We Asked, You Said, We Did

Below are some of the issues we have recently consulted on and their outcomes.

We asked

We asked stakeholders for their views on our new draft strategic plan. 

You said

Thank you for all your feedback. We have considered all the comments we recieved and this has helped us to finalise the plan. 

We did

On 1 April 2020 our new strategic plan came into force.

Our ‘Fit for the future’ strategy for 1 April 2020 to 31 March 2025 describes what we plan to do over the next five years to achieve our vision of being recognised for delivering world-class regulation and excellent customer service.

2020 has proven to be an unprecedented time for the optical professions and we did not anticipate that our strategic plan would be published during such extraordinary circumstances.

COVID-19 has impacted the way we currently regulate and will no doubt impact the future of the optical professions and in turn, our strategic plan. Therefore, as we continue to monitor the situation, we will revisit this plan after one year.

The three main strategic objectives for the next five years are:

  • Delivering world-class regulatory practice
  • Transforming customer service
  • Building a culture of continuous improvement

We asked

We asked the Open Canvas audience to provide feedback on the first task as conducted by the Expert Advisory Group (EAG). 

You said

The general feedback was that Knowledge, Skills and Behaviour applied to all categories, the EAG also agreed with this.

Under the following categories and elements, the Open Canvas feedback suggested:

  • Communication category: Under Communication the elements ‘Attitude' and 'Demeanour’ should read as ‘Professional Conduct’. ‘Breaking Bad News’ and ‘Managing Patient Expectations’ should read as ‘Explaining and Advising’
  • Supporting Others to Develop category: Under this category it was felt by a respondent that the element ‘Teaching’ should read as ‘Teaching and Assessing’
  • ‘Lifelong Learning’ category could incorporate ‘Supporting Others to Develop’
  • Clinical Excellence category should be merged with Clinical Management category
  • A respondent disagreed with the element ‘Entrepreneurship' sitting under Clinical Excellence and felt the name of this element was unsuitable
  • Disagreement with the element ‘Multimodal’ which sits under the Communication category.

We did

We presented the feedback from Open Canvas for Task 1 to the EAG they then decided whether to accept, reject or incorporate the feedback from Open Canvas into the next stage. The EAG feedback can be seen below:

  • Communication category - Under Communication the group decided that:
    • ‘Professional Conduct’ is a more suitable term than ‘Attitude and Demeanour’.
    • ‘Breaking bad news’ and ‘Managing patient expectations’ should fall under an element called ‘Advising the patient’.
  • Supporting Others to Develop category: Under this category the group decided that the element ‘Teaching’ should be ‘Teaching and Contribution to Assessing’
  • The EAG felt that the Lifelong Learning category should be kept as is and should not be merged with Supporting Others to Develop
  • The EAG felt that the ‘Clinical Excellence’ category and the ‘Clinical Management’ category should not be merged.
  • The element ‘Entrepreneurship’ (under Clinical Excellence) should read as ‘Innovation’ instead and the EAG decided against the use of ‘Multimodal’ as an element under the Communication category.  

We continue to invite you to relay to your stakeholders that the ESR Open Canvas is a platform open to the thoughts of all interested parties as we continue to develop the ESR.

We asked

We asked the Open Canvas audience to provide feedback on Task 1 as conducted by the Expert Advisory Group (EAG).

You said

The general feedback was that Knowledge, Skills and Behaviour applied to all categories, the EAG also agreed with this.

Under the following categories and elements, the Open Canvas feedback suggested:

  • Communication category: Under this category there should be an additional element called ‘Personal Appraisal’
  • Multi-disciplinary teamworking category: There should be an element added in this category called ‘Awareness of professional boundaries’
  • Clinical Excellence category: In this category the element ‘Research’ should read as ‘Conduct and critically evaluate research’, the element ‘Learning from near misses’ should be changed as it is difficult to define what a near miss is.

We did

We presented the feedback from Task 1 to the EAG, they then decided whether to accept, reject or incorporate the feedback from Open Canvas into the next stage. The group agreed the following:

  • Communication category: The term ‘Personal appraisal’ is associated with business and strays into employment the EAG felt this was ambiguous in meaning. Furthermore the EAG decided that ‘Personal Appraisal’ can be reflected under the element ‘self-reflection’
  • Multi-disciplinary teamworking category: The EAG felt the addition of ‘Awareness of professional boundaries’ as an element is not needed at this stage and will come under referral and signposting and can be reflected in the Ethics and Standards category.
  • Clinical Excellence category: The EAG felt that ‘Conduct and critically evaluate’ was going into a more granular level and will be explored later. The EAG agreed that the term ‘near-misses’ was not seen as appropriate and instead felt that NHS Governance terminology such as ‘Impact prevented’ was more suitable.

We continue to invite you to relay to your stakeholders that the ESR Open Canvas is a platform open to the thoughts of all interested parties as we continue to develop the ESR.

We asked

We asked stakeholders to provide feedback on a case management process, being introduced to facilitate the effective running of GOC hearings.  The process is designed to encourage both parties to prepare their cases efficiently, to co-operate with each other in order to keep delays to a minimum, and to and make the best use of hearing time.

You said

The general feedback was that the case management process was a positive proposal to assist with the timely management of cases.  There were some elements that could be tweaked in order to achieve the best outcomes and take into account the practicalities of case preparation and presentation in relation to both parties.

The general feedback suggested:

  • The process should commence at an earlier stage, to ensure both parties are equally being held to account.
  • A review of the timing of the first call should be undertaken as meaningful discussions are unlikely to occur two months after GOC disclosure in the majority of cases.
  • Additional support and guidance should be provided to unrepresented registrants.
  • Clarify why costs have been referred to in the plan.

We did

We reviewed the feedback from the plan and associated documents, and decided whether to accept, reject or incorporate the feedback in an adapted form.

The following amendments have been agreed:

  • We propose to launch the case management meeting process as a pilot in February 2020.  This will enable us to seek and review feedback from all parties at six, nine and twelve month intervals before implementing a finalised policy in February 2021.
  • We have commenced the process, at the point of referral by case examiners, taking into consideration the GOC’s own disclosure obligations.  This will ensure both parties are now equally being held to account.
  • We have reviewed the timing of the first call.  This call will now take place at three months from the date of disclosure by the GOC to the Registrant, when it is hoped parties will still be able to hold some meaningful discussions.
  • We have reviewed the guidance and support that will be provided to unrepresented registrants throughout this process, offering additional telephone conferences and guidance information, to assist understanding of the processes.
  • We hope it is now clearer that costs have been included in the plan as a reminder that under Rule 52 and 53 both parties have the option to  apply to the FTPC  for a costs order.  

We continue to invite you to relay your thoughts and experiences with the case management process throughout the pilot as we continue to develop the plan.

We asked

We asked you whether our draft guidance for registrants on disclosing confidential information about patients:

  • was clear and accessible and made it clear when disclosing information might be necessary to protect the public interest;
  • what impact (if any) the guidance would have on registrant confidence in disclosing confidential information; and
  • whether there was anything additional that we could do to make the decisionmaking process easier in situations where confidential information might need to be disclosed.

You said

280 of you – including optometrists, dispensing opticians, students, businesses, stakeholder bodies and members of the public – provided your views on the guidance and told us:

  • Overall, the guidance was clear and made the GOC’s expectations clear, but in some areas the language used could be clarified;
  • Some amendments to the structure of the guidance would make the decisionmaking process clearer; and
  • A number of additional activities around communication would help support registrants to use the guidance effectively.

As part of the consultation, there was also desire from some stakeholders to see a requirement of automatic notification to the DVLA/DVA if a patient does not meet the vision standards for driving. Whilst we understand the desire for this, previous research (and the consultation itself) supports a discretionary approach so as not to deter patients from seeking eye care and to safeguard (so far as possible) the relationship of trust between patient and practitioner.

We did

We took every piece of feedback we received into account and where possible, made the suggested amendments – particularly in relation to tightening up language. We also restructured part of the guidance to include a step-by-step approach to disclosing information and supported this with a flow chart to make the decision-making process clearer.

In terms of supportive communications, we have been liaising with key stakeholders in advance of publication to ensure that communications can be joint and aligned where appropriate.

We asked

Thank you for responding to our consultation Fit for the Future: Lifelong learning Review. We asked stakeholders for their views on proposed changes to our CET scheme. Our current CET scheme was introduced in 2013, but the optical sector has changed since then and the work optometrists and dispensing opticians carry out has expanded and diversified. We want to make sure that our CET scheme continues to support our registrants’ learning and development needs, and continues to maintain the safety and quality of care patients receive.

You said

We received 994 responses from a range of stakeholders and we welcome this feedback. In relation to one specific proposal, we took into account stakeholder views and concerns on our plan to implement a transition CET year in 2019 and a new scheme starting in 2020. The consultation highlighted concerns about this timeframe for change, and having carefully considered this we decided to revert to our usual three year CET cycle (starting in 2019), with the aim of introducing more significant change to the scheme in 2022. 

We did

We will continue to use all the feedback we received to help inform our policy thinking in this area and help ensure that our CET scheme continues to evolve to meet the challenges of the future. Moving forwards, we will also continue to listen and engage with stakeholders to help develop our policies. 

We asked

We asked you whether our draft business standards:

  • were clear and accessible to anyone working within an optical business and in any scope of practice
  • could be put into effect by businesses easily and have a positive impact

You said

358 of you - a mix of optical businesses, individuals and stakeholder organisations - gave us your views on the draft standards and told us:

  • Overall, the standards were clear, but elements of the language used could be made more specific so that it was easier to see where responsibilities lay
  • More explicit reference to online businesses and use of technology would be beneficial, including how the standards might apply in an online context
  • Commercial pressures faced in practice could be addressed more comprehensively

We did

We took every piece of feedback we received into account and where possible, made changes to the text of the standards (including making language more specific where it was appropriate to do so). For example, the standards now make reference to operational influences on commercial pressures; explicitly include online businesses within their scope as well as ensuring that standards relating to the business environment include the use of software and technology.

Where changes have not been made to the text, we have still taken the feedback on board and are addressing it in our implementation of the standards. We have a number of activities in the pipeline to make it easier for registrants to apply the standards to their practice context, including a microsite which will contain the standards and supporting material in an accessible way. 

The new Standards for Optical Businesses can be found on the GOC Standards microsite.

The full consultation report can be accessed here