Fit for the Future: Lifelong Learning Review

The College responds to the GOC's major consultation on the current CET system, with a view to developing a reformed programme that will equip optometrists for future challenges (August 2018).

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Tell us who you are

1. What is your name?
Josephine Mullin

2. What is your email address?

3. Are you responding as an individual or an organisation?

5. What is your organisation?
College of Optometrists

6. Which category best describes your organisation?
Optical professional body

Section 1: Views and understanding of the current CET scheme

7. To what extent do you agree or disagree with the following statements. The GOC’s current CET scheme:

Views on our current CET scheme - Allows registrants to develop their skills and knowledge in order to keep pace with the changes that are happening in the optical sector:
Neither agree or disagree

Views on our current CET scheme - Allows registrants the flexibility to undertake CET in relation to their individual scope of practice:

Views on our current CET scheme - Helps encourage professional development:
Strongly disagree

Views on our current CET scheme - Helps improve registrants’ practice:

Views on our current CET scheme - Helps registrants to keep up to date with good practice:
Neither agree or disagree

Views on our current CET scheme - Helps registrants plug gaps in their knowledge:

Views on our current CET scheme - Helps to build and maintain public trust and confidence in the optical professions:

Understanding risks in the optical sector and the role of revalidation

8. What do you think are the riskiest areas of work carried out by optometrists and dispensing opticians? How well does the CET scheme address these risks?

Please provide comments:
Areas of practice that could result in patient harm because sight (or life) threatening diseases were not detected include:

  • history taking
  • examination techniques, particularly techniques such as Goldmann, pachymetry and gonioscopy that are not assessed before registration
  • interpreting data incorrectly, for example use of OCT without expertise in image interpretation
  • clinical decision making skills, including not being clear about what, when and to whom to refer
  • initiating treatment for sight-threatening conditions, including prescribing drugs
  • communication skills
  • record keeping.

The current CET scheme does not fully address these risks as the need to do 36 points, much of which can be achieved very easily and which has to be spread across the whole competency framework, does not allow registrants to concentrate on areas that they have identified as requiring improvement. It is possible for registrants to approach the current CET requirements as a tick box exercise, meaning that it does little to improve their performance in their areas of work or to encourage them to reflect on their own performance. It is also aimed at a basic, core standards level that does little to encourage professional development.

9. Do you think that there is a risk that optometrists and dispensing opticians may be de-skilling i.e. losing their skills and knowledge in some areas of practice?

Additional comments:
Yes, but it is difficult to keep up-to-date in areas in which you do not practise regularly. For example, if registrants do not see many contact lens patients, prescribe many drugs (as an independent prescriber) or see many children, undertaking one or two hours of CET in these areas, will not replace lack of experience and could give a false sense of security.

We believe that encouraging a climate of peer learning, mentoring, taking responsibility for one’s own professional development and having a culture where it is possible to be honest about skills gaps is a better way of tackling deskilling in areas that are relevant to the registrant’s practice.

10. Are there any core areas of practice that optometrists and dispensing opticians should keep their skills and knowledge up to date in?

Additional comments:
Core areas for practising optometrists might include:

  • history taking
  • examination techniques
  • interpreting findings
  • diseases and abnormalities
  • clinical decision making, including referrals
  • communication, including explaining and advising
  • professionalism and ethics
  • safeguarding
  • managing their own learning and development, including auditing work and reflecting.

However, optometry is changing rapidly so it is difficult to set a range of core skills in which all optometrists should continue to keep up-to-date, particularly as the ability to work in different settings is increasing. For this reason, and because, as stated above, it is difficult to maintain skills that are not practised regularly, these would need to be supplemented by other more specific areas of knowledge and skills, tailored to the registrant’s own practice. This is borne out by research which shows that, to be effective, CPD needs to be linked with and relevant to individual learning needs within the context of the registrant’s own practice, and the needs of their patients. This means it needs to be planned. Learning with others and reflection are known to help, and active learning is regarded as useful. The impact of CPD is shown through positive changes in practice, knowledge acquisition and learner satisfaction.

Overall, CPD should be about keeping patients safe in the context in which registrants work, whether directly, for practising optometrists, or indirectly, for those working in the field of optometry but not directly with patients.

Lifelong learning and reflection

11. To what extent do you agree or disagree with the following statements?

Lifelong learning and reflection - The GOC’s current CET scheme intends to promote and embed a culture of lifelong learning and encourages registrants to reflect on their practice.:

Lifelong learning and reflection - The name of the current scheme, Continuing Education and Training (CET), helps to promote a culture of lifelong learning and reflection.:

Additional comments:
We have put disagree for the first statement, as although we recognise that it may intend to do this, we do not believe that it does.

Our reasons for thinking this are that the current CET scheme does not talk about lifelong learning, and reflection is rather cursory. In particular:

  • the language around the whole scheme does not support the concept of lifelong learning
  • reflection is not shown as part of an overall learning cycle and is sometimes considered by registrants as an add-on
  • reflection is not required for every CET activity

Collecting a number of points can mean that, rather than improving practice, it is the collecting that becomes the main driver. One possibility, used by many other professions, is the use of a portfolio of professional development. Checking the effectiveness of CPD by portfolio is a challenge, but imbuing an understanding of CPD is becoming more important, as the practice of registrants will change considerably through the life of their careers. It is important that they know how to direct their own learning effectively, to take responsibility for it and continue to provide good care for their patients.

12. Are these tools helpful?

Additional comments:

  • the basics are in place but more could be made of them
  • there is still not a culture of lifelong learning and reflection. That needs to come from moving away from CET and towards CPD and registrants’ ownership of professional development needs and identification of skills gaps. Point counting and covering every competence continues to dominate the CET requirements.

13. Are there any barriers that could make it difficult for optometrists and dispensing opticians to reflect on their practice?

Reflective practice - A lack of guidance or support:

Reflective practice - A lack of clarity around the concept of reflection and the benefits:

Reflective practice - Fear of being open and honest about where improvements could be made:

Additional comments:
Linking maintenance of registration to training and development will create concerns for some registrants about how honest they can be about any skills gaps, so this needs to be addressed openly from the start to reassure registrants. As the GOC will be aware, this is an issue that has been recognised in the rapid policy review report into gross negligence manslaughter led by Professor Sir Norman Williams, commissioned by the then Secretary of State for Health and Social Care. This was set up after concerns among healthcare professionals about how open and transparent they could be, including in their reflective practice. As a result of the report, steps are being taken to address this issue across the healthcare professions.

We have some guidance and templates for our members on planning and reflection.

14. What more could the GOC do to support registrants in embedding a culture of reflective practice?

We believe the following would help:

  • change the points system for a broader CPD one and have guidelines for minimum requirements
  • change the use of language on the MyGOC system and in supporting documents to emphasise the importance of reflection for lifelong learning
  • ensure that registrants understand that openness and honesty in reflection will not be used against them
  • make changes to the process and the MyGOC website to make reflection easy to do
  • make it relevant to registrants’ scope of practice and future practice
  • promote peer discussion and peer review
  • encourage mentoring.

Section 2: Views on the proposed changes to the CET scheme

15. To what extent do you agree or disagree with our proposed approach of giving optometrists and dispensing opticians more control over their learning and development?
Strongly agree

Additional comments:

  • clear, supportive guidance is needed; we can provide this for our members but overall guidance would be needed from the GOC for other registrants
  • this will promote the required culture of lifelong learning and CPD
  • the system for registrants to acquire that learning and development must support that approach and guide users through a planning, learning and reflection cycle.

16. What are the benefits and challenges of moving towards this approach?


  • CPD becomes relevant to registrants’ job
  • registrants will not be required to cover competencies that are not relevant to their scope of practice
  • gives registrants more ownership of their learning, which will be essential as time goes on and the jobs they are doing bear little resemblance to what they learnt originally
  • promotes professional development.


  • There is a significant risk that some registrants will not take responsibility for their own learning and actually do less CPD; the system will need to have safeguards to tackle that.

Aligning CET requirements for optometrists and dispensing opticians

17. If you are responding as an optometrist or dispensing optician, what is your experience of peer review and any benefits it has had on your practice?


We are responding as an organisation rather than an individual. However, we have had very positive feedback from members about peer review. Some examples
are below:

  • It was interesting to hear real life scenarios and everyone’s opinions.
  • Very useful to discuss real cases that people have questions about.
  • We felt it was useful to use delegates’ real life pts records. We also felt it would be even better if we could find out the outcome.
  • Extremely useful as real life scenarios that individuals can comment on and relate to.
  • Very happy with this format. Interesting to learn some challenging cases and their management.
  • More interesting than theoretical cases.
  • Very enjoyable and excellent discussion.
  • Very good at putting people at ease - I enjoyed the "chatty" nature of the session. I found my previous Peer Review session (approx 2 years ago) fairly intimidating and uncomfortable, and was not looking forward to this one at all, but felt instantly relaxed and able to put forward my opinions without fear of feeling stupid or wrong.
  • I have not been to a peer review session like this before and thoroughly enjoyed it. I also have a lot of very useful ideas to use in practice.
  • Our group bought varied cases which made our discussion particularly interesting.
  • I think this format involves fully engages participants as they are partly contributors to the review

18. To what extent do you agree or disagree that peer review should play a more central role in a scheme which aims to embed a concept of lifelong learning and reflection?
Strongly agree

Additional comments:

  • our members value the peer discussions and peer reviews we provide for them
  • it is an accepted approach in medical and other healthcare professions to do peer review on a frequent and regular basis with colleagues
  • it would help if the GOC were able to be more flexible and remove some of the bureaucracy, for example by encouraging registrants to undertake peer review locally without having to obtain approval first (but with guidance about how to do peer review)
  • we have support materials for members to assist them with peer review and we train and support a large bank of facilitators
  • DOCET has online facilitator training which is available to all UK registered optoms.

19. To what extent do you agree or disagree with the principle that the GOC should have the same CET requirements for all fully qualified optometrists and dispensing opticians, by introducing peer review for dispensing opticians?

Additional comments:

While being mindful that it is for dispensing opticians to comment on this, we believe that both dispensing opticians and optometrists would gain from undertaking peer review together on topics that are common to both professions.

20 What impact and barriers, if any, would this policy have on dispensing opticians?

It would give them a chance to discuss issues that were not clear-cut, which would build critical thinking and, therefore, clinical decision making skills. It is also a good way to build trust with fellow professionals and, if it is a case that can involve more than one profession, build trust between professions too.

As above, there is a danger that onerous bureaucratic processes in relation to approving peer review cases for CET would prevent people organising these.

Section 3: Views on the proposed timeframe for introducing changes

21. What impact, if any, will there be as a result of proposals for a one year transition period where registrants will still be expected to complete CET as outlined above?

It must be clearly publicised to ensure registrants understand the requirements. Key messages need to be widely promoted in a timely manner, to ensure that it does not have a negative impact on registrants, which might spill over into a new system. Because the minimum is currently six points in a year, some registrants may find 12 difficult, so will need maximum notice.

We do not believe that the removal of mandatory coverage of competencies is a problem, since registrants need not cover all competencies in one year anyway. However, removing mandatory peer review is counter to the lifelong learning message that will follow and could pose a problem for providers who have made plans for events in 2019. For these reasons, we think the decision to make it optional should be reconsidered.

We will continue to offer peer discussion and peer review sessions to our members because we think it is important for continuity of skills development and an essential part of a healthcare professional’s reflective process.

22. How could the GOC best support stakeholders during the transition year and into a new scheme starting in January 2020?


  • provide a clear statement for registrants that we can share, or direct them to
  • give us as much notice as possible of the new scheme requirements so we can implement in time for January 2020
  • provide sufficient guidance
  • ensure modern learning technologies and modes of learning are included in the new scheme and that the provider approval system allows flexibility to match applications to broad descriptors
  • reduce the bureaucratic burden as much as possible.

Final thoughts

23. Do you have any further comments you would like to add on any of the points raised in this consultation?

Additional comments:

We were perplexed by your assertion that your current CET system covers both professional development and revalidation.

As you rightly say revalidation is to ensure registrants continue to be fit to practise throughout their careers and was brought in by the GMC because of the Bristol heart babies case. As a result, their system includes a whole range of measures, which include CPD but also appraisal, peer and patient assessment, keeping a portfolio and reviewing it with a senior doctor. The senior doctor decides whether the doctor is up-to-date and fit to practise and a new licence is issued every five years on this basis. It is simply inconceivable that doing 36 points over three years, much of which can be achieved through reading articles and sitting in a lecture can fulfil the same role, even in a more low risk profession.

In addition, we see CET as a subset of CPD, rather than the other way round. CPD includes a whole range of professional development activities, some of which are formal (in GOC terms gaining points) and many of which are informal but nonetheless extremely valuable.

Having said that, we are delighted that the direction of travel is towards a more flexible system of CPD, which will allow registrants to tailor their professional development to their practice, and begin to develop a culture where they learn how to direct their own learning from the planning stage through to reflection. This will be much needed for the future, because undergraduates now will be doing a very different job from the one they are currently being trained for and will need the skills to take their own development forward. This will be a proportionate way of ensuring that registrants continue to be fit to practise throughout their careers.


24. Can we publish your response?