Feedback to the GOC on proposed extension of temporary changes to the Optometry Handbook

Our response to the consultation, April 2021

Optometrist at work

This is our response to the GOC’s proposal to extend the modifications to education requirements through temporary changes to the Optometry Handbook and supervision policy, which were originally introduced in August 2020 to allow optometry courses and pre-registration placements to be delivered in a safe and effective way during the pandemic.

Our response

We welcome the GOC’s proposal to extend the modification of its education requirements. Continuing uncertainty related to COVID-19 makes it too early to return to the pre-pandemic education requirements. Extending these temporary changes should help to manage the ongoing impact of the pandemic on students, pre-reg trainees, education providers and placement providers. Our academic members have told us that extending the temporary changes as soon as possible will be vital to their planning and providing as much certainty as possible to their students. Provided the GOC Council is satisfied that the available data shows the changes are not damaging standards of education and training, the GOC should confirm the extension of the temporary changes as soon as possible in order to give education and placement providers time to plan for the coming year, and to set clear expectations for students and trainees.

We know through our regular engagement with our members who are students and pre-registration trainees, education providers and employers that the last year has been very challenging and that there is still a high level of uncertainty about how the pandemic and its after-effects will impact on optometry education and training. We conducted a survey of AOP members undertaking, or expecting to soon start, pre-registration during September and October 2020 in order to understand how the pandemic had impacted their placements, results of which were shared with the College and GOC. We have also discussed the impact of COVID-19 regularly with the AOP Student Committee and pre-reg representatives, and the academic members on AOP Council.

In the light of member feedback, we have set out recommendations below about how the learning experience during the pandemic could be improved, and its knock-on impacts managed. Responsibility for managing these issues lies across the whole sector - with the GOC, education, qualification, and placement providers, and with support from the major optical sector bodies. We think the most important actions and principles are:

  • Providing students and pre-registration trainees with clear and regular communication about the arrangements for their education and training
  • Providing clear expectations about the likely timelines in which students and trainees should expect to qualify, as far as possible
  • Ensuring ongoing confidence in the standards and consistency of optical education
  • Supporting the welfare, including mental health, of all students and trainees
  • Ensuring fairness in assessment for students and trainees compared to those qualifying before the pandemic
  • Continued cross-sector work involving the GOC, education providers, employers and  representative bodies to address the impact of the pandemic on education, and particularly on the pre-registration period


A number of our pre-registration members have raised concerns with us, including through our 2020 survey, about the clarity, frequency and timeliness of the communication they have received about their training. While members recognise the immense challenges that university optometry schools and the College of Optometrists have faced during this period, it is vital that they communicate clearly and regularly with students and trainees about how learning, assessment and placements will take place.

Extending the temporary education changes as soon as possible should help education providers to plan activity and communicate clearly to students and trainees. Education providers should also provide students and trainees with realistic and clear expectations, as far as possible, about the likely timescales for completing their studies. This should help them plan their own activities and help support wellbeing overall during what has been a stressful time.

Confidence in modified learning experiences

Whilst students and trainees will receive a modified learning experience because of COVID-19 it is vital for them, and the wider sector, to have confidence that adequate standards and consistency are being maintained. Some of our student and pre-reg members have expressed worries about the impact of reduced clinical experience on their learning. If the GOC Council agrees to extend the current temporary changes, it will be important for the GOC to send a clear message that standards are being maintained.

Any concerns raised by students should be taken seriously, but some of the concerns may reflect perceptions of what the ‘normal journey’ leading to registration should be. The current Handbooks include detailed and tightly specified experiential requirements, but as the new ESR framework demonstrates, a variety of learning experiences can produce competent registrants. In some ways the temporary changes introduced in response to the pandemic foreshadow the new ESR education framework, which will allow greater flexibility about how courses are delivered in order to produce safe beginner practitioners.

Managing education delivery and delays

A key concern has been the availability of pre-registration placements due to pressures on employers and lengthier times to complete registration. There should be a continuation of cross-sector work to look at the pressures on the pre-registration period and encouragement and support for employers to provide placements.

Increases to the overall length of training have unfortunately been an inevitable consequence of pandemic restrictions, and these may continue for an extended period because of the cumulative impact of delays and the deferral of some experiential requirements to the pre-registration period.  Students and trainees must be supported through this and dealt with fairly. For example, the AOP has published ‘clinical refresher’ resources to support those who have faced delays or gaps in placements.

The GOC’s extension to the length of time allowed between graduation and pre-registration has been helpful, and it is likely that it will need to be flexed for courses approved under the current education framework for the foreseeable future. However, we have heard concerns from our pre-registration trainee members that they may be given fewer retake opportunities because of the current delays to assessment timelines, and the limited number of retakes that can be accommodated in the period currently allowed for pre-registration. It is vital that pre-registration trainees are given a fair opportunity to complete assessments, in the same way as previous cohorts, and that they are given assurances about this. If necessary, this could include extending the pre-registration period to accommodate a fair number of retakes. We welcome the fact that the College’s Scheme FAQs state that trainees should receive a fair number of retake attempts.

One of our pre-registration trainee members, an international student, has been concerned whether their visa can be extended to allow them sufficient time to complete their training. Whilst the number of trainees from outside the UK is small, this issue is vitally important for the individuals it affects, and uncertainty could cause huge anxieties. We ask the College and the GOC to look at how this group of trainees can be best advised and supported.

Managing and assessing impacts

The first priority of the GOC, providers and the wider sector should be on supporting students and trainees to reach the appropriate standard to join the register in a safe way. At a later stage it will be worth reviewing the impact on student and trainee cohorts of receiving education and training during the pandemic. This may provide useful information about remote teaching, different approaches to gaining clinical experience and welfare needs. This learning could help inform the development of optometry courses as they transition to the ESR framework and help identify any support needs that newly qualified registrants have. A plan for this work could be developed through a cross-sector group consisting of the GOC, providers, employers, and major optical bodies.