GOC consultation on the proposed update to the testing of sight statement and proposed revisions to supervision and delegation standards: our short summary

We have responded to the consultation by the General Optical Council (GOC) on the proposed updated testing of sight statement and proposed revisions to supervision and delegation standards in the GOC’s Standards of Practice for Optometrists and Dispensing Opticians and Standards for Optical Students.

We thank all our members, as well as the wider profession, who took part and completed our survey, which sought to understand the profession’s experiences and views. We received 661 responses, more than 95% of them from members, and those answers and comments have supported us in developing our response to this consultation.

We found that most respondents are opposed to the proposals, and there were many comments that made clear the strength of that opposition. We have offered to share the full survey report with the GOC.

The GOC's draft statement says the Opticians Act permits the sight test to be separated by time, person and/or place. We disagree. The independent legal advice we sought concludes that routine separation is not permitted within the act, but it does permit limited and clinically justified separation.

The legal advice also says the GOC's public protection duty requires it to assess foreseeable risks of new models of care and take reasonable steps to mitigate them. A lack of evidence of harm is not enough. The GOC's own evidence review contains no UK study that tests routine separation for an unselected population.

We have also told the GOC that each type of separation, and each combination, carries different risks and must be assessed separately.

Our concerns about supervision and delegation

In the survey, most respondents accept the proposal of trained colleagues carrying out tests such as IOP, fields, OCT and fundus photography, as long as the optometrist is on the premises and able to intervene, where necessary. Remote supervision, online testing and pre-screening days or weeks before the examination drew the sharpest opposition.

In our response we have told the GOC that we:

• Back “Option 1”, which is the option most respondents preferred: this states that the supervising optometrist must be on the premises and in a position to intervene
• Oppose “Option 2” (remote supervision). We do not believe it can be worded to keep patients safe
• Ask for supervision to be meaningful. An on-site optometrist with a fully booked clinic cannot genuinely intervene, so clinic scheduling must allow for it
• Ask for a clear definition of delegation, including who is responsible for training, the working environment and auditing quality
• Flag liability without control. Optometrists would stay responsible for tests they did not perform or oversee. Our survey data showed that nearly 4% of employed and nearly 10% of locum respondents already say the optometrist has no control over which tests are done.

The pressures on optometrists

Commercial pressure was the most common theme in the survey responses, by a clear margin. Many respondents expect extra delegation and remote working to be used to shorten appointments, increase throughput and cut costs, not to give patients more time. Many also described burnout, inadequate test times, low pay and pressure from managers.

The GOC's own thematic review on commercial pressures found the same power imbalance. Optometrists often feel unable to challenge poor practice and do not see the GOC as a source of support. We conclude that the proposals would put more responsibility on individual registrants without giving them the power to meet it.

In our response we have told the GOC that:

• We oppose the proposals. At the very least, they must not be introduced until business registration is compulsory, with meaningful sanctions proportional to turnover
• Optometrists must give explicit, freely given consent to delegation arrangements, so they can challenge practices that are not in patients' interests
• The GOC must do more to show registrants they will be supported when they raise concerns about patient care.  

Next steps

We will keep members updated as the GOC considers its next steps. We thank all our members for taking the time to share their views.

Read the consultation response in full.