Education and training requirements for therapeutics
The AOP’s response to the GOC’s new education framework for therapeutics, October 2021
In October 2021 we responded to the GOC consultation on its new education requirements for specialist entry to the register with qualifications in therapeutics. The AOP response was based on extensive feedback from across our committees and wider membership through our community forum. Overall, we are supportive of the GOC’s proposals, which should help widen access to therapeutics and build prescribing skills in the optometric workforce. However, the GOC must also ensure that risks from delivery of the new education system are managed. Transition to the new framework must not disadvantage those who are part way through qualifications, clinical experience must be of sufficient quality and practising practitioners should be supported to maintain their skills in prescribing.
Section 1: Consultation questions
Q1. What impact, if any, will introducing the proposed ‘Outcomes for Approved Qualifications for Specialist Entry to the GOC Register (AP, SP and IP)’ have on the expected knowledge, skill and behaviour of future independent prescribing optometrists?
AOP response: Positive impact
Q2. Is there anything in the criteria in the ‘Outcomes for Approved Qualifications for Specialist Entry to the GOC Register (AP, SP and IP)’ that is missing or should be changed?
AOP response: No
We are positive about the proposals and agree with the outcomes as laid out, but want to offer a short commentary:
We agree with the proposal that the content of the learning outcomes is drawn predominantly from the Royal Pharmaceutical Society’s competency framework (2021) for all prescribers. This seems logical as the RPS framework is the common learning standard that informs non-medical prescribing competence across UK healthcare. We also agree with the use of the Miller’s triangle hierarchy to indicate what level of competence learners need to demonstrate for each outcome (knows; knows how; shows how; does).
We know that the vast majority of the RPS framework had been included in the IP learning outcomes document. As this document undergoes periodic revision, so will the outcomes for specialist qualifications in optics, we suggest through a process involving sector stakeholders.
We agree with the proposal to integrate the theory, clinical experience, and assessment elements of specialist training into a single qualification, rather than in separate stages as now. This could reduce the number of times that students complete the theory and then are prevented from qualifying due to delays in finding a placement.
The availability of supervision places could still be a limiting factor, but other positive elements of the proposals are designed to resolve this problem.
Our members are supportive of the removal of the requirement to have been on the register for two years before beginning specialist training, and of the qualification being offered alongside/as part of the undergraduate degree. But they did express two concerns. First, to become a proficient independent prescriber requires seeing enough pathology (both in numbers and variety) to become competent in recognising and treating it. Recognising the limits of one's scope of knowledge also depends on seeing enough "unusual" problems. Undergraduate education does not normally expose students to sufficient cases and clearly course design will need to change in order to provide enough exposure.
The second concern was that it might be the case that not all undergraduate students are ready for the extra level of responsibility involved in independent prescribing at the point when they are studying for their BSc. The qualification should not be available to people who are not yet ready to demonstrate the extra competencies described in the outcomes. But nor should people be excluded from opportunities to develop those competencies later in their career.
We believe that the GOC should consider carefully the safety and quality of any new courses that propose to offer entry level and IP training together before giving approval, and give such courses additional attention in its quality assurance process.
On Additional Supply (AS) and Supplementary Prescribing (SP) qualifications, we understand why they remain a part of the framework, however the members who responded to our consultation said that they saw very little value in these qualifications compared to IP, given that the outcomes are almost identical to IP but the scope of practice they open up is much more limited.
To act as a stepping stone towards IP qualification, or a fall-back qualification for those who fail to meet the full requirements for IP, they should have a clearly different route to qualification, for example not requiring a full clinical placement. The GOC should modify requirements for AS/SP to make them more achievable and explain how they fit alongside IP in the framework, and the reasons to retain them in the new framework. It should engage with the sector and those who retain individual AS/SP qualifications to identify how the qualifications can most effectively be retained or transitioned out from the therapeutics framework in future.
Q3. Have you read the ‘Standards for Approved Qualifications for Specialist Entry to the GOC Register (AP, SP and IP)’ before answering these questions?
AOP response: Yes
Q4. What impact, if any, will introducing the proposed ‘Standards for Approved Qualifications for Specialist Entry to the GOC Register (AP, SP and IP)’ have on the expected knowledge, skill and behaviour of future independent prescribing optometrists?
Q5. Is there anything in the ‘Standards for Approved Qualifications for Specialist Entry to the GOC Register (AP, SP and IP)’ that is missing or should be changed?
AOP response: Yes
We are broadly supportive of the proposals, but want to enlarge on our view and describe risks.
We welcome the recent GOC agreement to changes in the College of Optometrists' IP placement programme, to allow trainees to begin placements after the two-year time limit has passed, to allow for some remote experience and session sign-off by IP optometrists. We hope that those who have recently completed the theory element of the training are made aware of this change and are supported to complete the qualification.
We hope that the GOC will use its quality assurance of new programmes to ensure that providers do not set arbitrary time limits for the recognition of prior learning.
We endorse the proposal that designated practitioners (not necessarily or only ophthalmologists) will be able to sign off clinical experience for trainees. However, many members who responded to our request for feedback on the proposals mentioned how valuable they had found it to undertake training in hospital clinics under an ophthalmologist. It will be crucial that during their hours of practical experience the trainees see a large number of cases and a wide range of pathology. This could not normally be achieved in a community setting at this time, and we think the GOC should look carefully at the proposed settings for clinical experience in order to ensure that the qualification will be based on wide-ranging experience. It may be necessary to strengthen the standards in order to make clear the requirement to provide access to sufficient breadth and complexity of cases.
Q6. Have you read the ‘Quality Assurance and Enhancement Method for Specialist Entry to the GOC Register (AP, SP and IP)’ before answering these questions?
Q7. Is there anything in the ‘Quality Assurance and Enhancement Method for Specialist Entry to the GOC Register (AP, SP and IP)’ that is missing or should be changed?
AOP response: No
But please note our references to the quality assurance process in our answers to preceding questions.
Q8. To what extent do you agree with our proposal to replace our handbook for independent prescribing optometrists and related policies with the proposed ‘Outcomes for Approved Qualifications for Specialist Entry to the GOC Register (AP, SP and IP),’ ‘Standards for Approved Qualifications for Specialist Entry to the GOC Register (AP, SP and IP)’ and ‘Quality Assurance and Enhancement Method for Specialist Entry to the GOC Register (AP, SP and IP)’?
Q9. To what extent do you agree with our proposal that at the point of retention, registrants in the additional supply, supplementary prescribing and/or independent prescribing categories will no longer need to supply details of prescribing decisions undertaken in the previous 12 months?
AOP response: Agree
We agree with this proposal because we know that the current process is mainly an administrative process, designed only to assess if a registrant needs to undertake more CET/CPD. IP optometrists should be recording diagnoses, decisions, and treatments as part of the normal clinical governance process in their practice setting.
However, we do want to mention the lost opportunity to gather aggregate data on the number and type of IP interventions taking place each year. To know this could help us judge the need for this level of qualification in practice in the future, as well as highlight any issues about under or over use of prescribing permissions.
Section 2: Impact of our proposals
Q3. Do you think any of the proposed changes will impact – positively or negatively – on any other individuals or groups (for example, trainees, patients and the public, current providers of approved qualifications, placement providers, employers and devolved nations)?
AOP response: Positive impact
Q4. 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.
The biggest benefit of integrating the IP qualification into the undergraduate degree will be for people with limited means. The requirement to self-fund has created a barrier for people of limited means that will be removed if the qualification can be undertaken alongside entry-level education.