We asked stakeholders for their views on our proposals to update our requirements for specialist entry to the GOC register in the additional supply (AS), supplementary prescribing (SP) and/or independent prescribing (IP) categories.
In general, the proposed Outcomes and Standards for approved qualifications for specialist entry to the GOC register (AS, SP, IP) and Quality Assurance Method were positively received. There was broad agreement that trainees acquiring a single qualification will help simplify and streamline the route to speciality registration.
Concerns related to detailed points, notably:
We welcome the feedback received and have reflected on the points that have been raised in this consultation. To help implement the proposals, the GOC Council on 8 December 2021 approved the use of reserves of up to £60,000 over a period of three years (2022 - 2025) to facilitate a cross-sector knowledge-led collaboration and information exchange.
In relation to the detailed points noted above (‘You said’), we decided that:
This consultation seeks your views on our proposals to update our requirements for specialist entry to the GOC register in the additional supply (AS), supplementary prescribing (SP) and/or independent prescribing (IP) categories. These proposals are available to download at the bottom of this page under the 'related' section.
What are we seeking your views on?
These proposals are available to download at the bottom of this page.
What will our proposals replace?
Together, these documents will replace ‘A Handbook for Optometry Specialist Registration in Therapeutic Prescribing’ (published in July 2008) and the ‘Competency Framework for Independent Prescribing’ (published in 2011), including the list of required core competences, the numerical requirements for trainees’ practical experiences, education policies and guidance contained within the handbooks, and our policies on supervision and recognition of prior learning, which are published separately. You can read the documents we are proposing to replace, here; handbook and competencies.
Why are we consulting?
We would like to hear your views and receive evidence of the impact of our proposals to update our education and training requirements for GOC approved qualifications for specialist entry to the GOC register to ensure that the qualifications we approve in the future are responsive to the changing landscape in the delivery of eye-care services and fit for purpose in each of the UK nations.
Our proposals mitigate the risk that our current requirements (contained within our quality assurance handbooks) become out of date.
The proposed outcomes and standards for approved qualifications and quality assurance and enhancement method together will ensure the qualifications we approve are responsive to the changing needs of patients and service-users and changes in higher education, not least as a result of the COVID-19 emergency, as well as increased expectations of the trainees, commissioners and employers.
What have we consulted on previously?
These proposals are based on our analysis of our responses to our Call for Evidence, Concepts and Principles Consultation 2017-2018, feedback from our 2018-2019 consultation on proposals stemming from the Education Strategic Review (ESR) and associated research, and our public consultation held in July-September 2020 on proposals to update our requirements for GOC approved qualifications leading to registration as an optometrist or a dispensing optician. For more information, please see the GOC's consultation hub. For further information about the ESR, please visit the ESR policy development and research page.
How have we developed our proposals?
Our proposals have been guided by evidence-based policy making and draw upon best practice from other regulators, professional and chartered bodies. You can read our research, background and briefing papers here.
In preparing this document we were advised by an Expert Advisory Group (EAG) with input from the Quality Assurance Agency and feedback from a range of stakeholder groups including our Education Visitors, our Advisory Panel (including the Education Committee), the optical sector and sight-loss charities.
We would like to thank everyone who took the time to help us develop our proposals to ensure our proposed outcomes for approved qualifications, standards for approved qualifications and quality assurance and enhancement method protects and benefits the public, safeguards patients, and helps to secure the health of service-users.
You can read the EAGs’ terms of reference and membership here.
What are our key proposals?
Key proposals
a. Candidates will acquire a single qualification approved by the GOC leading to specialist entry to the GOC register in AS, SP and/or IP categories, instead of two GOC approved qualifications (gained either sequentially or simultaneously) currently required for entry to a specialty registration category (AS, SP or IP).
b. The approved qualification will be either an academic award or a regulated qualification at a minimum of Regulated Qualification Framework (RQF) (or equivalent) level 7.
c. There will be no proposed minimum/maximum or recommended time or credit volume for an approved qualification or specified location or duration of clinical experience, other than the requirement that an approved qualification leading to specialist entry to the GOC register in AS, SP and/or IP categories must integrate approximately 90 hours of learning and experience in practice.
d. Trainees upon application must have identified a suitably experienced and qualified designated prescribing practitioner (DPP) who has agreed to supervise their learning in practice. A trainee’s DPP must be a registered healthcare professional in Great Britain or Northern Ireland with independent prescribing rights and be an active prescriber competent in the clinical area(s) they will be supervising the trainee in, have the relevant core competencies and be trained and supported to carry out their role effectively. If more than one registered healthcare professional with IP rights is involved in supervising a trainee, one independent prescriber must assume primary responsibility for coordinating the trainee’s supervision. That person will be the trainee’s DPP. In addition, we propose that there must be agreements in place between the trainee, their DPP and the qualification provider that describe their respective roles and responsibilities during periods of learning and experience in practice. These must be regularly reviewed and supported by management plans, systems and policies which prioritise patient safety.
e. The provider of the approved qualification must, in the design, delivery and assessment of an approved qualification, involve and be informed by feedback from a range of stakeholders including patients, employers, trainees, supervisors, members of the eye-care team and other healthcare professionals.
f. An outcomes-based approach is used to specify knowledge, skills and behaviours using an established competence and assessment hierarchy known as ‘Miller’s Pyramid of Clinical Competence’ (knows; knows how; shows how; and does), mapped to relevant external prescribing frameworks, including the draft Royal Pharmaceutical Society’s (RPS) Competency Framework for all Prescribers (2021).
g. Providers of approved qualifications are responsible for the measurement (assessment) of students’ achievement of the outcomes at the required level (on Miller’s Pyramid) leading to an award of an approved qualification.
h. Providers of approved qualifications will be responsible for recruiting and selecting trainees onto a programme leading to an award of an approved qualification. Recognition of prior learning can be deployed to assist the progression of trainees whose progress to specialist registration has stalled, and the requirement for optometrist IP trainees to have been registered for at least two years prior to commencing clinical experience/hospital placements has been removed.
j. At the point of retention, registrants in the AS, SP and/or IP categories will no longer need to supply details of prescribing decisions undertaken in the previous 12 months.
What do I need to do?
If you are a member of the public, a patient or service-user, you may only be interested in reading our proposed outcomes for approved qualifications and answering questions 1, 2 and 3 in section 1 (which should take about five minutes to complete in addition to reading the document) along with questions in section 2 (which we are asking everyone to answer) about the impact of our proposals. However, you may well be interested in reading our proposals in full and answering all the questions we’ve asked in section 1.
If you are a GOC registrant, or an employer of GOC registrants, or you are responding on behalf of a provider of a GOC-approved qualification, a professional membership or third sector body, or another organisation or regulator, you may be interested in reading our proposals in full and answering some or all of the questions in section 1 (which should take about 15-20 minutes to complete in addition to reading the documents.)
Towards the end there are some questions for everyone to answer about the impact of our proposals (section 2, which will take about five minutes to complete).
We recognise our proposals are detailed, with a range of impacts on different stakeholder groups, so if you wish to answer all the questions in both sections of the questionnaire, please do so.
Consultation data will be securely shared with our research partner for this work, Enventure Research, for independent analysis and reporting. We will be receiving data on a regular basis and will adjust our approach to engagement with the sector as guided by Enventure Research.
Privacy statement
The information you provide to us, the GOC (as data controller), will be processed and used in line with our statutory purpose under the Opticians Act as a public task in order to set standards for optical education and training, performance and conduct. For more information regarding how we process your data please see the full privacy statement on our website.
Right to erasure
Article 17 of the General Data Protection Regulations provides data with the right to erasure; this is known as the right to be forgotten. Right to erasure requests should be sent to the Data Protection Officer (FOI@optical.org) and will be responded to within one calendar month of receipt.
Data controller
We are registered as a data controller with the Information Commissioner's Office, registration number Z5718812. We are committed to maintaining robust information governance policies and processes to ensure compliance with relevant legislation. Any information you supply will be stored and processed by us or on our behalf, by approved and verified third parties, in accordance with the General Data Protection Regulations and the Data Protection Act 2018.
The responses to this public consultation will be independently analysed and a report prepared for the GOC which will be published thereafter. The GOC will carefully consider the results of this consultation before publishing its own response.
Share
Share on Twitter Share on Facebook