GOC consultation on the proposed update to the testing of sight statement

What has been announced

The General Optical Council (GOC) has announced a consultation to consider an update to its 2013 testing of sight statement.

This move follows the GOC’s call for evidence on the Opticians Act 1989 and consultation on associated GOC policies in 2023 – which we responded to at the time. In 2023, the regulator said that it would consider updating the 2013 statement on testing of sight to clarify the position in relation to pre-screening tests related to the sight test (referred to as ‘eye examination’ in Scotland) that may be carried out by persons other than the optometrist or registered medical practitioner.

Setting out its remit for this consultation in 2026, the GOC states: “Our approach to this issue is grounded in our overarching statutory objective to protect the public. We aim to support responsible innovation while protecting the public and maintaining public confidence in the professions and businesses we regulate, as outlined in our Corporate Strategy 2025-30. We consider that an updated statement will allow us to put appropriate safeguards in place to protect the public as well as make our expectations for registrants clear.”

The consultation includes a proposed updated statement on testing of sight which it is asking for stakeholders’ views on.

When considering businesses separating elements of the sight test by “time, person and/or place,” in practice: “separation by time” could mean booking a patient in on another day for a dilated appointment or cycloplegic refraction; “separation by person” could apply to the first example, but where a different practitioner conducts the dilation and separation by place could mean that the dilation is conducted at a different practice. These separations could be individual or occur in various combinations; and while dilation is one such example, another example would be the model of sight testing that Brillen attempted to launch in the UK.

The proposed statement is accompanied by proposals to change the standards for optometrists, dispensing opticians and optical students, with particular focus on changes that may be needed with regard to teleoptometry. The GOC commissioned research into the risks of teleoptometry. In its view, the research indicated cautious but conditional openness to sight testing using teleoptometry.

The GOC’s full consultation is available online.

The principal areas covered in the consultation

The broad areas of the consultation are as follows:

Updated testing of sight statement

• The GOC sets out the position that, in its opinion, optometrists or registered medical practitioners may delegate parts of the sight test, for example IOP checks, visual fields, autorefraction and retinal photography/OCT, to a suitably trained person, including non-registrants, provided the optometrist retains overall control and oversight.
• The consultation states that the delegation of subjective refraction for the purpose of prescribing is not allowed.
• In the view of the GOC, the Opticians Act 1989 does not prohibit separation of sight test components by time, person and/or place, provided all statutory components – visual acuity, refractive error, binocular vision and eye health – are completed before a prescription is issued.
• The consultation proposes updated safeguards via changes to the GOC standards: business-level assurance and audit obligations that scale with the number and degree of separation; documented suitability and risk-stratification protocols; informed patient consent; and an intention to review the proposed statement after no more than five years.

Supervision and delegation standard changes

• In the consultation, the GOC draws a distinction between the supervision of students and delegation to unregistered colleagues. Student supervision keeps the existing on-premises requirement, citing GOC-commissioned research and stakeholder roundtable consensus that remote student supervision lacks an evidence base.
• For instances where unregistered colleagues undertake delegated tasks, the GOC is consulting on two options rather than proposing a single position. One option is that an optometrist must be on the premises and in a position to intervene, and so is more cautious and potentially more safety-focused; and the other option allows for remote supervision, which is more permissive of innovation but, as a result, creates greater risk.

What do we say

This is an important consultation by the GOC that covers several areas that are significant not just to AOP members, but to the whole profession. The questions posed within the consultation could set the path for how optometry is delivered in the UK for the foreseeable future.

We accept that optometry has evolved since the GOC’s 2013 statement and the Opticians Act 1989 was written. Optometrists’ scope of practice has evolved and the level of knowledge and skill in the profession has grown. That is why much of what the GOC proposes is uncontentious.

Pre-screening tests conducted by optical assistants have been custom and practice for some time. Without them and particularly given the level of NHS funding that is available in England, sight testing would most likely have followed the path that dentistry has, and seen a collapse of NHS provision. A move that formally permits this much-needed division of care is therefore a sensible step.

The need for the optometrist to remain in control and to have oversight is also important. This must be universal. Assistants can help, but decisions on interpretation and on when a test may need repeating to get a better image, or a more accurate result, must sit with the optometrist.

However, there are areas where we do not believe the GOC has made the right assessment. Grouping all aspects of separation of the sight test together, and appearing to consider the risk profile to be equal across all of them, is not sufficiently nuanced. We have explained to the GOC that we believe separation of the sight test by time, person and place, and any combination of these factors, carries different and unequal risks. We have also explained to the GOC that the research on which it relies is flawed – using an array of inapplicable comparators, including different countries, different regulations and research conducted mid-pandemic, when the risk comparison was against doing nothing rather than established optometric practice.

We are pleased that the GOC appears to recognise the need for additional safeguards, but we are concerned that a number of these proposed steps are unworkable. They either shift the burden onto the optometrist in a way that, for employed staff, will be difficult for them to control, or they rely on business regulation that, until wider changes are made, is largely unenforceable.

With regards to the supervision of students, we are pleased to see the GOC has heard the concerns of the sector that this group is most in need of onsite supervision. Optometry education in the UK is already undergoing a period of change; the removal of this essential safety net would place students and patients at unnecessary risk. Even once the changes to education are more embedded, it is hard to envisage a situation where students could be supervised remotely.

In terms of wider supervision of unregistered colleagues, both options presented in the consultation have challenges. It is unclear how patient safety could be maintained without having an optometrist on the premises and able to intervene when necessary. However, we are concerned that the onsite optometrist, without careful protections being included, could find themselves in an almost impossible position where they are responsible not only for their own clinic but also for overseeing a remote clinic. Our view is that, on balance, there must be an optometrist onsite, but they must be protected by additional requirements.

The GOC consultation is open until 21 October.

Next steps

The AOP will be helping our members to understand the consultation and its significance for their future practice. We will do this be continuing to identify risks and opportunities from this consultation and ensuring we reflect and protect the professional interests of our members. We will also be engaging with sector partners to find common ground wherever possible.

GOC consultation: FAQs for members