Optometry bodies say funding uncertainty on GOC education plans threatens patient safety and public confidence

Joint statement from the Association of Optometrists, College of Optometrists and the Optometry Schools Council

AOP, College of Optometrists and the Optometry Schools Council logos

The General Optical Council’s proposed new framework for optometric education is untested – and it isn’t yet clear whether education providers will be funded to deliver it safely. The Association of Optometrists, the College of Optometrists and the Optometry Schools Council are concerned that this could significantly disrupt future optometry education and training, affecting patient safety and public confidence. We are urging the GOC to agree to monitor this risk closely and only confirm the new framework when it is clear that it is financially viable for providers.

What's happening

The GOC is currently consulting on final proposals for the new Education Strategic Review (ESR) framework, and is aiming to agree them by December 2020. The consultation closes on 19 October 2020. The AOP, the College and the OSC will all respond to the consultation, giving our individual perspectives and views. But we are making this joint public statement now because we agree the risks around funding are critical, and could cause serious damage to optometry education and training.

The ESR proposals would change the regulatory requirements that optometry education programmes in the UK have to meet. To enable innovation, many aspects of the new framework are less specific than the current rules. However, the model also imposes new conditions, including the requirement that providers must offer an integrated path to GOC registration, incorporating at least 48 weeks of clinical experience organised by the provider. This is a substantial change from the current two-stage process, whereby most students undertake a BSc degree followed by a separate pre-registration phase. It will require providers to arrange, manage and quality assure a high volume of placements, which will carry a substantial cost for the providers. 

The risks

There are differing views in the optical sector on whether change on this scale is needed, and what the benefits maybe. At times, the GOC has suggested that the practical changes providers have to make may be modest. But, in our view, the level of change for education providers, and for employers and supervisors providing placements, will be substantial. 

The AOP, the College and the OSC have all previously said that the GOC must think through the funding implications before introducing such major changes. The GOC has done some work on this but we have deep concerns that, in the draft Impact Assessment published alongside the current consultation, the GOC has made no assessment of the financial impact its proposals will have on education providers. It has only asked providers to give their views in response to the consultation. The GOC has recently commissioned consultancy advice on this issue, to inform its Council’s decisions on the new framework; however, the final report will not be available until after the end of the consultation. We do not think the timeframe and funding for this commissioned work is proportionate to the complexity of the funding implications of the ESR across the four nations. 

This inadequate approach will not allow time for informed public scrutiny and debate on the likely financial implications of the ESR before the planned GOC Council decision on the framework in December.

This is not just an abstract concern. If the GOC agrees a final framework that providers cannot afford to deliver, then some providers will exit the market – reducing student choice, cutting the number of trained optometrists available to join the register each year, and impacting on the fulfilment of patient care needs. Other providers may struggle to deliver the new requirements, leading to  training that does not meet the revised standards. Either outcome would threaten patient safety and public confidence in the profession – the things the GOC exists to protect. 

The COVID-19 pandemic has considerably heightened these concerns. It is clear that universities are already facing massive resource and capacity pressures because of recent events, but it is too early to tell what the long-term impact will be. The additional financial uncertainty created by the ESR, including for optometry employers that invest in, support and depend on optometry workforce supply, will provide additional challenge and insecurity for providers to manage. 

What are we calling for

At this point the AOP, the College and the OSC are not arguing that the new framework should be completely dropped. We believe that the proposals include some positive  changes that should not be lost. Each of us will set out our own views on the way forward in our own consultation responses. 
Ahead of that, given the high level of uncertainty over the financial impact of the ESR on providers, we are jointly calling on the GOC to: 

1) Confirm that it will work closely with education providers and other stakeholders to address the likely financial impact of the proposed new framework and the sourcing of funding to deliver it

2) Commit to establishing that the new model is financially viable in all four nations before taking the final decision on approval


For AOP comment, please contact Vicky Vine, Communications Director at the Association of Optometrists, on [email protected] or telephone 020 7549 2046.

For College comment, please contact Catherine Bithell, Director of Member Services and Communications at the College of Optometrists, on [email protected] or telephone 07530 268 998.


Notes to editors

Association of Optometrists

The Association of Optometrists (AOP) is the leading representative membership organisation for optometrists in the UK. We support over 82% of practising optometrists, to fulfil their professional roles to protect the nation’s eye health. For more information, visit

The College of Optometrists
The College of Optometrists is the professional body for optometry. It qualifies the profession and delivers the guidance and training to ensure optometrists provide the best possible care. We promote excellence through the College’s affixes, by building the evidence base for optometry, and raising awareness of the profession with the public, commissioners, and health care professionals. For more information visit


The Optometry School Council 

The Optometry Schools Council (OSC) represents the collective views of UK institutions providing GOC accredited optometry programmes. Further details, including a list of members, can be found at