Our response to the consultation on managing applications for GOC registration from optical professionals who have qualified outside the UK or Switzerland

This GOC consultation has called for the views of stakeholders on the process for managing  applications for GOC registration from optical professionals who have qualified outside the UK or Switzerland in line with the new education and training requirements (ETR). GOC's aim is that optical professionals who have qualified outside the UK or Switzerland and wish to join the GOC’s register must meet the same standards of education and training as optical professionals who have qualified in the UK.

Our response

Q1. We are interested in your views and evidence on which overseas qualifications, if any, may be comparable to GOC approved qualifications in optometry or dispensing optics which meet the new ETR. Please identify which qualifications may be comparable and why?

The table on page 20 of the ECOO-Professions Scope of Practice Blue Book 2020 sets out the scope of optometrist competencies separated into that permitted, prohibited, and practised by European countries. It demonstrates the greater scope of optical skills practised in the UK relative to other European states. This reflects the comprehensive nature of UK optometric education in which graduates are furnished with professional skills over and beyond the scope of practitioner requirements within optical practices.

In our view, the solid foundation provided by UK university optometric education is bolstered by the UK’s effective regulatory and legislative environment which balances robust public safety mechanisms with the UK’s diverse, patient-choice orientated range of optical practice types and business. Accordingly, the UK has the largest optometric workforce in Europe and a sizeable dispensing workforce as well.

In the rest of Europe, the ECOO accreditation system of the European Diploma has been welcome and represents a comparable competency with UK entry level university optometry education. However, few European universities are currently accredited with the European diploma.

For these reasons, we do not feel there are any European countries where there is comparable activity or scope of practise. Even in countries such as the Netherlands which permits a greater scope of optometric practise, the lack of regulation and general variability in regulation removes assurance and presents significant risk.

Regarding Switzerland, our understanding is that there is already an agreed process for applicants from Switzerland, but clarity would be welcome. Outside of Europe, there are countries where there are comparable qualifications enabling a wide scope of practise such as Australia and the US but, again, there is some variability here. For example, in the US, whilst all qualifications in Optometry are postgraduate qualifications, there are differences in their range and content depending on the state in which one studies. However, it appears that the scope of practice in all is at least equivalent to the UK.

In terms of the UK professional health care environment, the existence of the NHS – a largely unique health system – adds an additional level of complexity for non-UK providers considering relocation to the UK. By the same measure, and while UK optometrists themselves relocating overseas are not in scope here, it is likely that these optometrists face a similar difficult adjustment to other countries where there is no state-health care provider equivalent to the NHS.

As a final point, we believe the high level of optometric education in the UK is indicative of the potential for UK optometrists to deliver a greater range of optometry clinical services than is presently the case. While non-core (GOS) services have expanded throughout England in recent years, and the Scottish and Welsh commissioning systems allow for a greater scope of care than core GOS-alone, there is still much more scope for innovative commissioning to help meet Government and NHS objectives for more out of hospital care, integrated care and preventative care.

These sorts of services are within optometrists’ core competencies as per the UK’s extensive practitioner education system. At the same time, we recognise the clinical importance of post-graduate accreditation programmes (such as that provided by Cardiff University’s Wales Optometry Post-Graduate Education Centre) for underpinning these competencies and where appropriate, assuring commissioners and the regulator of optometrists’ ability to provide non-core primary eyecare services to the public.

Q2. Please consider proposals one and two described in section two of this consultation.

1. The applicant successfully completes and is awarded a GOC approved qualification in either dispensing optics or optometry.
2. The GOC will no longer undertake individual registration assessments prior to an applicant applying to be admitted to a GOC approved qualification.

Will these proposals have a positive, neutral or negative impact on the management of applications for GOC registration from optical professionals who have qualified outside the UK or Switzerland?

AOP response: Neutral

We feel as long as the long as the same standards are applied, the impact will be neutral in terms of management. It will however shift the administration assessment burden from the GOC to GOC-approved qualification providers (universities in the case of optometry) which for a small cohort may not be economically viable and potentially affect the current intake spread of students into universities.

It is also important that the requirements of the GOC approved qualification are fully understood by qualification centres and applicants, including timescales, methods of study, and minimum standards necessary to pass.

Q3. If your answer to Question 2 is ‘negative’, do you have an alternative proposal for managing applications for GOC registration from optical professionals who have qualified outside the UK or Switzerland, following the introduction of the GOC’s updated education and training requirements?

AOP response: N/A

Q4. Please consider proposal three described in section two of this consultation - “The GOC may continue to assess applications for registration from optical professionals who have qualified outside the UK or Switzerland who meet or exceed the requirements for GOC registration (including the relevant ‘outcomes for registration’)”. (Note - We expect such applications to be rare (less than 10 a year. We will continue to charge a fee for this assessment).

Will this proposal have a positive, neutral or negative impact on the management of applications for GOC registration from optical professionals who have qualified outside the UK or Switzerland, who are likely to meet or exceed the requirements for GOC registration (including the relevant ‘outcomes for registration’).

AOP response: Neutral

Our understanding of this proposal as per Figure 1 in the consultation papers is that this method will act alongside the qualification route with outcomes for individuals being either a) immediate entry into the GOC register, or b) a requirement to go through the qualification route. More clarity on which individuals this concerns from the GOC would be welcome. In general, as the proposed numbers are very small, we do not expect this to have a significant impact.

However, we feel the GOC should clarify the nature of the revalidation of skills. Will optometrists relocating to the UK be assessed on their practise competencies for every competency required of UK optometrists, or will assessment be based on individuals’ declared historical scope within optical practice settings? In order for clinically safe treatment to be provided to the public, we feel that the former is more appropriate as a mandated set of requirements for optometrists qualifying outside of the UK or Switzerland.

Regarding universities, it is our understanding that they are not in a position to provide assessments for optometrists from overseas, nor are they in favour of adopting this position. The GOC as it stands provides an interview which the small number of optometrists in question can take which helps to keep professional relocation costs low.

Q5. Should such applications be pre-assessed by a provider of the approved qualification, or may optical professionals apply directly to the GOC?

AOP response: Direct application to the GOC only

For consistency and parity, we believe this requirement should remain with the GOC. Option c) would potentially serve to confuse applicants and perhaps qualification centres if the individual was deemed required to enter the qualification phase following an application as per Question 4.

Given that the qualification route is proposed to now run through other GOC-approved centres, and the low expected numbers for the direct registration route, the administration burden to the GOC will be low.

Q6. We want to understand whether the approach may discriminate against or unintentionally disadvantage any individuals or groups sharing any of the protected characteristics in the Equality Act 2010 which protects everyone living in the UK including refugees and migrants. Do you think the approach will have a negative impact on certain individuals or groups who share any of the protected characteristics listed below?

AOP response: ;None of the above

Q7: We also want to understand whether the approach may benefit any individuals or groups sharing any of the protected characteristics in the Equality Act 2010 which protects everyone living in the UK including refugees and migrants. Do you think the approach will have a positive impact on any individuals or groups who share any of the protected characteristics listed below?

AOP response: None of the above

Q8. How do you think the approach will impact – positively or negatively – on any other individuals or groups (for example, students, patients and the public, current providers of approved qualifications, placement providers, employers and devolved nations)?

AOP response: Negative

a) Applicants from optical professionals who have qualified outside the UK or Switzerland – The wider ETR changes mean that it is unclear how the final year, which will now incorporate and replace the traditional pre-reg, will work. There is a risk that these changes may mean this route to joining the UK register is no longer available.

b) Patients and the public

As the numbers involved are small, it is unlikely that if this route to joining the UK register is removed that there will be a significant impact on the wider workforce. Patients and the public should not be unduly affected by these proposals given the large, skilled optometric workforce that exists in the UK.

c) Current and prospective providers of approved qualifications

As the numbers of potential students are low and that administration will pass to qualification providers from the GOC as is currently the case, we are of the view that this may inhibit new entrants to the market and force those already involved to exit. This risk in our view calls the proposals into question.

d) Placement providers

It is our view that under the new arrangements that these applicants will not be an attractive option for placement providers due to the complexity of funding and university engagement, as well as greater administration.

e) Employers

As above.

f) Devolved Nations

For Scotland the rules around tuition fees are likely to prohibit overseas placements as is the requirement that placements also consider IP.

Q9. Have we identified and captured the impact accurately within the impact assessment (see annex one - pages 16-24 in the consultation document).

AOP response: Yes

Q10. Are there other impacts (positive or negative) we should consider?

AOP response: Yes

We are concerned that the low numbers may mean that most universities do not consider this to be a viable proposition. While this relates to wider ETR changes and the GOC have suggested that they are out of scope, it is our view that this is an unintended consequence of the ETR process.

Q11. Is the proposed implementation date realistic (September 2026)?

AOP response: Neutral