General Optical Council (GOC) consultation on the approach to setting registrant fees

We broadly agreed with the set of principles intended to inform a framework for future fee policies that were mapped by the GOC in the discussion document. However, there was some disparity of views on the details of who should benefit from a sliding scale fee structure. One aspect that was uniformly agreed upon was that the fundamental level of the GOC fee remains a key concern. Respondents consistently highlighted that rising fees present significant financial pressure alongside inflation, stagnant salaries and rising living costs.

We welcomed the prospect of introducing a differential fee system – as long as it is proportionate to registrant circumstance and does not create excessive administrate cost that ends up being added to GOC fee.

Broadly speaking, members welcomed the possibility of greater flexibility to pay via direct debit instalments spread across the year. There was also a strong appetite for ongoing transparency in how fees are determined and what they are used for. Any changes in fees (precedented or unprecedented) should be backed by explanations, with this information made accessible to registrants in an easily digestible format.

Our member survey highlighted strong support for introducing a reduced fee for those on leave/career breaks. In particular, the feedback from members focussed on registrants on maternity leave, stressing that they be entitled to pause all GOC fees if they are not undertaking any paid work. This could not only help with sector retention but also ensure that the sector remains diverse.

AOP members strongly opposed a higher fee for specialists, stating that those who have invested in themselves to upskill should not be penalised through higher fees. Many felt that a higher fee associated with additional qualifications could act as a disincentive for registrants to obtain them. We also stated that the financial justification for this was weak; a £50 surcharge on specialists saves every other registrant just £6.60. This could be particularly detrimental to the profession at a time when qualifications are needed to ensure provision of enhanced services, deliver better quality of care to patients, and reduce the pressure on secondary care.

In our survey, 71.62% of respondents favoured business registrant entities paying higher fees than individual registrants. However, we previously lobbied the GOC for a proportionate approach in setting business registrant fees – in short, we asked for a tiered fee system that is proportionate to the business’ size, operational scope, and financial capacity. A sliding scale based on business turnover (expecting that smaller independent practices pay less in GOC fees).

We strongly supported further consultation on costed plans and fees as this would help registrants better understand the relationship between regulatory activity of the GOC, the expenditure and subsequent fee levels. However, we asserted that evidence must be provided on how cost-audit/auditory process are proportional to the cost incurred by the members – in other words, how is the budget is being allocated on measures to improve transparency.