AOP response to the GOC consultation questions

GOC question: What impact, if any, will introducing the proposed ‘Outcomes for Registration’ have on the expected knowledge, skill and behaviour of future optometrists?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Don't know

GOC question: Is there anything in the criteria in the 'Outcomes for Registration' that is missing or should be changed?

(Yes / No / Don't know)

AOP answer: Yes

As we have said in Section 1 of our consultation response ('Unclear minimum requirements to join the register'), in principle we support the move to higher-level requirements, and the current draft Outcomes are more clear, logical and fit for purpose than the drafts the GOC consulted on in 2018/19. However, the clinical content of the draft Outcomes is too high-level to provide confidence that all education providers using the new framework will train students to the necessary minimum standards to produce a 'safe beginner' optometrist. Of the seven outcome domains, only outcome 6 describes knowledge, skills and behaviours that are specific to optical practice, and then only those that are common across optometry and dispensing optics.

Indicative guidance

The GOC has said it will 'co-produce' with the sector an indicative guidance document to provide more detail on required clinical skills. We welcome this proposal, which would help providers to understand baseline expectations, and to construct programmes that can deliver safe beginner optometrists, while also enabling the guidance to be amended quickly in response to developments where needed. The indicative document would set a sector benchmark for course content, and it is right that the GOC and the sector should share responsibility for producing this; it would not be appropriate for the GOC to define such detail on its own.

However, we think the guidance must be given a clear formal role within the new framework, to ensure that providers cover all the necessary clinical topics and to mitigate the risk of undue variability in course content. It should be possible to do this while allowing education providers to adopt innovative approaches to delivering content – for instance by adopting a 'comply or explain' approach, which would require providers either to follow the guidance, or to explain why they have departed from it.

In working with the sector to develop this indicative guidance, the GOC should consider the approach taken by other regulators of healthcare professionals. For example, the GMC Practical skills and procedures document has been produced to supplement the outcomes for medical graduates by "defining the core diagnostic, therapeutic and practical skills and procedures newly qualified doctors must be able to perform safely and effectively". The GPhC Standards for the initial education and training of pharmacists includes an indicative syllabus as an annex alongside higher level outcomes for registration within the standards.

Verification process

We are pleased that the GOC plans to use the Delphi verification method to test the outcomes for registration. As we have argued in previous ESR consultations, using an accepted verification methodology should provide confidence about the appropriateness of the outcomes.

However, we are concerned about the tight timeline for the completion of this work over the autumn, at a time when academics will be busy adapting to delivery during the pandemic. This means that, as with the GOC's further work on the financial impacts of the ESR, there won't be an opportunity for stakeholders to consider and respond to the outputs from the verification process before the GOC decides whether to finalise the framework. This is not an acceptable consultation process.

GOC question: What impact, if any, will introducing the proposed 'Standards for Approved Qualifications' have on the expected knowledge, skill and behaviour of future optometrists and dispensing opticians?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Negative impact

GOC question: Is there anything in the 'Standards for Approved Qualifications' that is missing or should be changed?

(Yes / No / Don't know)

AOP answer: Yes

We have commented on the Standards in our responses to the questions in Section 3 of the GOC questionnaire. The specific changes we have suggested to the Standards are:

• Standard 1.2 should be supplemented with guidance for education providers on how to run robust and fair student Fitness to Train (FTT) procedures
• Standard 3.14 says that placements must be 'in one or more periods of time in more than one sector and more than one setting of practice'. We suggest this should be changed to "more than one period of time in more than one sector…"
• Standard 4 should be strengthened by an explicit requirement that the quality of supervision should not be affected by commercial pressures. This would bring the education Standards  into line with the GOC's Standards of Practice for individual and business registrants. This additional requirement could logically be added to S4.9 which already includes a statement about safeguarding patients 

We also suggest that Standard 2.3 should be expanded to require that where a course has provisional rather than full GOC approval, this fact, and its implications in the event of approval being withdrawn, is made clear to prospective students.

GOC question: The 'Standards for Approved Qualifications' include a proposal to integrate what is currently known as pre-registration training within the approved qualification (which must be either a regulated qualification (by Ofqual or equivalent) or an academic award listed on one of the national frameworks for higher education qualifications for UK degree-awarding bodies). What do you think the impact of this proposal will be on the expected knowledge, skill and behaviour of future optometrists and dispensing opticians?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Very negative impact

GOC question: Please explain your answer. Please consider what potential improvements or barriers of integrating what is currently known as pre-registration training within the approved qualification for future optometrists and dispensing opticians could create.

As we have said in Section 1 of our consultation response ('Weak rationale for a compulsory integrated model'), the GOC has still not set out the public protection rationale for moving to a compulsory integrated approach. We remain concerned about the likely costs and impacts of a compulsory integrated approach, and do not think the benefits the GOC has suggested the model will deliver can justify the risks and costs involved.

We are not aware of any evidence that the proposed approach will improve patient safety, for instance by reducing fitness to practise issues. The GOC has said the integrated model would meet students’ desire for more clinical content to be integrated with academic study, but this is entirely possible under the current optometry education model, which already allows providers to adopt an integrated approach, as some have done.

The GOC has also said the proposal will increase student choice, but imposing an integrated model on all providers arguably reduces choice, and could also mean that students would have to decide on their whole path to registration, including the setting of their clinical placements, before starting study. The financial implications of the proposal seem likely to involve a further year of student fees for optometry training, which could make the subject less attractive to students.

A compulsory integrated model may appear to tidy up the GOC's regulatory role in education, by clarifying accountability for education delivery, but we do not think that in itself justifies imposing this model on the sector. Creating a new web of contracts between education providers, assessment providers and clinical placement providers will bring significant new costs and complexity. This will create new challenges for the GOC and may not in reality do much to resolve difficult issues, such as the current shortage of clinical placements caused by the pandemic, which can only be addressed by collaboration between all those involved.

As we have said in Section 1 of our response ('Financial impact of the ESR and implementation timing'), we are most concerned that the GOC has not yet evaluated the potentially significant financial impact of the compulsory integrated model on education providers. We discuss the financial and delivery risks further in our answers to Section 4 of this consultation questionnaire, and recently set out our shared concerns in a joint statement with the College of Optometrists and Optometry Schools Council.

As we said in our 2019 consultation response, this model also heightens the risk that employers may have undue influence over the design and delivery of optometry education. The compulsory integrated model will also increase the risk of inconsistent training and assessment, by removing the current College Scheme for Registration which most optometry students currently undertake to join the register. This could ultimately affect patient safety.

GOC question: Do you agree or disagree with our proposal to replace our Quality Assurance Handbook for optometry and related policies with the proposed 'Outcomes for Registration,' 'Standards for Approved Qualifications' and 'Quality Assurance and Enhancement Method?' Please explain your response.

(Strongly agree / Agree / Neither agree nor disagree / Disagree / Strongly disagree / Don't know)

AOP answer: Don't know

We agree that the current education standards are out of date, too prescriptive and input focused and in need of revision, and that in principle, the new draft Outcomes and Standards are an improvement. If and when it is established that the new model is financially viable in all four nations of the UK, and that the other key risks and concerns we have identified in Section 1 of this response will be effectively mitigated, it would be appropriate for the new ESR framework to replace the existing Optometry Handbook. But that should not happen until these significant issues are addressed.

Those elements within the ESR framework that do not pose material risks could be implemented ahead of other parts of the framework to avoid unnecessary delay. However, it may be necessary to extend the lifespan of the current Optometry Handbook if the issues we have identified cannot be resolved in the limited time available under the current implementation timetable. We discuss this further in our response to the question about the timeline in Section 4 of the GOC questionnaire.

Standard 1: Public and patient safety 

GOC question: Please consider criterion S1.1 There must be policies and systems in place to ensure students understand and adhere to GOC's Standards for Optical Students and Standards of Practice.' Do you agree or disagree that both the GOC's Standards for Optical Students and Standards of Practice should be included in this criterion?

(Agree – it should be both the GOC's Standards for Optical Students and Standards of Practice / Disagree – it should be the GOC's Standards for Optical Students only / Don't know or Not sure)

AOP answer: Agree

While the requirement for students to register with the GOC remains in place, it is logical for both the student and practitioner Standards to be included in S1.1. However, it should be understood that each standards document has a different role and function. The Standards for Optical Students set out requirements for students from the very start of their pathway to registration, and throughout the course of their studies, while the Standards of Practice should inform what students are working towards through their learning towards registration.

GOC question: Please consider S1.2 – 'Concerns about a student's fitness to train must be investigated and where necessary, action taken and reported to GOC. (The GOC acceptance criteria and related guidance in Annex A should be used as a guide as to when a fitness to train matter should be reported to GOC.)' What impact, if any, will this criteria and the guidance in Annex A have on student's continuing fitness to train?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Positive impact

GOC question: Please explain your answer. Please consider what potential improvements or barriers of using the GOC acceptance criteria and related guidance in Annex A to the Standards as a guide as to when a fitness to train matter should be reported to GOC could create

As we have said in Section 1 of our response, the AOP provides legal support and representation to our student members, including in 'Fitness to Train' (FTT) investigations run by universities. Through this work we know that although some universities have robust FTT processes, often drawing on learning from courses in other healthcare disciplines, our members at other universities have faced unfair university investigation and hearing processes. This also creates a risk of inconsistent outcomes when a student faces both a university disciplinary process and a GOC investigation, bearing in mind that the GOC is the only healthcare professional regulator in the UK that requires student registration.

In summer 2020 we therefore proposed to the GOC that the new ESR framework should promote appropriate FTT processes within education providers, by setting out guidance covering the principles that education providers should follow when running investigations, hearings and appeals. We noted that other healthcare professional regulators, including the GMC and GPhC, publish comprehensive guidance about carrying out fitness to train processes for education providers.

We are pleased that the latest draft of Standard 1 includes draft guidance on when an FTT matter should be referred to the GOC by a university. This is a positive development. However, the draft guidance in Annex A to the Standards does not cover the key issues around fair internal processes in education providers and will need substantial revision and expansion to be fit for purpose. We have set out below the principles that we think the guidance needs to cover.

We understand from recent discussions with the GOC that it agrees guidance on these lines is needed. We note that the GOC could provide appropriate guidance on student FTT to education providers in advance of the ESR being implemented, and we think this issue should be taken forward as a priority whatever the next steps on the ESR, to ensure that current and future students are treated fairly.

Principles that education providers' Fitness to Train processes should follow

Investigations

Universities should be given clear guidance on how to conduct an investigation appropriately which would include:

1. Investigators and decision makers must be separate people with no role cross over 
2. The burden of proof
3. Investigations must be clear, fair, transparent and proportionate
4. Students must be informed that they are under investigation and why as well as being provided with appropriate support by the institution
5. The institution must provide information on how the investigation will be carried out, what the student can expect, how they will be informed of progress in an investigation and the name of the person they can contact from the investigation team
6. Reasonable adjustments

Hearings

7. The burden of proof
8. How allegations should be drafted (clearly, concisely and providing specificity where possible)
9. Disclosure of evidence to the student
10. Admissibility of evidence in FTP hearings
11. Outcome stages of an FTP hearing (ie Is the allegation proved? Is FTP impaired as a result? Is a sanction necessary? What should it be?
12. Reasonable adjustments

Appeals

13. Appeal processes should be clearly defined and available to all students (to include information on the Office of the Independent Adjudicator for Higher Education) 

GOC question: The GOC is unique amongst healthcare regulators in registering students, and whilst we may consult on whether we should continue to register students at a later date, we anticipate continuing to register students for the time being. Please consider criterion S1.4 'Students on admission and at regular intervals thereafter must be informed it is an offence not to be registered as a student with the GOC at all times whilst studying on a programme leading to an approved qualification in optometry or dispensing optician.' What impact, if any, will this criterion have upon providers and their students studying approved qualifications for optometry and dispensing opticians?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Positive impact

In our view it is sensible to include this criterion as long as the GOC student registration requirement remains in place. It is important that students are made aware that they need to register with the GOC.

More generally, we think the current requirement for students to register with the GOC is unnecessary. It can also lead to a risk of inconsistent university and GOC (FTT) outcomes, as we have outlined in our comments on S1.2 above. We understand that the GOC plans to revisit whether to remove this requirement through legislation, and hope that it does so soon.

GOC question: Looking at the proposed Standard 1 and supporting criteria, are our expectations clear and proportionate in your/your organisation's view?

(Yes / No / Don’t know)

AOP answer: Yes

Standard 2: Admission of Students

GOC question (on S2.1): Our research has shown that all UK healthcare regulators have an English language requirement for overseas students applying to for admission to programmes in the UK that they approve. What potential improvements or barriers, if any, might this criterion create for providers of approved qualifications and their students?

This seems a sensible admission requirement. It makes sense for the GOC to be consistent with the other healthcare regulators in requiring English language for admission to approved programmes, because of the importance of communication, both in healthcare teaching and care delivery.

GOC question: Looking at the proposed Standard 2 and supporting criteria, are our expectations clear and proportionate in your/your organisation's view?

(Yes / No / Don't know)

AOP answer: Yes

Standard 3 – Assessment of Outcomes and Curriculum Design

GOC question (S3.11): We think it's important that we specify that the qualifications we approve must either be a regulated qualification or an academic award listed on one of the national frameworks for higher education qualifications to ensure that approved qualifications sit within an external quality controlled and regulated academic framework. What impact, if any, will this criterion have for providers of approved qualifications and their students?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Positive impact

We support the proposal to require that any qualification leading to registration be either a regulated qualification or listed academic award. This will provide additional independent oversight of academic standards and would prevent a non-academic organisation such as an employer seeking GOC approval for an unregulated qualification leading to registration.

However, we note that the introduction of this requirement does not in itself require or justify the separate proposed requirement that the learning leading to registration must be delivered through a single qualification through a Single Point of Accountability. As we have said in our answer to the question about the integration of the education programme for registration in Section 2 of this questionnaire, the GOC has not made the case for compulsory integration of the entire pathway to registration, which would create a range of financial and delivery risks.

There is already a de facto requirement for students to complete Stage 1 of the current education system through a regulated qualification. This is because the Stage 2 College Scheme for Registration requires that entrants have a Certificate of Clinical Competence which is normally only provided to those who have achieved at least a 2:2 degree award in an approved optometry qualification.

GOC question (S3.18):  Please consider criterion S3.18 – 'Equality and diversity data and its analysis must inform curriculum design, delivery and assessment of the approved qualification. This analysis must include students' progression by protected characteristic. In addition, the principles of equality, diversity and inclusion must be embedded in curriculum design and assessment and used to enhance student's experience of studying on a programme leading to an approved qualification.' This is a new requirement not currently included in our Quality Assurance Handbooks and builds on the intention explored in previous consultations for a greater emphasis on evidencing a commitment to equality, diversity and inclusion by providers of approved qualifications. What impact, if any, will this criterion have upon providers of approved qualifications and their students?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Positive impact

In principle, we support the intention that course design and delivery should take account of equality and diversity data. However, we think the GOC should make clear its expectations of providers in respect of this Standard. We understand that education providers already pay close attention to equality and diversity issues, and it is not clear what if anything the GOC would expect providers to do beyond that.

The requirement to collect and analyse this data could be an additional cost for providers, but is potentially of value to the wider sector if it can be published or otherwise shared on an anonymised basis.

GOC question: Please consider the criteria which support Standard 3. What impact, if any, will they have upon the measurement of students' achievement of the outcomes leading to the award of the approved qualification on providers of approved qualifications and their students?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Don't know

Assessment

The new draft Standard 3.7 for education providers requires that student assessment criteria "must be explicit and set at the right standard", but does not specify what the "right" standard is. It is important that the sector has a clear shared understanding of how the GOC will ensure that appropriate standards of assessment are in place, particularly given that the proposed shift to an integrated model will remove the common final assessment that the College Scheme for Registration currently provides for the large majority of optometry students. 

The GOC has told us that the requirement in Standard 3.7 for providers to use "an appropriate and tested standard-setting process" will mitigate risks of inconsistent standards, and that the GOC quality assurance process will pay close attention to the standard-setting process each education provider is using. This emphasises the need for the GOC education assurance process to be properly resourced, expert and transparent, so that stakeholders can be confident that assessment standards in each education provider are comparable and robust.

Clinical experience

Standard 3.14 says that placements must be 'in one or more periods of time in more than one sector and more than one setting of practice'. We suggest this should be changed to "more than one period of time in more than one sector…". In practice, it may not be feasible for providers to deliver placements in more than one sector and setting of practice within a single time period. More importantly, in principle we think a requirement for more than one period of clinical experience in the course of optometry training is desirable, particularly given the long-standing ESR policy intention to give students earlier clinical experience. However, we recognise that this could add further to the capacity and resource challenges for education providers that we have identified in our answers to Section 2 (integrated delivery) and Section 4 (financial impacts) of this questionnaire.

S3.14 includes one of the few defined input requirements in the new Standards, that students receive 'at least 1600 hours / 48 weeks of patient-facing professional and clinical experience'. We understand this is intended to be roughly equivalent to experience gained by trainees in the current Stage 2 pre-registration period. We understand the rationale for this, but it may create unintended consequences in combination with financial pressures that the ESR framework could create. In particular, our hospital optometrist members are concerned that that this requirement may reduce the likelihood and viability of placements in the vital hospital optometry sector.

This is because the 48 weeks required would need to be allocated across all the different types of clinical experience for students' learning pathway, including elements that are currently part of the undergraduate optometry programme. This could make the current pre-reg placements in hospital settings, which hospitals rely on as a stepping stone to work in that mode of practice, less viable.

This is a potentially serious workforce issue, both for optometry and the wider NHS. Hospital clinical experience for optometry students is already under severe pressure because of the particular challenges of funding (since hospital pre-reg placements currently receive no NHS funding) and COVID-19, which we discuss further in our answers in Section 4 on financial impacts.

Stakeholder feedback

S3.4 requires that curriculum design, delivery and assessment is informed by "feedback from a range of stakeholders such as patients, employers, placement providers, members of the optometry team and other healthcare professionals". This is a potentially wide-ranging requirement, and it is not clear from the Standard how the GOC expects feedback from stakeholders to be used. The requirement to obtain feedback is also likely to be an additional cost on providers.

GOC question: Please consider the criteria which support this standard. What impact, if any, will these criteria have for providers of approved qualifications and their students?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Negative impact

Assuring the quality of workplace supervision

We support the provisions in Standard 4 (mainly in S4.9, S4.10 and S4.11) that set requirements for the quality of clinical supervision in education programmes. It is vital that the new framework promotes good-quality supervision in clinical settings. A survey of AOP members we conducted this year showed that a significant minority of recent pre-registration trainees found the quality of supervision they had received inadequate at least some of the time.

We think the requirements in Standard 4 should be strengthened by an explicit requirement that the quality of supervision should not be affected by commercial pressures. This would bring the education Standards into line with the GOC's Standards of Practice for individual and business registrants. This additional requirement could logically be added to S4.9 which already includes a statement about safeguarding patients.

Our recent member survey shows clearly that where supervision works well in the current system, this is often due to the 'beyond the call of duty' efforts of supervisors who are not properly funded to carry out their role. This is a systemic weakness in the current funding arrangements for optometry education. The requirements on supervision quality in Standard 4 – which are vital if the new framework is to work effectively – will carry additional costs for education providers and extra work for placement supervisors. This is one of our key concerns about the financial impact of the new framework, as discussed in our responses to Section 4 of the questionnaire.

GOC question: Please consider the criteria which support Standard 5. What impact, if any, will they have for providers of approved qualifications and their students?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Don't know

Overall, we agree that the new framework should be less prescriptive in specifying precise resource inputs than the current Handbook. Our academic members have said that the current framework is overly prescriptive and 'tick box' in defining course inputs. Standard 5 sets out reasonable expectations about course leadership, resources and capacity.

However, as with other aspects of the framework the lack of detail will make additional demands of the GOC's approval and assurance mechanisms to ensure the safe delivery of education programmes. If the GOC cannot adequately assure education programmes' capacity to safely deliver courses within available resources, there is a risk that courses are unexpectedly withdrawn - either because of financial non-viability or because the GOC withdraws approval. When this happens, as it did in 2019 because the GOC withdrew its provisional approval for an optometry course, it has a significant negative impact on the affected students and may damage wider public confidence in optical education.

A particular risk area for course viability and safety is the staffing of education programmes. The GOC must assure itself that all programmes have staff, especially in leadership levels, of adequate experience and capability to deliver courses. There is anecdotal evidence that it is already challenging for some optical education providers to source appropriately skilled and experienced staff teams. The new requirements imposed on providers by the ESR framework may add to the stress on staff capacity within education providers.

From a strategic standpoint, we do not think that the ESR framework and delivery plan overall provides adequate confidence that the new education system can be safely delivered within the resources, education and placement capacity that will be available to providers.  Our responses about financial impacts in Section 4 further discuss these risks.

Quality Assurance and Enhancement Method

GOC question: What impact, if any, will the proposed quality assurance and enhancement framework of annual, thematic, sample-based and periodic reviews have for providers of approved qualifications and their students?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Don't know

We support the move to an outcomes based assurance system in principle, but this is a significant shift in approach for GOC educational oversight, creating significant risks and challenges that will need to be well managed.

Adequate resourcing for GOC assurance and approval

In our response to the last ESR consultation in 2018-19, we said that the proposed new approach would require robust GOC validation and quality assurance processes, which must be properly resourced. In assessing proposed new courses and monitoring those that are approved, the GOC will need adequate capacity to assess whether a wide variety of providers are delivering outcomes and meeting standards that are framed in a high-level way, and that allow a great deal of variation and scope for innovation in course delivery and assessment methods.

AOP members working in education providers have told us they think the GOC will need significant extra resources, including expertise in pedagogy as well as in optics, to do this effectively. As well as ensuring that visitor panels have the right skills, the GOC will need to devise and support a clear and robust quality assurance process, which visitors can apply effectively and consistently when reviewing an increasingly diverse range of education programmes.

The task of assurance and approval will be increased in complexity because of the phased timeline for transition to the ESR framework that the GOC has set out. This will require simultaneous oversight of:

• Existing approved providers offering and eventually 'teaching out' courses under the current framework, including the Scheme for Registration
• Existing providers setting up new courses under the ESR framework or transitioning existing courses
• New providers who may be proposing to deliver programmes in innovative ways

Given the vital role of effective GOC oversight, the GOC must ensure that its education function is fit for the new challenges it will face, and that its decisions on education issues are evidence-based, transparent and accountable. The GOC should therefore make an honest and transparent assessment of the resourcing it will need in its education assurance and approval team to be fit for purpose in the complex transition to a more complex education environment

Approval of new qualifications 

In principle it is reasonable for the GOC to take a risk-based stratification approach to the assessment and quality assurance of providers seeking to operate under the ESR. In the approach set out by the GOC, new courses developed by unfamiliar providers have been classified as high risk, while new courses from SPAs involving established providers have been classified as medium risk. We think the GOC's approach to risk should also take into account the level of innovation, in design and delivery, of proposed new courses.

The AOP opposed the proposal for an optometry degree apprenticeship on which a 'trailblazer group' of optical sector employers consulted in 2019. As we set out in our consultation response our view is that a mainly workplace-based route to registration as an optometrist, in optical practices that have a strong retail as well as clinical focus (as most do), would pose significant risks to patient safety and public confidence in the profession.

Given the concerns about the ESR that we have highlighted in this consultation response – including unclear minimum requirements to join the register, the risk of inconsistent and inadequate assessment of students, the need to assure the quality of workplace supervision and fund it properly, and the challenge of ensuring robust GOC oversight – we do not think the new framework in its current form could ensure the safety of any revised proposal for an optometry degree apprenticeship. Given the inherent risks in the degree apprenticeship model, any application for GOC approval of a revised proposal should automatically be treated as high-risk by the GOC, and subject to full public scrutiny and consultation. This should be the case even if the proposal involves an established provider of optometry higher education.

Governance

Decisions made in the GOC's education and quality assurance process should be transparent, evidence based and accountable. AOP members who have experience of the current GOC assurance approach have raised concerns that the recommendations of Education Visitor Panels are sometimes overridden without any explanation or justification. While the GOC Council has executive authority and 'may choose to accept, reject or modify advice from our Education Visitors in relation to the qualification under consideration', they must take into account and be led by the evidence. Reasons for decisions should therefore be fully documented and justified. It is also a concern that the statutory oversight provided by the GOC's Education Committee appears to have been diluted in effectiveness by the merger of its statutory committees.

Quality Assurance and Enhancement Method Timescale

GOC question: What impact, if any, could the proposed timescale have on the ability of providers to develop, seek approval for and recruit to a 'new’ or 'adapted' approved qualification that meets the outcomes & standards in your/your organisation's view?

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Very negative impact

We think the ESR implementation timeline as it stands presents significant risks to patient safety and public confidence, because of factors including the uncertain financial impact of the new framework, the inadequate and apparently rushed process for this final consultation, and the impact of the COVID-19 pandemic.

The GOC should therefore review the timeline in the light of the responses to this consultation and the other available evidence, and reset it as far as necessary to manage these risks.

Financial impact

Our joint statement with the College of Optometrists and the Optometry Schools Council on 1 October 2020 set out our concerns that uncertainty over the funding of the proposed new education framework could significantly disrupt future optometry education and training, affecting patient safety and public confidence. We, along with the College and the OSC, therefore called 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 sources of funding to deliver it
2. Commit to establishing that the new model is financially viable in all four nations of the UK before taking the final decision on approval

In this consultation response we have addressed the GOC's specific consultation questions, and proposed changes to improve the new framework if it is introduced. However, these changes would not mitigate our over-riding concern about the need to confirm the financial viability of the new framework before it is implemented. It is vital that we and other stakeholders have a proper opportunity to comment on the GOC's commissioned assessment of the ESR's financial impact before the GOC takes a final decision. 

Inadequate consultation process

Although the ESR project has been running since 2016, the material on which the GOC is currently consulting has only been developed in the past year, after the 2018-19 consultation on an earlier set of draft standards and learning outcomes led to wholescale revision. The delivery timeline for completion and approval of the ESR framework by December 2020 appears to be unnecessarily rushed, and will not enable stakeholders to engage properly with key aspects of the GOC's ongoing work on the ESR.

Both the verification process for the Outcomes for Registration and the (only recently announced) financial impact evaluation are due to report by late October / November, after the end of the current public consultation. This is bad practice in terms of engagement and proper scrutiny. As a result, we do not think the GOC is likely to be able to take a properly informed final decision on approval of the framework by the end of 2020.

Impact of the pandemic

The COVID-19 pandemic has had a massive impact on the optical sector (including on the availability of clinical placements in both primary and secondary care for students and pre-reg trainees) as well as on education providers across the UK. However, the GOC does not seem to have taken this into account at all in its ESR implementation planning.

The impact of the pandemic on pre-reg placements is not yet clear, and we are currently surveying our pre-reg members to assess their experience. However, there is already significant anecdotal evidence that offers of placements are being deferred or withdrawn altogether. This may lead to a substantial, and potentially sustained, distortion in the profile of the 'pipeline' of students passing through the Scheme for Registration and onto the GOC register. Moving to a significantly different education delivery model and mandating integration of the route to registration would create substantial risk in this context.

The GOC has suggested that the pandemic has strengthened the case for quick delivery of the ESR framework, because of the flexibility it would create for innovative and responsive education delivery. The AOP supports agile regulatory responses from the GOC to meet the challenges created by COVID-19, but those responses need to be properly designed, transparent and targeted to the actual emerging issues. For example, we have already supported temporary changes to the GOC's current optometry education Handbook to reflect the impact of the pandemic.

Similarly, it would now be appropriate for the GOC to expedite changes to IP placement requirements to remove barriers to completion of the qualification, because new eye care services created in response to the pandemic are increasing the demand for optometrists with therapeutic competency. However, the ESR framework is a massive structural change whose costs and impacts are still not clear, as we have noted in this response. The GOC has suggested that it is necessary to keep to the current implementation timetable because some providers are keen to be 'early adopters', using the ESR framework from 2022 onwards. We are not aware of any providers who have expressed interest in this.

Equality and diversity impacts

GOC question: We want to understand whether our proposals may discriminate against or unintentionally disadvantage any individuals or groups sharing any of the protected characteristics in the Equality Act 2010. Do you think our proposals will have a negative impact on certain individuals or groups who share any of the protected characteristics listed below? (Please select all that apply)

GOC question: We also want to understand whether our proposals may benefit any individuals or groups sharing any of the protected characteristics in the Equality Act 2010. Do you think our proposals will have a positive impact on any individuals or groups who share any of the protected characteristics listed below? (Please tick all that apply)

(Age / Disability / Gender reassignment / Marriage and civil partnership / Pregnancy and maternity / Race / Religion or belief / Sex / Sexual orientation / None of the above /Don't know)

AOP answer: We are not aware of any evidence that the ESR overall will have any positive or negative impacts for individuals or groups sharing these characteristics.

Impact on other individuals or groups

GOC questions: Do you think any of the proposed changes will impact – positively or negatively – on any other individuals or groups? For example, students, patients and the public, current providers of approved qualifications, placement providers, employers and devolved nations?

Please describe the impact and the individuals or groups concerned. We are particularly keen to understand further any financial or other impacts we haven't considered in our accompanying impact assessment.

(Very positive impact / Positive impact / No impact / Negative impact / Very negative impact / Don't know)

AOP answer: Very negative impact

Our joint statement with the College of Optometrists and the Optometry Schools Council on 1 October 2020 set out our concerns that uncertainty over the funding of the proposed new education framework could significantly disrupt future optometry education and training, affecting patient safety and public confidence. We, along with the College and the OSC, therefore called on the GOC to:

• 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 sources of funding to deliver it
• Commit to establishing that the new model is financially viable in all four nations of the UK before taking the final decision on approval

In this consultation response we have addressed the GOC's specific consultation questions, and we have proposed changes to improve the new framework if it is introduced. However, these changes would not mitigate our over-riding concern about the need to confirm the financial viability of the new framework before it is implemented. 

As the joint statement of 1 October 2020 set out, we are deeply concerned 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 advice on this issue, to inform the GOC Council's decisions on the new framework. However, the final report will not be available until after the end of the consultation. This 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 2020.

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 and cutting the number of trained optometrists available to join the register each year. Other providers may struggle to deliver the new requirements, leading to sub-standard training. Either outcome would threaten patient safety and public confidence in the profession – the things the GOC exists to protect. 

In considering the current consultation, and in our response to the GOC's previous consultation on the ESR, we have identified a number of specific negative impacts and risks that the GOC will need to manage if the new framework is introduced. These include:

Education providers

Providers will become responsible for organising and quality-assuring all student clinical experience, including experience that currently falls into the separate pre-registration placement, for students over the entire route to registration. This is a significant and resource-intensive activity, particularly since the new framework rightly includes robust requirements on the quality of clinical supervision, as discussed in our comments on Standard 4.

The requirement for an integrated qualification is likely to require education providers to enter into contractual arrangements with other bodies such as placement providers and possibly assessment providers. This will generate costs and complexity.

As we noted in our response to the last ESR consultation, education providers will generally rely heavily on employers to deliver clinical experience for optometry students. There is a risk that employers which provide a large volume of student's clinical experience could have an undue influence on the way programmes are designed and run.  This could affect (or be perceived to affect) the academic rigour and credibility of optometry training.

Students

Following the ESR it is likely that education providers will choose to run four-year programmes to include the clinical experience which is currently provided through pre-registration training. This will mean additional course fees for students. It is also unclear whether the level of salaries currently available to pre-registration trainees – who are employees of the placement provider – will remain available to students under the new framework.

As discussed in our response to the consultation question on the compulsory integration of academic study and clinical experience, the new framework has the potential to reduce student choice. This is partly because it removes the current choice between integrated and non-integrated routes to registration, and partly because students will have to decide on their whole path to registration, including the setting of their clinical placements, before starting study.

Hospital placements

Providing optometry students with meaningful clinical experience in hospital settings is already a challenge because of the absence of NHS funding for placements. In our response to the consultation question on Standard 3 we have noted that the required 48 weeks of clinical experience would need to be allocated across all the different types of clinical experience for students' learning pathway, including elements that are currently part of the undergraduate optometry programme. This could make the current pre-reg placements in hospital settings, which hospitals rely on as a stepping stone to work in that mode of practice, less viable. This is a potentially serious workforce issue, both for optometry and the wider NHS.