GOC Standards for Optical Businesses

Read the College's response to the GOC consultation on the proposed Standards for Optical Businesses (August 2018)

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We welcome the opportunity to comment on the GOC’s draft business Standards.  In general we welcome the Standards, and believe they will improve patient safety.  We would like to make the following comments in addition to those completed via the GOC Consultation Hub.


Section 1.1 – Patient care is delivered in a suitable environment

1.1.3. Maintain a good standard of hygiene and repair in any of your premises from which care is provided, and ensure that any equipment used is also hygienic and in good condition

We feel it is important to ensure that equipment, as well as being hygienic and in good repair, is also adequate for the purpose for which it is intended.

1.1.6. Where care is provided in a domiciliary or other community setting, make it clear to staff that they should only deliver care if they consider the environment to be safe in which to do so

We feel that practices could also be included as ‘community settings’, and would suggest rephrasing the Standard to say ‘Make it clear to all staff that they should only deliver care if they consider the environment to be safe in which to do so.  This includes domiciliary and non-practice based environments’, or ‘This applies to wherever care is being provided, including during domciliary visits’.

1.1.8. Provide appropriate disposal facilities for controlled, clinical and offensive waste 

We would suggest making it clear that this applies to all waste, not just controlled, clinical and offensive waste.

1.1.9. Require and enforce infection prevention protocols appropriate for your practice and ensure that all staff are in a position to follow them 

We use the phrase infection control, rather than prevention, as infection cannot always be prevented.

1.1.11. Ensure that unauthorised access to equipment and restricted areas of the premises is prevented 

We would suggest rephrasing this to say ‘Ensure that protocols prohibiting unauthorised access to confidential information are implemented’.  

1.1.12. Put matters right where patients are, or may be, put at risk due to the condition of equipment or premises 

We feel that if the change to equipment as in 1.1.3 above is implemented then paragraph 1.1.12 is redundant.


Section 1.2. Patients can expect to be safe in your care

1.2.4. Safeguard patients against abuse by ensuring that relevant staff have up-to-date Disclosure and Barring Service (DBS) checks in place 

Disclosure and barring checks are not mandatory, and this paragraph appears to suggest that businesses should conduct them.  We would suggest adding ‘where appropriate’ to this paragraph, and supplementing it with when the GOC would feel that these checks were appropriate.

1.2.6. Be prepared to restrict trading in areas of concern if continuing to carry on business may damage the reputation of the profession 

This would benefit from clarification as we are unclear what this means.


Section 1.3. Communication is clear and effective

1.3.3. Ensure that commercial pressures do not inhibit staff from allowing patients the time they need to process information given and the opportunity to change their mind before care is provided 

We particularly welcome this point.

1.3.4. Make clear information available regarding any change to existing products or appliances supplied, to ensure that patients have the right to decide about their own care 

We understand the rationale for this but think it would benefit from clarification.  Possibly along the lines of ‘Ensure patients are informed when products that they are supplied with, such as contact lenses, are changed and that patients consent to such a change’. 

1.3.6. Support your staff, where appropriate, to provide patients or carers with all the information they need to be able to safely use, administer or look after any optical devices, drugs or other equipment that they have been prescribed or directed to use in order to manage their eye conditions 

We feel this should be limited to optical appliances (rather than devices), drugs or other equipment that has been prescribed by someone working for the business registrant.  As it stands it could apply to drugs that have been prescribed by the hospital, or another healthcare professional unrelated to the business registrant, which we assume is not what was intended.  We would suggest rephrasing to say ‘where appropriate’ after ‘to provide’, so that it reads ‘Support your staff to provide patients or carers with the information they need to be able to safely use, administer or look after any optical appliances, drugs or other equipment that your staff have prescribed or directed them to use to manage their eye conditions’.


Section 1.4. Patients can give informed consent to treatment

We note that the second sentence in preamble refers to ‘optical appliances’.  Patients may purchase other items too, so we suggest rephrasing to say ‘Consent reflects the right of patients to determine what happens to their own bodies and make choices about what to purchase’.  

1.4.1. Make information available to staff regarding the differences in the provision of consent in children, young people and vulnerable adults, and any legislation affecting the provision of consent in the nation of the UK in which they work 

We believe that it is the rules surrounding consent that are important, rather than the provision of it, and it is more important to train relevant staff than to simply provide them with information.  We would therefore suggest this is rephrased to say ‘Ensure relevant staff are trained about the different rules surrounding consent for children, young people and adults and how these apply in the UK country in which they work’.  

1.4.2. Support staff in making an assessment of patient capacity where they are unsure, and provide a mechanism for recording any advice they receive on making such an assessment 

We are not sure what this paragraph means, and feel it would benefit from clarification?  If it relates to a particular patient would the staff (who are likely to be registrants themselves) not simply record any discussions they had had about the patient on the particular patient record?

1.4.3. Make staff aware that consent is an ongoing process throughout the provision of care and enable them to seek this from patients 

We feel that as this is likely to only apply to registrant staff it is not needed in the business standards, as registrants are already bound to comply with the Standards of Practice for Optometrists and Dispensing Opticians.

1.4.4. Do not impose sales targets that have an adverse effect on patient care 

We particularly welcome this point.

1.4.5. Implement a practice protocol for documenting where patients have refused or withdrawn consent 

As for paragraph 1.4.2 we feel that this would simply be recorded in the individual patient record, and as such does not need a specific business standard.  Any patient refusal of a non-clinical matter would be recorded in the appropriate place, such as an opt-out of marketing information.


Section 2.1. Your business practices are open and transparent

2.1.2. Ensure that all public-facing staff are clearly identifiable and have roles appropriately assigned, with clear lines of accountability 

In smaller practices there may be a lot of multitasking, with, for example, the optometrist manning reception at times as well as answering the phone.  Any standard would need to be flexible enough to accommodate this.  


Section 2.4. Ensure that those individuals or organisations to which you refer patients have the necessary qualifications and registration so that patient care is not compromised 

2.4.6. Have a protocol for staff to follow so that breaches of confidentiality in the public interest are thoroughly documented

We feel this standard as written is unclear, and as this is about reporting unintentional breaches of confidentially, would benefit from being rephrased to say ‘Have a protocol so that staff know how they can report data protection breaches to the appropriate person’.


Section 3.1. Your staff are able to freely exercise their professional judgement

3.1.2. Make sure that commercial pressures do not inhibit the exercise of professional judgement and compromise patient safety 

We particularly welcome this point.

3.1.6. Encourage staff to undertake learning and development in professional decision-making 

We particularly welcome this point.


Section 3.2. Staff are suitably trained, qualified and registered 

3.2.4. Require staff to only work within the limits of their individual competence with regard to patient care and take appropriate action where they do not 

We particularly welcome this point.

3.2.5. Provide an appropriate system for the monitoring of staff objectives and training needs 

We feel this point should focus on clinical rather than commercial objectives.


Section 3.3. Staff are adequately supervised

3.3.2. Encourage staff to record details of any supervision undertaken in the patient record

This is already a requirement in the Standards of Practice for Optometrists and Dispensing Opticians (8.2.7), so we wonder if it is necessary in the Business Standards too?

3.3.6. Provide students with sufficient information to know who to contact if they have an issue with any aspect of their supervision 

We think this would benefit from clarification as to whether this would be within the company, or externally.

3.3.7. Provide for pre-registration students to have protected time to study 

We particularly welcome this point.


Section 3.4. Staff collaborate with others, where appropriate

3.4.2. Facilitate the sharing of appropriate and relevant information in a timely manner 

We are unclear what this means, and feel it would benefit from clarification.

3.4.5. Require staff to keep patient records that are clear, legible, contemporaneous and sufficiently detailed to be accessible to another healthcare professional 

As well as being clear, legible, contemporaneous and sufficiently detailed, it is also important that the records are accurate, so we would suggest adding this to the standard.


30 August 2018