GOC response to concerns raised by Association of British Dispensing Opticians about the Education Strategic Review
We acknowledge the Association of British Dispensing Opticians’ (ABDO) concerns, published on its website on 6 August 2020, relating to our latest Education Strategic Review (ESR) consultation to update the education and training requirements for dispensing opticians and optometrists. We would like to address these concerns and clarify our proposals.
Firstly, we would like to thank ABDO staff and members for the time they have committed to helping us draft our proposals as part of our Expert Advisory Group (EAG). We look forward to working with ABDO in the co-commissioning of research vital to ensure our proposals to update our Quality Assurance Handbooks strengthen the capacity of future dispensing opticians to provide safe and effective care.
The consultation is seeking views from across the optical sector and we encourage all dispensing opticians (DOs), and those responsible for teaching the next generation of DOs, to read our proposals and provide their feedback. The rationale for change has been clearly articulated in various reports we have commissioned and published on our website.
We note ABDO’s view in its statement that, ‘Under the proposed new model, there could be multiple routes to registration with the GOC’ and that ‘This is a fundamental change to the current system…’. There are currently multiple routes to registration as a DO or an optometrist. We know that whilst both the College of Optometrists and ABDO offer the market-leading route to GOC registration, it has never been the case that each hold a monopoly position. Any potential provider of a DO or optometry qualification may apply to us for approval. It would be unlawful of us as a statutory regulator to refuse to consider such applications.
A key material risk is that our current requirements require strengthening to ensure such approval decisions will be able to continue to be in the public interest, which is why we are consulting on updating our requirements to raise, not lower, our standards. Under our proposals, any qualification we approve must ensure students meet all the outcomes at the right level. In addition, they significantly strengthen our requirements for the teaching and assessment of the outcomes to maintain consistency between potential providers, backed up by a new and robust quality assurance process led by our well-trained lay education visitors.
The concept of a ‘single point of accountability’ is unrelated to the issue of multiple routes to registration. At present anyone can apply to us for approval, even if they are not legally incorporated or an academic institution with a substantial and demonstrable track record of assessment design and standard setting. Our proposals for a single point of accountability enhance our requirements for those who we might receive an application for approval from; it does not amend our current statutory obligation to consider, and approve (if our requirements are met) alternative/multiple routes to registration as a DO than those offered by ABDO.
The requirement for a broad range of stakeholders, including patients, to inform and be engaged in the design, teaching and assessment of qualifications we approve is more explicit than in our current requirements, and an important safeguard to ensure the clinical content of courses and its assessment remains relevant and up to date, given the varying contexts in each of the developed nations.
We are aware there is more to do to understand the impact of our proposals, particularly the financial impact on providers and students if we integrate professional and clinical experience within qualifications we approve. We look forward to receiving information from stakeholders on this and other aspects of our proposals.
To have your say, visit the GOC Consultation Hub. The consultation will close at 5 pm on 19 October 2020.
If you have any questions about our consultation or the detail of our proposals, please feel free to email us on firstname.lastname@example.org. You can also join our Director of Education at one of our ‘Tea with Leonie’ online Q&A sessions. To express your interest, please email email@example.com.