GOC's Education Strategic Review FAQs

Funding is still a real risk. Optometry courses are likely to be more expensive for universities to deliver under the ESR, partly because universities will probably arrange and quality-assure the practice-based learning and experience that most students currently obtain through their pre-reg placement after graduation.

That will have some benefits for students – for instance, it may reduce the risk of students being left to fend for themselves if a pre-reg placement falls through, as happened in some cases during the COVID-19 pandemic. But it will come at a cost – including to students, who are likely to incur higher student debt in future because of longer university courses.

Initial education and training for optometry is currently less well funded than for other healthcare professions including dentistry and pharmacy, and we are still concerned that universities may struggle to deliver the ESR without extra funding. The GOC and the sector bodies are now working together to explore options for extra funding for optical professional training. If it seems during the ESR implementation period that limited funding to deliver the ESR may threaten the future provision of optometry courses, with implications for patient safety, the AOP will expect the GOC to take whatever steps it can to ensure continued provision of training and safeguard patients.

This is still a risk. The GOC has said it will work with education providers and the College of Optometrists to help them plan to adopt the new ESR requirements. After the AOP and other sector bodies jointly asked the GOC in January 2021 to clarify how far providers would be required to change their current education models, the GOC confirmed that the choice of operating model for the award of approved qualifications is a decision for providers to make in consultation with stakeholders, and that the GOC is not seeking ‘change for change’s sake’.

This has provided some reassurance that providers will be able to migrate their existing education models without unnecessary disruption or cost. However, it will be important for the GOC and the sector to monitor the impact of the ESR closely during the implementation period, and for corrective action to be taken if the new requirements are causing unacceptable disruption.

Given the changes the GOC has made while finalising the ESR requirements in recent months, we don’t think this is a significant risk. In fact, some of the new features of the GOC’s education requirements should reinforce the academic status of optometry training. For instance:

• New optometry qualifications must be set at Masters level, in line with a recommendation by the Quality Assurance Agency (QAA) 
• Any qualification must also be either a recognised academic award or regulated qualification

These requirements aren’t included in the current GOC education handbook, and the current College Scheme for Registration doesn’t lead to a Masters level qualification.

It will not be any easier to seek GOC approval for a degree apprenticeship under the new ESR requirements than under the current GOC handbook. If anything, the GOC approval process for future qualifications should be more rigorous, because it will be based on an overall assessment of whether the proposal would meet the ESR outcomes and standards, rather than what could be considered the ‘tick-box’ requirements for student experience in the current GOC education handbook. 

It remains possible that a provider may seek GOC approval for a degree apprenticeship qualification in future (although this would now have to be a higher degree apprenticeship at Masters level). The AOP would oppose any such proposal, for the reasons we set out in our response to the degree apprenticeship consultation in 2019. In particular, we believe that in the light of our members’ own experiences, a mainly workplace-based route to registration as an optometrist in a mixed clinical and retail environment will not give students the necessary full range of skills to develop into a safe practitioner in a range of clinical settings, or to withstand the recognised commercial pressures on optometrists.

Because of these concerns, we argued in our response to the 2020 ESR consultation that any application to the GOC to approve a degree apprenticeship in optometry should automatically be treated as high-risk and subject to full consultation.

Under the new ESR requirements the GOC will only approve qualifications that lead straight to registration, rather than the current two-stage process – the undergraduate degree followed by the College Scheme for Registration – that most (but not all) optometry trainees currently follow.

It will be for education and assessment providers, including universities and the College, to decide how they work together to provide the new qualifications, and how clinical placements and academic study are integrated within each qualification.

This will depend on discussions between the GOC, universities and the College. The GOC has said it expects most universities will aim to begin programmes under the new ESR requirements from autumn 2023 or 2024, but that it will work with education providers individually to support them through the transition. It seems possible that some providers will still offer courses under the pre-ESR education handbook in 2023 or beyond, and if so the Scheme for Registration will also need to stay in place until students on those courses have completed it. The GOC has said it expects the Scheme will be required until at least 2030.

No – the ESR requirements will only apply to the new qualifications to be approved by the GOC. Optometrists who are already registered, and students pursuing existing approved qualifications, will not be affected by this change.

We are no longer concerned about this, because the GOC has now agreed to give a formal role to the new indicative guidance on the clinical content of optometry and DO training that is being commissioned to supplement the high-level ESR outcomes. The GOC will require universities that seek GOC approval for a qualification either to demonstrate that their programme delivers the content set out in the indicative guidance, or to justify why they have taken a different approach. This will then be assessed as part of the GOC’s approval process for new qualifications.

The AOP suggested this ‘comply or explain’ approach during the 2020 consultation process, because it will ensure firm minimum clinical requirements for optometry education while also enabling universities to develop new approaches to the way they deliver programmes, drawing on the latest clinical developments.

Our members have told us the quality of supervision of pre-reg trainees in the current system, and the support given to their supervisors, is not always good enough. In summer 2020 we ran a member survey on pre-reg supervision experience; a substantial minority of the current and recent pre-reg trainees who took part told us the support they received was either “sometimes adequate and sometimes less than adequate”, or “less than adequate most of the time”. This is a significant concern and demonstrates the need for better funding of clinical placements in optometry. It is also one of the reasons why the AOP opposes the idea of a degree apprenticeship in optometry.

The same concerns will apply to the learning and experience in practice that will be integrated into new qualifications under the ESR. Although our undergraduate student members tell us that they value early clinical experience in their studies, and would welcome more of it, we also know that it creates cost and complexity for universities. This is one of the reasons why we and others have flagged funding as one of the big risks associated with the ESR.

Because of the concerns our members have raised about the quality of clinical supervision, we urged the GOC to include in the new standards a requirement for education providers to ensure that commercial pressures don’t affect the quality of supervision on placements. We are pleased that the GOC listened to us and has introduced this important safeguard. However, education and placement providers will only be able to provide high-quality supervision if the resources are available for them to do so. This is one reason why it remains vital for the GOC and the sector to manage the risks around future funding for optometry education.

It seems likely that many trainees will still undertake a long clinical placement towards the end of their training, in a similar way to the current pre-reg placement. Whether such placements are salaried in the same way as pre-reg placements will be for placement providers, working with education and assessment providers, to decide.

The funding of student learning and experience in practice is one of the key outstanding issues on the ESR that we and others remain concerned about, and the sector is working together to explore options for more generous funding of optical professional education in each part of the UK.

Our response to the GOC’s 2020 consultation on the ESR set out eight key concerns, and we have summarised our current view on each of them below.

Financial impact and implementation timing

As discussed in FAQ [1] and [2], we are still concerned that universities may struggle to deliver the ESR requirements without extra funding. If it seems during the ESR implementation period that funding problems may threaten the future provision of optometry courses, with implications for patient safety, the AOP will expect the GOC to take whatever steps it can to ensure continued provision of training and safeguard patients.

Weak rationale for a compulsory integrated model

We still think the GOC should do more to explain the benefits of the new model, under which it will only approve qualifications that lead straight to registration rather than the current two-stage process, and why these benefits justify the costs involved. As discussed in FAQ [2] the GOC has said that the choice of operating model for the award of approved qualifications is a decision for providers to make in consultation with stakeholders, and that the GOC is not seeking ‘change for change’s sake’. This gives some reassurance that providers will be able to migrate their existing education models without unnecessary disruption or cost. However, it will be important for the GOC and the sector to monitor the impact of the ESR closely during the implementation period, and for corrective action to be taken if necessary. 

Unclear minimum requirements to join the register

As discussed in FAQ [9], we are no longer concerned about this because the GOC has now given a formal role to the new indicative guidance on clinical content that is being commissioned to supplement the high-level outcomes in the ESR framework. This will ensure firm minimum clinical requirements for optometry education.

Risk of inconsistent and inadequate assessment of students

We said in our 2020 consultation response that it was unclear how the GOC will ensure that appropriate standards of assessment are in place. After further discussion with the GOC, we understand that student assessment will be a core focus of its new qualification approval process and quality assurance work. We welcome this, but it highlights the need for the GOC to ensure that its education oversight and quality assurance functions are robust and properly resourced (see below).

Assuring the quality of workplace supervision

As discussed in FAQ [9], because of the concerns our members have raised about the quality of clinical supervision, we urged the GOC to require education providers to ensure commercial pressures don’t affect the quality of supervision on placements. We are pleased that the GOC listened to us and has added this important safeguard to the ESR standards. However, education and placement providers will only be able to provide high-quality supervision if the resources are available for them to do so. This is one reason why it remains vital for the GOC and the sector to manage the risks around optometry education funding.

Need for effective GOC oversight and quality assurance

Our October 2020 consultation response emphasised the need for the GOC to develop the capacity to assess and quality-assure a wide variety of education programmes, and the likelihood that this will need significant extra resource. The GOC has said it will put the necessary resources in place. The resourcing and effectiveness of the GOC’s education processes is another risk factor that the sector will need to monitor during the implementation phase of the ESR.

The ESR and degree apprenticeships

As discussed in FAQ [4], a provider may in future seek GOC approval for a higher degree apprenticeship qualification under the ESR requirements. The AOP would oppose any such proposal, for the reasons we set out in our response to the degree apprenticeship consultation in 2019. In particular, we believe that in the light of our members’ own experiences, a mainly workplace-based route to registration as an optometrist in a mixed clinical and retail environment will not give students the necessary full range of skills to develop into a safe practitioner in a range of clinical settings, or to withstand the recognised commercial pressures on optometrists.

Because of these concerns, we argued in our response to the 2020 ESR consultation that any application to the GOC to approve a degree apprenticeship in optometry should automatically be treated as high-risk and subject to full consultation.

Student Fitness to Train process and guidance

In our 2020 consultation response we noted that some AOP student members have faced unfair Fitness to Train investigation and hearing processes at university, explained that we had previously asked the GOC to include guidance on this in the new ESR standards, and set out how we thought the draft guidance on which the GOC was then consulting needed to be changed to be fit for purpose.

We are pleased that the GOC has substantially expanded and improved the guidance in the final version of the standards. This should help to ensure that our student members and other optical students receive fair treatment when universities investigate Fitness to Train concerns in future.