Response to the GOC consultation on education requirements for entry to the register as a Contact Lens Optician (CLO)

This is our response to the GOC consultation on new education requirements for registration as a CLO. This is part of the GOC’s Strategic Review (ESR) and follows on from the publication of new requirements for optometry and dispensing optician education programmes in February 2021 and for optometry prescribing in December 2021.

CLOs are an important part of the optical workforce and an education model which allows appropriate workforce capacity is essential. As well as traditional roles in community optics CLOs, as well as dispensing opticians, are increasingly becoming involved in the delivery of enhanced primary care optical services such as for minor eye conditions and low vision.

The AOP currently has over 150 dispensing optician members and a designated position to represent DO members on our Council.

Our response

Q: What impact, if any, will introducing the proposed 'Outcomes for Approved Qualifications for Specialist Entry to the GOC Register as a contact lens optician' have on the expected knowledge, skill and behaviour of future contact lens opticians?

A: Positive impact

Q: Is there anything in the criteria in the ‘Outcomes for Approved Qualifications for Specialist Entry to the GOC Register as a contact lens optician’ that is missing or should be changed?

A: Yes

We agree with the use of the Miller’s learning hierarchy to structure the outcomes for CLOs in order to align these with the education requirements for all the other frameworks leading to GOC optical registration. It would be helpful for the GOC to explain its proposed approach for the future review and update of the outcomes for CLO registration. The optometry therapeutics learning outcomes will need review every 5 years when the RPS framework, which it is mapped to, is revised. Whilst the outcomes for CLOs are not similarly mapped to another framework, there may be benefit in constructing a similar schedule for review in order to ensure the outcomes are kept up to date.

Q: What impact, if any, will introducing the proposed ‘Standards for Approved Qualifications for Specialist Entry to the GOC Register as a contact lens optician’ have on the expected knowledge, skill and behaviour of future contact lens opticians?

A: Positive impact

Q: Is there anything in the ‘Quality Assurance and Enhancement Method for Specialist Entry to the GOC Register as a contact lens optician' that is missing or should be changed?

A: No

Q: To what extent do you agree with our proposal to replace our handbook for contact lens opticians and related policies with the proposed ‘Outcomes for Approved Qualifications for Specialist Entry to the GOC Register as a contact lens optician,’ ‘Standards for Approved Qualifications for Specialist Entry to the GOC Register as a contact lens optician’ and ‘Quality Assurance and Enhancement Method for Specialist Entry to the GOC Register as a contact lens optician'?

A: Agree

The current CLO education requirements are 14 years old and it’s right for these to be updated as a logical step following the agreement of new education requirements in February 2021 for entry to the register as an optometrist and dispensing optician, and more recently to the framework for optometrist prescribers. This will bring the design of the CLO requirements into alignment with these other frameworks, moving to less prescriptive requirements for providers, with outcomes framed using the Miller’s triangle hierarchy, and a common risk based approach to quality assurance and approval. As a result however the CLO requirements will also suffer from the same delivery risks that inevitably flow from the use of a high level flexible set of requirements, and these will need to be mitigated through the GOC’s quality assurance and approval process.

The new CLO education requirements do not provide any minimum duration requirements for the qualification to be completed, save for the inclusion of 225 of learning experience in practice. This is a reasonable move given similar changes to the other optical education frameworks. However, the GOC should monitor CLO course duration and resourcing as part of its approval and assurance process - to mitigate the risk of overly short course lengths compromising the overall quality of learning.

We welcome the inclusion of outcomes 6.2 about urgency of glaucoma, retinal detachment and AMD (knows) and 6.3 on the principles of myopia management (knows how) for CLOs. It should be beneficial for CLOs to have basic knowledge about symptoms of these eye conditions - to give them an understanding about relative urgency in service delivery, and a knowledge of myopia management principles will also be useful. Within the learning framework these outcomes should logically focus on developing knowledge rather than practice, as these are not part of the current CLO competencies or directly related to CLO practice.  It is important that the distinction between knowledge and practice is clear. The GOC should ensure that CLOs are not exposed to professional risks as a result of pressure from employers to work in areas covered by outcomes 6.2 and 6.3 which they’re not appropriately skilled in. This could be done via the standards for optical businesses and through CPD.

It would also be useful for the GOC to clarify whether the requirement for the CLO qualification to be at RQF level 6 has any impact on those registrants who have previously gained their dispensing optician registration as a level 5 qualification.