Our response to the consultation on draft GOC Council strategy for 2025 to 2030

In April 2024 the GOC launched a consultation on its in 2025 to 2030 Strategy. With the Strategy the GOC aimed to focus on continuous improvement across their statutory functions such as maintaining registers, approving qualifications, and managing fitness to practise.

AOP welcomed the opportunity to comment/liaise with the GOC on its Strategy and arranged some targeted discussions with the Policy Committee and Council members to gather a sector viewpoint on the key issues. Following these rich discussions, we responded in general support of the strategy, but with some key concerns highlighted.

Firstly, the educational aspects of the Strategy gave pause to some members. Improvements were suggested on the reformation of the CPD system and some clarity sought on the proposed post-registration qualification registrar. AOP further expressed its opinion that the gathering of data for research and insight purposes should be undertaken thoroughly, with wider sector collaboration to ensure that the information is beneficial and with a clear purpose to tackle health inequalities in eye care.

We were supportive of the GOC’s agile approach to regulation during the Covid-19 pandemic, but urged the GOC to keep registrants’ needs front-of-mind as the regulator embeds this ethos. As we live in ever changing times, a more proactive and flexible approach to regulation is welcomed, but it should not come at the cost of being evidence-based and maintain full accountability and transparency.

Proposed changes to the standards

The GOC strategy 2025-2030 focused on three key objectives underpinned by the wider changes in the profession:

• Creating fairer and more inclusive eye care services
• Supporting responsible innovation and protecting the public
• Preventing harm through agile regulation.

Our response

Q1. Do you agree with our vision ‘safe and effective eye care for all’?

Yes

Q4. Do you agree with our strategic objective ‘Creating fairer and more inclusive eye care services’?

Yes

Explanation: We would urge being as thorough as possible when gathering the research data on health inequalities – ensuring to cover all aspects that encapsulate ethnicity, socio-demographic, geographical et al. All with a view to how they affect patient access to services. The GOC strategy should endeavour to use these data collected on health inequalities for the purpose of improving eyecare services all over the UK - not only for highlighting it.

A commitment in the strategy to working with the wider sector to reduce the inequalities highlighted is strongly recommended. The AOP would be keen to collaborate on future work in this area as complexity will grow exponentially with the widening societal health gap.

Q5. Do you agree with our strategic objective ‘Supporting responsible innovation and protecting the public’?

Yes

Explanation: Delving further into the detail of the GOC's suggested activities to meet this objective, the AOP do hold some concerns on the educational aspects, namely CPD reform and the potential expansion of GOC responsibility for post-registration qualifications. The reformation of the CPD system should focus on the quality training of the modules along with our members expressing concern on the number of hours spent on completing modules with additional administrative burdens.

A number of members spoke positively about the personal development plan (PDP) as a welcome addition in the most recent changes and considered it the key to structuring a practitioner’s learning. Additionally, we would suggest that CPD could focus more on non-optical skills such as management, leadership, equality and diversity and legal topics.

Q6. Do you agree with our strategic objective ‘Preventing harm through agile regulation’?

Not sure

We recognise the positives of adopting an agile approach to regulation, especially in such a fluid healthcare culture. However, the implementation of suggested agile regulation needs to be considered thoroughly and how this will affect professionals. Regulation should be proactive and have the necessary levels of flexibility built in. There are potential risks involved in decisions being made too quickly without all of the relevant information.

We would request that the GOC is clear and concise on your definition of ‘agile’ as the new strategy is finalised. We also have some concerns about the challenge of keeping abreast of any regulatory shifts that professionals returning from career breaks might face. We feel that the GOC needs to consider what data they would be collecting and the reasons for it. If this is necessary to inform decisions on the size and qualifications of the future profession then we would be broadly supportive.

Q12. Is there anything else you think we should consider as part of the development of our strategy?

Yes

Explanation: The GOC needs to expand on the financial planning and resourcing of these objectives. In a broad sense, many of the activities that the GOC has suggested to help implement the three objectives will depend on funding levels. We are aware that there is a Finance Strategy being crafted alongside the main strategy being consulted on, but our members felt that they couldn’t endorse some aspects of the strategy without fully understanding the funding implications.

To help avoid any negative perception of the strategy from registrants, we recommend a cross-referenced caveat to weave through the objectives that note funding implications wherever appropriate. This could help to mitigate registrants’ fears and concerns over how their fees are being utilised.

To take it a step further, as the GOC income has demonstrably increased over the last few years, we would respectfully request a formal Value For Money review over the coming strategy period.