Response to the GOC consultation on changes to CET rules
Our response to the consultation, January 2021
This is our response to the GOC consultation on CET rules about the changes being made to the statutory rules as a result of the new elements being introduced in the revised CPD scheme from 2022. The consultation ran from December 2020 to January 2021.
Amendments to the GOC's CET rules
Q7. To what extent do you agree that the amended CET rules reflect the changes we are seeking to make to the scheme in January 2022?
Q8. Are any of the amendments unclear?
Please provide any additional comments.
We have not identified any significant issues with the amended CET rules presented in the consultation. However, it is unclear whether the amended rules incorporate all the necessary changes to implement the GOC’s new approach to CPD, because the GOC has not explained what changes it has made or how these link to the implementation of the new CPD scheme.
We have not been able to identify changes to reflect the following elements of the new CPD scheme:
- Moving away from a competency based system to one with four professional domains linked to the Standards of Practice (the amended rules frequently refer to ”competencies” which seems more appropriate to the current CET scheme than the new CPD scheme)
- The GOC having the power to introduce a fifth domain in which registrants would need to acquire CPD
We appreciate that it may be possible to implement these features of the new scheme under the proposed amended rules. However, it would be helpful if the GOC could confirm their approach on this to ensure we have understood their intentions correctly and that the amended rules are in fact appropriate for the new CPD scheme. It would also be useful for the GOC to better document how and why the CET rules have been changed to allow a better understanding of how the legislation underpins the scheme.
We have two specific comments on areas of the rules where we think more clarity is needed.
In rule 7, we understand the GOC’s policy intention is to remove the need for established providers to require prior approval for CPD content – a change which the AOP supports. Para 7(3) enables this approach, but para 7(1) is ambiguously drafted and could cause confusion. We assume the intention of para 7(1) is to provide that “unless permission has been granted by the administrator under para 7(3), any listed provider … shall apply to the administrator for the event to be approved”. We suggest para 7(1) is amended accordingly.
We have also noticed a drafting error - there appears to be no rule 8 in the amended CET rules, with listing going from rule 7 to rule 9. This will be a problem as for interpretation and coherence as, for example, rule 10 refers to rule 8.
Q9. Is there anything missing?
We have not identified elements that are necessarily missing, but have queried how the amended CET rules map so some features of the new CPD scheme in our answer to question 8.
Aligning CPD requirements for optometrists and dispensing opticians: introducing peer review for dispensing opticians
Q10. To what extend to you agree with introducing peer review for dispensing opticians?
Q11. What impact, if any, will introducing a mandatory requirement for peer review for dispensing opticians have?
Please use the box below to explain your answers above if required, thinking about what potential improvements or barriers this change could create.
We welcome the introduction of peer-review for dispensing opticians. Many DOs already choose to benefit from the learning experience provided by peer review. Making this a requirement would help provide this valuable learning experience for all DOs. We supported aligning this requirement in our response to the GOC Lifelong Learning Review consultation.
Q12. Do you have any comments in relation to amending the Rules to allow Council to set the CET provider fee at their discretion?
We accept the GOC’s reasoning for removing the reference to a set level, currently £45, for the annual provider fee. Whilst it does not make sense to fix the amount of the fee in legislation, we think it is important for the GOC to clarify its future intentions on the likely fee level and the process by which the GOC Council will set it. As a large provider of CET, an increase in the fee level would not greatly impact the AOP. However, the optical sector has many small CET providers such as Local Optical Committees which may not find it viable to continue to provide CPD if the fee rises significantly. The GOC should take this into account in setting the provider fee to avoid unnecessarily limiting the educational content offered to registrants.