• patients misunderstanding whether they have received a complete sight test  
• patients not returning to complete the examination

These risks may become greater as the interval between components increases.

Asynchronous review of results presents different challenges, particularly in ensuring that findings are interpreted in their appropriate clinical context, relevant concerns are identified and acted upon, and professional responsibility remains clear throughout the care pathway.

The College therefore considers that separation by time should normally be clinically justified by an individual patient's circumstances rather than being adopted as a routine service model for a whole population.

Separation by person may introduce risks where different individuals undertake different components of the sight test without adequate communication or clinical synthesis.

These include:

• failure to identify relationships between refractive, binocular vision and ocular health findings
• missed or delayed diagnosis of ocular disease
• inappropriate or delayed referral
• inappropriate prescribing
• differences in clinical judgement or interpretation
• loss of clinical context
• uncertainty regarding professional accountability
• the risk that an individual undertaking one component does not recognise information that would have been apparent from considering the patient more holistically

The College therefore supports delegation of appropriate defined tests, and individualised care to meet a single patient’s needs, but does not support the implication that the clinical assessment can routinely be divided between optometrists.

Separation by place, particularly where it involves remote or asynchronous care, may introduce risks relating to:

• limitations of technology
• incomplete clinical information
• difficulties assessing clinical context and non-verbal cues e.g. observing how a patient enters the room
• connectivity or equipment failures
• inappropriate testing environment affecting quality of results
• delays in escalation or referral
• difficulties accessing face-to-face assessment when required
• digital exclusion
• reduced continuity of care
• uncertainty about accountability where several professionals or organisations are involved.

The College recognises that real-time remote interaction between an optometrist and patient can mitigate some of these risks and may be appropriate in particular circumstances, provided it is in the patient’s best interests and suitable governance and clinical safeguards are in place. 

We acknowledge the importance of physical presence for patients in providing reassurance and enabling immediate intervention where necessary.  The GOC’s 2026 patient research [1] provides further insight into these concerns. Safety, quality and trust were identified as the principal barriers to teleoptometry. Participants expressed concerns about the potential for pathology to be missed or conditions to be misdiagnosed, particularly where patients had symptoms, a family history of eye disease or an existing eye condition. They also raised concerns about the reliability of technology and connectivity, privacy and data security, and whether remote consultations would provide the same level of attention and professionalism as face-to-face care.

The research also highlighted the importance of personal interaction. Some patients valued face-to-face relationships for the reassurance, continuity and opportunity they provided to discuss concerns or receive difficult news. This was particularly important to people with existing eye conditions and those who valued an established relationship with their optometrist. These findings reinforce the importance of maintaining continuity of care, considering the patient’s wider clinical context and ensuring timely access to face-to-face assessment where required.

The College considers that any remote model of sight testing must therefore be appropriate to the individual patient’s needs and the clinical requirements of the examination. Clear arrangements for clinical oversight, escalation, referral and accountability are essential to mitigate risks and maintain patient safety, clinical quality and public confidence in the comprehensive sight test and the optometrist’s role.

The College is particularly concerned about the cumulative effect of separation across more than one dimension of time, person or place. For example, a model in which a technician undertakes investigations at one location and an optometrist reviews the results remotely at another time and place may create greater risks than a model involving real-time remote interaction between the optometrist and patient.

Each additional separation creates another point at which information, responsibility, or patients themselves may fall through the gaps. Separating care by time, person, and place simultaneously therefore increases the risks of information loss, unclear accountability, and fragmented or incomplete care. 

These risks are consistent with the GOC's risk-based framework research [2], which identified missed clinical information, difficulties identifying diagnostic patterns, reduced continuity, increased referrals and NHS costs, delayed diagnosis and treatment, and increased health inequalities as potential risks. The research considered the likelihood of these risks to be generally low in routine eye examinations but identified potentially greater risks for patients with higher-risk profiles.  No model should be adopted until there is robust evidence of benefits and risks at a population level, and it should not be left with businesses to monitor harms: this should be audited and assessed via established research protocols.

[1] General Optical Council (2026), Patient views on teleoptometry: Research report

[2] Jonuscheit, S., Lawrenson, J.G., Harper, R., Myint, J., Little, J.-A., Löffler, G. and Higgins, A. (2025) Testing of sight – a risk-based framework: Project report

The evidence base for separating the components of a sight test by time, person and/or place remains limited, particularly evidence directly evaluating the safety, clinical effectiveness and cost-effectiveness of separating the comprehensive sight test. 

Our review of the available literature has not identified high-quality evidence demonstrating that routinely separating the sight test by time, person or place improves clinical outcomes, patient safety or cost-effectiveness for the public. While evidence supports the use of remote technologies [1] and delegation for certain defined activities and clinical contexts, the extent to which these approaches can safely and effectively replace or fragment a comprehensive sight test remains unclear. Further robust research is needed to establish the clinical, economic and patient-experience implications of such models before their routine adoption can be justified.

There is little published evidence providing comparative assessment of population level ocular health outcomes in countries with different models of sight testing, although a review of primary eye care systems in France, Germany and the UK indicated that there are benefits to the UK’s well-regulated, optometry-led service [2]. The Italian optometric system is predominantly based around refraction with no obligation to detect ocular pathology. Cheloni et al. (2021) [3] conducted a literature review to develop a preliminary evidence-based referral framework for routine Italian optometric practice. Drawing on prevalence data from a Canadian cohort, the authors estimated that up to approximately 19–20% of asymptomatic patients might have ocular conditions that could remain undetected during routine Italian optometric examinations that do not include a comprehensive ocular health assessment. As such, it is our view that any changes could not be justified by the existing evidence base, or lack thereof. A lack of evidence of harm also means a lack of evidence of safety.

We believe it is essential that the sight test should continue to be a single episode of care delivered on the same day, at the same location and carried out by one registrant optometrist or medical practitioner, unless it is in an individual patient’s best interest to split the test across more than one appointment (which may mean seeing more than one optometrist) or to provide a remote testing service to an otherwise underserved community. There is a strong case for maintaining the current position and no evidence of a need to change. The UK has a well-established optometric sector, with community-based services delivered through both NHS-funded and private provision. The GOC’s 2026 Public Perceptions Research [4] indicates generally positive experiences among those who access optometric services, with 89% of respondents satisfied with the time they waited for their most recent appointment.

Feedback from our membership indicates substantial concern about the routine separation of the sight test by person, time and/ or place. The College considers it important to distinguish between evidence supporting delegation of individual investigations and evidence supporting separation of the clinical sight test itself. The existence of evidence that a particular investigation can safely be delegated to a suitably trained individual does not in itself demonstrate that separating the clinical assessment by time, person or place is safe or clinically equivalent to a comprehensive sight test.

There is a widely accepted practice in modern optometry and ophthalmology for appropriately trained individuals to undertake defined technical investigations, such as visual fields, intraocular pressure measurements, autorefraction and retinal imaging, where the results are subsequently interpreted by the responsible optometrist.

The College supports this type of delegation subject to appropriate training, competency, governance and clinical oversight.

However, the College does not consider that this evidence is sufficient to establish the safety and efficacy of routine separation of sight-test components across the population. In particular, there is limited evidence directly evaluating models in which refraction, ocular health and binocular vision assessment are systematically separated by person, time or place.

The College's previous evidence review, undertaken in 2022, found no high-quality or compelling scientific or economic evidence demonstrating that separating refraction from ocular health assessment improves clinical outcomes, patient safety, accessibility or cost-effectiveness for the public. Our review also identified evidence suggesting that clinically significant ocular conditions may be present in people presenting primarily with refractive symptoms [5] – which would be missed if the eye examination is not completed. 

A more recent review published by the Canadian Agency for Drugs and Technologies in Health published in 2025 found that the evidence comparing teleoptometry with in-person eye examinations remains limited [6]. Further robust research is required to establish the clinical, economic and patient-experience implications of such models before their routine adoption can be justified. In addition, given the general lack of public awareness regarding the importance of comprehensive eye health examinations, implementing these models without sufficient evidence and appropriate safeguards could pose a risk to patient health, as patients may be more likely to prioritise attending an appointment for refraction and may fail to attend the comprehensive assessment of ocular health.

There is limited evidence directly evaluating the safety and efficacy of systematically separating components of a sight test across different appointments.

The College is not aware of compelling evidence demonstrating that routine separation by time improves clinical outcomes or access sufficiently to outweigh the potential risks to continuity, information transfer and clinical synthesis.

There may nevertheless be individual circumstances in which completing a sight test over more than one appointment is clinically appropriate and in the patient's best interests. The College considers this different from adopting separation by time as a routine population-level service model.

Evidence relating to teleoptometry and remote delivery is developing. The GOC's commissioned risk-based research identified potential benefits of technology-enabled models but also identified significant risks and concluded that further evidence was required.  This is mirrored by the recent Canadian review of the evidence base mentioned above.

The GOC's 2026 patient research [7] should also be reflected in the assessment of the evidence base. Public acceptance of teleoptometry was cautious and conditional rather than opposed: participants generally recognised the potential of technology where it addressed a genuine access problem, but wanted evidence that it was as safe, effective and patient-centred as face-to-face care. They identified clear communication, professional accountability, appropriately trained and supervised technicians, reliable technology, clear referral and escalation pathways, privacy and data protection, evidence of safety and effectiveness, gradual introduction, a demonstrable patient benefit and genuine choice between teleoptometry and face-to-face care as important conditions for confidence.

This is qualitative evidence about patient views rather than evidence of clinical equivalence or effectiveness.

Evidence from general practice [8] [9] [10] provides a relevant, although indirect, caution about assuming that remote delivery is appropriate for all clinical presentations. Research on remote GP consultations has identified risks including missed or inaccurate diagnoses, underestimation of severity, delayed referral and treatment, and inadequate follow-up, particularly for some urgent or complex conditions. The Health Services Safety Investigations Body [11] has also highlighted cases in which online consultation tools did not enable practices to collect the information needed to make safe decisions, contributing to delayed care. These findings do not establish that remote optometric care carries the same risks, but they reinforce the need for robust research to assess safety for each proposed model of care and to retain timely access to face-to-face assessment where clinically indicated.

It should also be noted that the College considers that real-time remote interaction between the optometrist and patient is clinically different from an asynchronous model in which an optometrist reviews information or test results at a later time, without direct interaction with the patient.  Much of the published evidence on asynchronous review of tests is from outpatient eye care clinics, where patients are being monitored for progression of a known condition.  This is very different to the role of a sight test, which is to detect previously unidentified injury, disease or abnormality.  There is no good evidence available on the benefits or the potential risks of asynchronous review within a sight test context.

The GOC-commissioned risk-based research represents an important contribution to understanding the risks of separating elements of a sight test. However, its aim was to develop a risk assessment framework, rather than establish clinical equivalence or demonstrate the effectiveness of separated models. The review also identified a limited evidence base, with most published studies relating to tele-care in secondary care settings and few directly examining the separation of sight test components. Finally, the review has not been published in a peer-reviewed journal, so its findings have not been independently verified.

The College considers that the available evidence is insufficient to support routinely separating sight test components by time, person and/or place across the population. Key concerns include the potential for missed pathology, particularly where patients may attend only for refraction, the challenges of assessing binocular vision, continuity of care, professional accountability, patient understanding and public confidence. The College also recognises the potential impact on the profession and public trust in primary eye care.

While technology-enabled models may offer benefits, including greater operational efficiency, lower-cost sight tests and potentially shorter appointments that could encourage attendance among some patients, their wider adoption should be underpinned by robust evidence demonstrating safety, effectiveness and meaningful patient benefit. This should include evidence of clinical safety and diagnostic accuracy, rates of missed diagnosis, the appropriateness and timeliness of escalation, patient experience, impacts on vulnerable groups, and implications for access to services and health inequalities.

The College therefore considers that any changes to the delivery of sight testing must be evidence-led and evaluated against clinical outcomes, patient safety and equity of access, rather than justified primarily by operational efficiency.

Any significant expansion of these models should therefore be accompanied by prospective evaluation, including:

• diagnostic accuracy
• missed pathology
• referral rates
• prescribing outcomes
• repeat examination rates
• patient safety incidents
• continuity of care
• patient experience
• health inequalities
• accessibility
• workforce impact
• cost-effectiveness

The GOC exists to protect the public and must therefore use an appropriate evidence base before making any changes to its policy on separation by time, person or place at a population level.  We do not believe this evidence base currently exists.

[1] Al-Nosairy, K.O., Stolle, F., Choritz, L. et al. Patient satisfaction in tele-ophthalmology: systematic review and meta-analysis. Eye (2026) 

[2] IBES Diskussionsbeitrag, 2011, Comparative Analysis of Delivery of Primary Eye Care in Three European Countries

[3] Cheloni, R., Swystun, A. G. ., Frisani, M. ., & Davey, C. J. . (2021). Referral in a routine Italian optometric examination: towards an evidence-based model. Scandinavian Journal of Optometry and Visual Science, 14(1), 1–11

[4] General Optical Council (2026), Public perceptions research

[5] Cheloni, R., Swystun, A. G. ., Frisani, M. ., & Davey, C. J. . (2021). Referral in a routine Italian optometric examination: towards an evidence-based model. Scandinavian Journal of Optometry and Visual Science, 14(1), 1–11

[6] Teleoptometry for Eye Exams Health Technology Review, Ottawa (ON): Canadian Agency for Drugs and Technologies in Health; 2026 Mar 

[7] General Optical Council (2026), Patient views on teleoptometry: Research report

[8] Nuffield Trust (2022) Remote GP consultations here to stay but are not a fix for all ills, think tank warns

[9] Payne R, Clarke A, Swann N, van Dael J, Brenman N, Rosen R, Mackridge A, Moore L, Kalin A, Ladds E, Hemmings N, Rybczynska-Bunt S, Faulkner S, Hanson I, Spitters S, Wieringa S, Dakin FH, Shaw SE, Wherton J, Byng R, Husain L, Greenhalgh T. Patient safety in remote primary care encounters: multimethod qualitative study combining Safety I and Safety II analysis. BMJ Qual Saf. 2024 Aug 16;33(9):573-586. doi: 10.1136/bmjqs-2023-016674. PMID: 38050161; PMCID: PMC11347200

[10] Aminu AQ, Sinclair DR, Davies K, Hall A, Wiedemann M, O'Neill TW, Clegg A, Todd C. Disparities in the use of remote general practice consultations: learning from the COVID-19 pandemic, an analysis of 19 million electronic health records using OpenSAFELY. BMC Med. 2025 Dec 2;23(1):673. doi: 10.1186/s12916-025-04469-1. PMID: 41331593; PMCID: PMC12673744

[11] Health Services Safety Investigations Body (HSSIB) (2024) Patient and staff concerns over GP online consultation tools

The College supports the principle that appropriately trained individuals should be able to undertake defined activities that contribute to a sight test, where this is safe, appropriate and supported by adequate training, governance and supervision.

It is important to distinguish between technical investigations and the clinical interpretation and synthesis of those investigations.

The GOC’s patient research [1] provides further support for this approach. Patients were generally more accepting of technicians supporting the sight test, reflecting their familiarity with activities such as pre-testing. However, this acceptance was conditional on technicians being appropriately trained, understanding the limits of their responsibilities and working under appropriate supervision. Public acceptance of delegation should not be interpreted as support for the wider fragmentation of the sight test or the transfer of clinical interpretation and decision-making away from the responsible optometrist.

The College strongly supports the proposed position that subjective refraction for the purpose of issuing a prescription should not be delegated.

The College's position is that:

• defined technical investigations may appropriately be delegated
• the person undertaking the delegated activity must be appropriately trained and competent and keep those skills up to date
• the optometrist must retain responsibility for interpreting the findings in the context of the whole patient
• subjective refraction for the purpose of issuing a prescription should not be delegated
• delegation should not result in fragmentation of the clinical reasoning required to undertake a comprehensive sight test

The statement should make clearer that delegation of an individual investigation does not mean delegation of the clinical responsibility to interpret that investigation or to determine its significance in the context of the complete sight test.

We recommend that the statement explicitly distinguish:

1. undertaking an investigation
2. assisting an optometrist in undertaking an investigation
3. delegating responsibility for undertaking an investigation
4. making the clinical judgement arising from the investigation and the sight test as a whole

The College also recommends that "suitably trained" should be supported by clearer expectations around competency, training, assessment, maintenance of competence and documentation.

[1] General Optical Council (2026), Patient views on teleoptometry: Research report

The College recognises that there may be legal flexibility in how the components of a sight test are delivered. However, we do not believe that this means there is a clinical need for flexibility at population level.  The proposed statement should not imply that separation by time, person or place is clinically equivalent to a comprehensive sight test undertaken as one episode of care.

The College's position is as follows:

The College does not support routine separation of the sight test into different appointments as a population-level model due to the absence of strong evidence of benefit.

There may be circumstances where separation by time is appropriate in an individual patient's best interests – for example, where a patient's disability, health, fatigue or other circumstances make it difficult to complete all components in one appointment.  Where this occurs, the optometrist should remain responsible for ensuring that the statutory and clinical components of the sight test are completed and appropriately interpreted, and that the patient understands what remains to be completed.

The longer the interval between components, the greater the need for clinical justification, appropriate documentation and consideration of whether previously completed components remain clinically valid.

The College also does not support asynchronous models in which an optometrist reviews sight test results without direct, real-time interaction between the optometrist and the patient. Such models can make it more difficult to identify clinical context, clarify symptoms, assess patient understanding and respond dynamically to findings.  Much of the published evidence on asynchronous review of tests is from outpatient eye care clinics, where patients are being monitored for progression of a known condition.  This is very different to the role of a sight test, which is to detect previously unidentified injury, disease or abnormality.  There is no good evidence available on the benefits or the potential risks of asynchronous review within a sight test context.

The College supports appropriate delegation of defined technical investigations to suitably trained individuals.

Feedback from College members and the Patient and Public Reference Group supports the delegation of clearly defined technical activities to appropriately trained non-registrants, subject to robust safeguards. Members emphasised the importance of clearly specifying the activities that may be delegated, while patient perspectives highlighted the need for appropriate accredited training, ongoing competency assessments, suitable facilities, optometrist review and interpretation, and clear professional and legal accountability.

Retinal photography, visual field testing, optical coherence tomography (OCT) and intraocular pressure (IOP) measurement are examples of activities that could potentially be undertaken by appropriately trained optical assistants or technicians. However, the clinical interpretation of findings, diagnostic judgement and decision-making, which should remain the responsibility of the optometrist overseeing the sight test. 

Where different optometrists undertake different components, the statement should make clear that the final optometrist must have sufficient clinical information and must exercise their own professional judgement. They should not be expected simply to accept previous findings without appropriate consideration of their reliability, relevance and clinical context.

The College considers that refraction, ocular health assessment and binocular vision assessment are clinically interdependent and should normally be delivered as one episode of care by the optometrist responsible for the sight test.  The College therefore supports the proposed restriction on delegation of subjective refraction for the purpose of issuing a prescription.

The College recognises that remote delivery can have a role in improving access to care, particularly in remote or underserved areas.

The College supports real-time (synchronous) remote care, where the optometrist and patient interact directly through appropriate technology, where this is in the patient's best interests and where suitable safeguards are in place.

Where different components are delivered in different locations, the governance arrangements should therefore clearly establish how information is transferred, how the environment is controlled so that it is appropriate for the test conditions required, who has responsibility for the overall clinical decision and how patients are escalated to face-to-face care when necessary.

The College considers that the risks may increase where separation occurs across more than one dimension i.e. separated by a combination of time and/or place and/or person. Such models may create greater risks to continuity, communication and clinical synthesis than a model involving a patient and optometrist interacting remotely in real time.

The GOC should therefore avoid treating separation by time, person and place as interchangeable concepts. The risks and appropriate safeguards of each should be considered separately and cumulatively and requires robust evidence of safety and benefit before any changes to the interpretation of the legislation on sight testing are considered.  Clinical care should benefit from innovations, but these changes cannot be driven by law and must be informed by robust, peer-reviewed research.

The College considers that the updated statement should make clear that:

• the sight test is a holistic clinical assessment
• separation is not inherently safe merely because statutory requirements can be satisfied
• refraction, ocular health and binocular vision assessment should be brought together as one routine episode of care
• defined technical investigations may be delegated where appropriate
• real-time remote care is clinically distinct from asynchronous review
• the clinical appropriateness of separation could be considered to meet individual patient needs but is not proven to be safe at population level
• where separation is in a patient’s best interests, continuity and clinical accountability must be maintained and appropriate escalation to face-to-face care must be available
• subjective refraction for the purpose of issuing a prescription should not be delegated

The College therefore considers that separation should primarily be an enabler of patient-centred care where there is a clear clinical rationale, rather than a default model for restructuring the sight test.

The ultimate safeguard is to ensure that no changes are made to the statement on testing of sight that would permit routine splitting of the sight test by person, place or time until robust clinical evidence demonstrates that the benefits outweigh the risks at a population level. Until such evidence is available, clinical practice should not be changed by legislation alone, nor should businesses be permitted to establish the safety of such changes through their own assurances. Only appropriate, robust research evidence can establish whether these changes are safe and beneficial.

Feedback from our members reinforces the importance of robust safeguards for any delegation of defined elements of the sight test. It is important to have a clearly defined responsibilities, clear professional accountability, appropriate training and demonstration of competence, effective governance such as good record keeping and robust escalation procedures. Open communication with patients is also essential. Delegation of specific activities that form part of the sight test should remain within clearly specified boundaries and must not inadvertently extend to more clinically complex activities requiring the optometrist’s clinical judgement. The optometrist must retain responsibility for clinical interpretation and decision-making.

The College considers that particular care must be taken to ensure that changes to the delivery of sight testing do not disproportionately affect patients who may be more vulnerable to missed pathology, difficulties accessing appropriate care or gaps in continuity of care. This includes children, older adults, people with existing eye conditions and people who are registered as sight impaired or severely sight impaired, as well as those with disabilities, cognitive or communication difficulties, or other circumstances that may make it more difficult to understand or navigate a separated or technology-enabled service.

These groups may have specific clinical, communication or support needs that require a more individualised approach.

The College considers that the suitability of any proposed model should therefore be determined by the individual patient's clinical needs, circumstances and ability to access and benefit from the service, rather than by operational considerations alone. Any changes must not result in reduced safeguards, delayed identification of disease, inappropriate prescribing or barriers to further assessment. 

We do not support the routine adoption of new models of sight testing until there is sound evidence on the impact specifically for these groups, including through monitoring of clinical outcomes, patient experience, missed or delayed diagnoses and inequalities in access to care. The College considers that innovation should improve access and patient experience without weakening existing protections for those who may be most adversely affected by changes to the delivery of eye care.

Several areas would benefit from greater clarity.

The statement should emphasise that a sight test is a holistic clinical assessment rather than simply a series of technical checks.

The statement should distinguish delegation from assistance and make clear that delegation of an investigation does not transfer responsibility for clinical interpretation or judgement.

The phrase "overall control of the process" could be clearer. The GOC should specify what this means in practical terms.

The phrase "significant period of time" is potentially ambiguous. The GOC should consider whether examples or a clearer principle is needed.

The statement should make clearer that informed consent requires more than notification that a different format of sight test is being used. Patients should understand the implications of the format and any material differences from a conventional sight test.

The GOC's patient research [1] indicates that many members of the public have limited awareness of teleoptometry and may be unclear about the different roles of optometrists, technicians and other staff. This strengthens the case for the statement and associated guidance to require clear communication about who is undertaking each element of care, who is clinically responsible and what patients should expect. 

The respective responsibilities of the business, the individual registrant and the person undertaking a delegated activity should be made explicit.

The College’s engagement with its membership has highlighted ongoing concerns about the clarity of professional and organisational accountability in the delivery of sight testing. Members indicated that the respective responsibilities of the optometrist, employer and optical business are not always clearly defined, particularly where care involves technology, artificial intelligence (AI), overseas providers or other organisations not regulated by the GOC.

The College considers that this reinforces the need for clearer regulatory guidance on accountability where the delivery of care is distributed across different practitioners, locations or technologies. Regulatory wording should make clear how professional responsibilities are allocated, who retains responsibility for clinical oversight and decision-making, and how appropriate governance and accountability are maintained throughout the patient journey. The use of technology or third-party providers should not create ambiguity about responsibility for patient care or compromise patient safety.

[1] General Optical Council (2026), Patient views on teleoptometry: Research report

The College considers that the proposed statement would benefit from a clearer articulation of the principle that technology and service design should support clinical judgement rather than direct or replace it.

The GOC should distinguish between the increased use of technology in eye care and the use of remote care, as these are separate developments with different implications for patient safety and clinical practice. They should not be treated as interchangeable when considering the implications of the proposed changes or evaluating the evidence on future models of sight testing.

Advances in eye care technology create both opportunities and risks. Diagnostic equipment, imaging, digital systems and other technological developments may support clinical assessment, improve the availability of information and enable more efficient delivery of services. However, their impact on clinical outcomes and patient safety and confidentiality should be assessed on the basis of robust evidence, rather than assumed from their technical capabilities or potential operational benefits.  Robust governance is required to ensure that patient confidentiality is maintained, to ensure technologies are not used for purposes over and above their licensed/approved use and to assess long-term benefits and risks in a local population. 

Remote care raises additional and distinct considerations. It has demonstrated benefits in maintaining access to professional advice and enabling continuity of care, such as during the COVID-19 pandemic, when remote consultations helped patients access services while reducing the risk of infection. Remote care may also improve access for some patients who face geographical, mobility or other barriers to attending appointments. The College recognises that demand for remote eye care may continue to increase as service delivery and patient expectations evolve.

However, remote care also presents specific clinical risks, including the possibility of missed pathology, limitations in the information available to the clinician, difficulties obtaining a full clinical history and context, and potentially delays in escalation to face-to-face assessment. The rapid development and adoption of remote services also underline the importance of ensuring that regulatory requirements and professional guidance keep pace with changes in practice [1] [2].

The statement should also recognise that there is a distinction between legal permissibility and clinical appropriateness. The fact that the legislation permits a particular way of structuring a sight test does not, by itself, establish that the model is safe and effective for all patients or settings. This can only be determined by robust research.

The College would welcome a commitment from the GOC to review the statement as evidence develops, particularly evidence arising from research into new models of care.

We also recommend that implementation should be accompanied by clear guidance for registrants and businesses, including examples of appropriate and inappropriate use of delegation and separation.

[1] Gillam M, Hawrami D, Dutton C, Price L, Hardman-Lea S, Manzouri B, (2022); Ensuring high-quality telemedicine consultations; Optometry in Practice, vol.23, Issue 2, London

[2] Teleoptometry for Eye Exams Health Technology Review, Ottawa (ON): Canadian Agency for Drugs and Technologies in Health; 2026 Mar 

The proposed standard has the benefit of clearly stating that students should only undertake supervised activities where the supervisor is appropriately approved, present on the premises and able to intervene.

This provides an important safeguard for patients and provides students with clarity about the nature of their responsibilities.

The proposed wording also appropriately retains clinical responsibility with the supervisor and requires students to comply with legal requirements.

The College supports the continued requirement for supervisors of students to be physically present and able to intervene. This is particularly important because students are developing their clinical competence and may require immediate support, correction or intervention.

Student supervision should support development of clinical reasoning and professional judgement, rather than merely ensuring compliance with individual activities.

The standard could also make clearer that supervision requirements should reflect the student's level of competence and stage of training. Students at different stages may require different levels and types of supervision.

The College also considers it important that the student standard remains clearly distinct from arrangements for unregistered colleagues. Students are undertaking an approved programme of professional education and are subject to defined educational and regulatory requirements. The level of competence and nature of supervision required for an unregistered colleague undertaking a delegated task may be different.

The College suggests:

8. Ensure that supervision is undertaken appropriately

The supervisor and student share responsibility for ensuring that supervision does not compromise patient care or safety. Students must undertake activities only within the scope of their education, training and competence and under appropriate supervision.

8.1 You may undertake supervised activities only where your supervisor has been appropriately approved by your employer or education/training provider.

8.2 Your supervisor must be on the premises, able to oversee the activities you undertake and ready to intervene where necessary to protect patients.

8.3 Your supervisor retains clinical responsibility for the patient while you are undertaking supervised activities.

8.4 You must comply with all legal and regulatory requirements governing the activity and must recognise and promptly communicate any situation where you require additional support or supervision.

This wording retains the important safeguards in the GOC proposal while making the relationship between competence, supervision and patient safety clearer.

Option 1 provides a greater safeguard than a model in which no registrant is physically present.

Its principal potential benefits are:

• enabling remote specialist or supervisory input
• potentially improving access to services in areas where particular expertise is not locally available, but could be provided remotely
• supporting more flexible workforce deployment
• retaining a registrant on the premises who can respond immediately to patient needs or support unregistered colleagues
• allowing technology to support, rather than entirely replace, local professional oversight
• potentially supporting enhanced pathways where delegated investigations can be undertaken locally and reviewed by another optometrist remotely

The GOC's patient research [1] found divided views on whether an optometrist needed to be physically present. Some participants were comfortable with remote supervision where robust safeguards were in place, while others regarded physical presence as important for safety and reassurance. This supports the College's view that the presence of a registrant can provide an additional benefit to patients.  However, physical presence should not be treated as sufficient in itself: competence, authority, information, escalation arrangements and clear allocation of responsibility remain necessary.

The requirement for a registrant to be physically present provides an additional layer of patient protection because someone appropriately qualified can intervene if an unexpected finding, equipment problem or patient safety issue arises. 

This is particularly important when spectacles are supplied to children under 16. Children require careful, individual assessment of frame selection, facial measurements, fit, stability and lens positioning to help ensure that spectacles provide the intended optical correction. Option 1 therefore helps preserve an important safeguard for children as a registrant who is physically present can assess these factors directly and intervene immediately if adjustments or other action are needed. Remote supervision alone cannot provide the same opportunity for direct physical assessment or immediate intervention.

[1] General Optical Council (2026), Patient views on teleoptometry: Research report

The main risk is ambiguity about the responsibilities of the registrant who is physically present.

The proposed wording could create a situation in which an optometrist or dispensing optician is expected to intervene in a clinical situation without having been the person responsible for the original assessment, without having sufficient information about the patient's circumstances or without the required scope of practice.

There are also potential risks relating to:

• workload and capacity
• unclear accountability
• inappropriate delegation of tasks beyond the local registrant's competence
• assumptions that physical presence alone constitutes adequate supervision and safety
• insufficient communication between the remote supervisor and local registrant
• increased pressure on registrants who are not formally supervising but may nevertheless be expected to intervene

The GOC should therefore clarify that the registrant on site must be appropriately qualified and competent for the delegated activity and must have sufficient information, authority and time to intervene.

The College is also concerned about the potential impact on workload and capacity for registrants. The requirement for a registrant to remain on the premises is supported, but the GOC should consider the workload and capacity implications for registrants who are not formally supervising but may nevertheless be expected to step in when an issue arises. The final standards should therefore make clear how such responsibilities are allocated and how businesses should ensure that local registrants have sufficient capacity to undertake them safely.

The wording should also make clear that the physical presence of a registrant does not, in itself, transfer or remove responsibility for the delegated activity from the supervising registrant. The College considers it important to distinguish between students undertaking supervised clinical learning as part of an approved education and training pathway, and other unregistered individuals undertaking delegated activities. Students are developing their knowledge, skills and clinical judgement within a structured educational framework, whereas other unregistered individuals may undertake only those activities for which they have received appropriate training and demonstrated competence. Although the supervision arrangements may appropriately differ, both contexts require clear boundaries around the activities that may be undertaken, appropriate assessment of competence, access to suitable support, clear accountability and arrangements for recognising and escalating concerns. The GOC should ensure that its standards reflect these distinctions while maintaining appropriate safeguards for patients in all settings.

The College suggests:

Where you oversee delegated activities remotely, you must be able to oversee the work and intervene where necessary to protect patients. You must ensure that a registrant who is appropriately qualified and competent for the delegated activity is physically present on the premises, with sufficient information, authority and opportunity to intervene where necessary. You must ensure that the respective responsibilities of you and the registrant present on the premises are clearly defined and documented.

Option 2 could offer greater flexibility in workforce deployment and may support access to services where it is difficult to provide a registrant physically on site.

Potential benefits include:

• improved access in remote or underserved areas through greater flexibility in deployment of the optical workforce
• opportunities to use specialist expertise remotely

However, these potential benefits should be considered alongside the risks and should be demonstrated through evidence.

Please note that the example of asynchronous care used in this specific response relates to oversight of the monitoring of patients with a known eye condition, where there is an evidence base to indicate safety and effectiveness of such models. The College does not support asynchronous sight testing models (ie split by time).

The College has significant concerns about option 2.

Removing the requirement for a registrant to be physically present increases the risk that an unregistered colleague may encounter a patient whose needs fall outside the intended pathway and that there may be no suitable registrant available to intervene.

Potential risks include:

• inability to assess non-verbal or contextual clinical information to help with assessment or diagnosis
• technical or connectivity failures
• poor implementation of tests or procedures leading to inaccurate results
• delays in identification of emergency conditions that require immediate escalation
• ambiguity about responsibility
• variable competence among unregistered colleagues
• reduced patient confidence
• difficulties supporting vulnerable patients
• patients less likely to attend if they are not seeing a registered eye care professional

The GOC's 2026 patient research [1] is consistent with the need for these safeguards. Participants identified appropriately trained and supervised technicians, reliable technology and connectivity, clear referral and escalation pathways, strong privacy and data protection, professional accountability and evidence of safety and effectiveness as important conditions for accepting teleoptometry. They also required a clear patient benefit and genuine choice between remote and face-to-face care. The College considers that these expectations should inform the conditions attached to any option permitting remote oversight without a registrant on site.

There is also an important policy question about consistency. The proposed student standard continues to require a supervisor to be physically present, while option 2 would permit remote oversight of unregistered colleagues without a registrant on site. The GOC should explain the evidence and risk assessment underpinning this distinction as both appear to have similar risk profiles.

Feedback from the College’s Patient and Public Reference Group, alongside views expressed by College members, supports particular caution where the supervising optometrist is not physically present. Patients raised concerns about the safety and effectiveness of remote sight testing in the absence of an optometrist on the premises, while College members expressed a preference for supervision arrangements that require the optometrist’s physical presence. These perspectives highlight the importance of direct clinical oversight, timely intervention and clear lines of accountability to both professionals and patients.

The College therefore considers that any model permitting remote supervision without the optometrist being physically present should be supported by demonstrable safeguards, clearly defined escalation arrangements and robust evidence that patient safety and clinical outcomes are maintained. Such models should not be adopted at scale without appropriate evaluation of their impact on patients, the quality of care and public confidence in the comprehensive sight test.

[1] General Optical Council (2026), Patient views on teleoptometry: Research report

See our response to Q17. The College does not support Option 2 and, given our fundamental concerns about remote oversight and the associated risks to patient safety, we are therefore not proposing alternative wording. We recommend that the GOC does not adopt Option 2.

Yes.

The proposals have the potential to affect some demographic groups differently, although the direction and magnitude of the impact will depend on how the new models are implemented.

Feedback from the College’s Patient and Public Reference Group highlights the importance of accessibility when considering remote models of sight testing. Patients raised concerns that remote delivery could create additional barriers for people with visual impairment. Feedback from College members further highlighted the need for reliable digital infrastructure, appropriate digital skills and access to suitable technology, particularly in remote areas. These concerns reinforce the importance of ensuring that remote models do not disadvantage patients who may be unable to access or use the technology required, and that appropriate alternatives remain available.

These perspectives reinforce the College’s position that equality assessments must consider not only whether a service is technically available, but also whether patients with different needs and circumstances can realistically access, use and benefit from it. Any proposed model should therefore be assessed for its potential to exacerbate existing inequalities, with appropriate measures in place to ensure that remote or technology-enabled delivery does not disadvantage particular patient groups or restrict access to safe, effective and appropriate care. Patients should also be offered a meaningful choice of delivery model, including face-to-face care where appropriate, and should not be disadvantaged if they are unable or prefer not to access services remotely.

Potentially disproportionate impacts could arise for:

• older people
• people with disabilities
• people with cognitive or communication difficulties
• people with sensory impairments
• people with limited digital access or digital confidence
• people experiencing socio-economic disadvantage
• people for whom English is not their first language
• people who require reasonable adjustments
• people living in rural or poorly connected areas
• people with multiple or overlapping vulnerabilities

The GOC's 2026 public perceptions research provides evidence that patient experience is already uneven across some groups. Although overall satisfaction was high, the GOC’s research identified lower satisfaction among younger patients and participants from ethnic-minority backgrounds across several aspects of the eye care experience, including satisfaction with the optometrist, the clarity of information provided and the time given to address their needs. These findings reinforce the need for equality impact assessment and disaggregated monitoring of patient experience as new models are implemented.

For some groups, remote or separated models may improve access. For others, they may create additional barriers. Patients considered teleoptometry acceptable in particular circumstances, but emphasised safeguards, communication and patient choice [1].

The College therefore recommends that equality impact assessments should consider not simply whether a service is technically available, but whether patients can meaningfully access and benefit from it.

[1] General Optical Council (2026), Patient views on teleoptometry: Research report. 

Yes.

Potential positive impacts of remote models of sight testing include improved access for:

• people living in rural or remote areas;
• people with mobility difficulties;
• people who find conventional appointments difficult because of caring responsibilities;
• people who have difficulty travelling;
• people who require shorter or more flexible appointments; and
• people living in areas with limited access to particular professional expertise.

The GOC's patient research [1] is consistent with these potential benefits, identifying rural and underserved populations, people with mobility difficulties, working people and people needing specialist input as groups that may benefit from teleoptometry. It also identified reduced travel, greater flexibility and availability of appointments where an on-site optometrist is unavailable as potential advantages. These benefits should, however, remain contingent on the service producing a demonstrable benefit for patients and on an appropriate alternative being available where the remote model is unsuitable or the patient has not consented.

However, these benefits should not be assumed to apply universally.  Providing remote eye care to meet an individual patient’s needs or the needs of a remote or underserved community may provide overall benefit to those individuals, but should not be taken as benefit to a wider population.

Patient choice and access to an appropriate conventional face-to-face service should remain important safeguards. Feedback from College members highlights the importance of transparency with patients where elements of their care may be delivered by different practitioners, remotely or across different locations. Patient perspectives gathered through the College’s Patient and Public Reference Group  similarly emphasise that patients need to understand how the different elements of their care fit together and who retains overall responsibility for their care and clinical outcomes.

These perspectives support the College’s recommendation that clear information, informed patient choice and a defined route to face-to-face assessment should be explicit safeguards in any model involving remote delivery of sight testing. Patients should understand in advance how their care will be delivered, who is responsible for clinical oversight and decision-making, and how further assessment can be accessed where clinically necessary or preferred. Transparency and clear accountability are essential to maintaining patient trust, continuity of care and confidence in the comprehensive sight test.

[1] General Optical Council (2026), Patient views on teleoptometry: Research report

Not sure.

The College considers that the proposals could have implications for Welsh-language access, but the extent of any effect is unclear.

Technology-enabled and remotely delivered care could potentially improve access to Welsh-speaking professionals in some circumstances. Conversely, if remote services or digital platforms do not support Welsh adequately, patients may experience reduced opportunities to use Welsh.

The impact is therefore likely to depend on implementation, technology, workforce availability and commissioning arrangements in Wales.

Yes.

The GOC could strengthen the proposals by requiring businesses introducing remote or technology-enabled models to consider Welsh-language needs as part of service design.

This could include:

• ensuring patients can request Welsh-language communication
• considering the availability of Welsh-speaking professionals when designing remote pathways
• ensuring digital interfaces and patient information are available in Welsh where required
• monitoring whether implementation creates differential access to Welsh-language services
• ensuring patient choice regarding language is incorporated into consent and communication arrangements

Yes.

The GOC could require businesses and registrants introducing new models of care to assess the potential impact on Welsh-language provision and to make reasonable arrangements to avoid disadvantaging Welsh-speaking patients.

This should form part of broader implementation guidance covering equality, accessibility, communication, patient choice and reasonable adjustments.