FtP Focus: a special edition for students

'FtP Focus: a special edition for students' was emailed to student registrants on 20 November 2024. The copy as it appeared in the e-bulletin is below:

Hello, and a warm welcome to all student and trainee registrants to our latest FtP Focus bulletin. I hope you’re settling in well to your new academic year.

I’m the Director of Regulatory Operations at the General Optical Council (GOC). For newer students who may not be so familiar with us, the GOC is your regulator. We regulate the optical professions in the UK, including student optometrists and dispensing opticians, fully qualified optometrists and dispensing opticians, and optical businesses. Our overarching aim is to protect patients and the public and maintain public confidence. Find out more about our different functions on the Introduction to the GOC page on our website.

The Regulatory Operations directorate which I lead includes our Fitness to Practise (FtP) function. The aim of our FtP Focus bulletins is to explain and demystify our FtP function and share learnings so that you’re better supported to deliver safe and effective eye care. Read previous editions of FtP Focus.

This edition is for student and trainee registrants. For newer students and those who want to re-familiarise themselves, the bulletin starts with an overview of FtP from our Head of Case Progression, Claire Marchant-Williams, looking at what FtP is and how we investigate if a concern is raised. Elsewhere, pre-registration supervisor Nick Bradshaw talks about his role and provides advice for pre-registration trainees on how to avoid common pitfalls. We also look at a couple of examples of recent FtP cases involving students and what can be learnt from them.

I hope you find this bulletin informative and that it goes some way to easing any concerns you have about FtP. Of course, if you have any questions about FtP, don’t hesitate to email the team at ftp@optical.org. If you have any thoughts or feedback about the FtP Focus bulletin itself, please email focus@optical.org.

I wish all students – new, returning, and pre-registration trainees – all the very best for the year ahead.

Carole Auchterlonie
Acting Director of Regulatory Operations

What is fitness to practise?

Claire Marchant-Williams, the GOC’s Head of Case Progression, guides us through the fitness to practise process.

One of the most visible ways we protect the public is through our fitness to practise function.

It is our job to investigate and act when we receive information or concerns which call in to question a registrant’s fitness to train, practise or run a GOC-registered business.

Anyone can raise a concern with us. We receive concerns from members of the public, patients, carers, employers, the police and other GOC registrants.

Any concerns received are assessed against our Standards which define the behaviour and performance that are expected of registrants. As students, it is particularly important you are familiar with our Standards for Optical Students.

You will not be removed from the register for something minor

We are aware that the fitness to practise process may cause some fear. You may be nervous about receiving a notification of investigation from us or that you may be ‘struck off’ for minor things, but this really isn’t the case.

As it stands, we have around 31,000 registrants (excluding body corporates). We hope you’ll be reassured that in 2023-24, only 34 (0.1%) individuals appeared before a hearing, and none were student optometrists or student dispensing opticians.

There are many reasons why your fitness to train may be impaired. These include:

academic malpractice (like plagiarising or cheating in exams);
amending records;
serious inappropriate behaviour (like violence or sexual assault);
being under the influence of drugs;
receiving a criminal conviction or caution; or
physical or mental health problems that affect your work.

You can read a couple of recent examples later on in this bulletin.

So how do our investigations work?

Our triage team is responsible for reviewing any concerns, self-referrals or referrals that we receive. This team will progress any complaints that could raise potentially serious allegations. They also identify complaints that do not require regulatory intervention and close them.

If a case needs examining further, it will be investigated by our investigations team before being presented to our independent Case Examiners, who will decide what action to take. If they believe it’s likely a concern could be proved, and it’s so serious a sanction may be necessary, it will be referred to our Fitness to Practise Committee for hearing. Our hearings are usually held in public, unless there are private matters involved, such as health or personal issues.

If the concerns are found to be proven at the hearing, there are several possible outcomes. These include suspension, erasure, conditions of practice and no further action.

Visit the Hearings section on our website to find out more about hearings, read recent hearing outcomes, and see guidance for those asked to attend a hearing.

Honesty is always the best policy

Please remember, it is vital that when registering or renewing your registration that you declare any criminal convictions or cautions, disciplinary matters at your college or university, or health issues that could affect your fitness to train, and we encourage you to report any incidents when they happen. Honesty is always the best policy. Read our Declaration Guidance for further information.

If you have any queries or concerns about Fitness to Practise, please contact FTP@optical.org.

Statistics – how many students face hearings each year?

The figures below show the total number of students who attended hearings between 2020 and 2024 and the outcomes. As you can see, it is a tiny proportion of the circa 6,100 student registrants we have on the register.

Year	Total number of student hearings	Erasure	Suspension	Conditions of practice	No further action
2020-21	6	3	2	0	1
2021-22	6	3	3	0	0
2022-23	2	1	0	1	0
2023-24	0	0	0	0	0

My experience as a pre-registration supervisor

Before you become a fully-qualified registrant, you must undertake training in the workplace to apply what you’ve learnt on your course, develop your skills further, and gain hands-on experience. This is known as pre-registration.

Here, pre-registration supervisor Nick Bradshaw, an Ophthalmic Director, discusses his role working with trainee optometrists, some of the issues he’s had to address and how to overcome them.

As a supervisor, my primary role is to support pre-registration trainee(s) through their development with a suitable amount of clinical oversight to ensure the safety of the patient and the trainee’s progression. I've supervised 12 pre-registration optometrists in my career and each has needed differing amounts of help to supplement their academic knowledge, lateral thinking, practical skills or communication. I see it as a very serious responsibility but also an enjoyable and rewarding one.

In the early days, the level of supervision is much greater. However, the vital time spent at this stage is well worth the investment. Building a strong trainee-mentor relationship based on trust, encouragement and professionalism is essential. As this relationship grows and the trainee progresses, the level of supervision changes, the interactions and case scenario discussions elevate and the transformation from newly graduated student into fully qualified registrant occurs.

The pre-registration year can be challenging for both trainee and supervisor. For many trainees, this will be your first job and so getting used to working in a multi-disciplinary team with different characters and levels of workload can be a little overwhelming. Communication with your supervisor is key: share your feelings or concerns early so they can support you or make any changes needed to help your transition from university.

Fortunately, I have never had to approach the GOC with any concerns over a pre-registration optometrist but that doesn't mean I haven't had issues that have had to be addressed. Common pitfalls for trainee optometrists in my experience have included: not completing your logbook as you go along, issues around punctuality or preparedness for the working day, lack of advanced notice or discussion about upcoming assessments and courses, and poor attendance. More serious clinical matters can arise when notes are not completed fully or accurately, referrals are not completed in a timely manner, or you allow patients that need to be checked to leave the practice before your supervisor is available. Whilst the admin downfalls can easily be avoided with some good organisation skills, clinical matters sometimes have to be addressed with a more formal discussion and/or documented outcome.

My best advice to both trainee optometrists and dispensing opticians is to be honest with your supervisor about what you do and don't know. Trust is crucial and building this with your supervisor only comes with integrity and demonstrating your dedication to your training. Stay on top of your admin, and be aware of your competencies and what you need to complete in what timescale. If you put in the time and hard work, you will reap the benefits and become a confident and competent fully qualified registrant and a value to the profession.

Case studies

Case study #1: Self-referral of a student registrant who was cautioned for possession of a Class B drug.

Self-referral
The registrant informed the GOC that they had accepted a simple police caution for possession of a Class B drug.

Investigation
The investigation was opened following the registrant’s self-referral where they admitted to the alleged misconduct. The registrant had no previous convictions or cautions. During the investigation, it was found that there was no direct evidence that the conduct which gave rise to the caution was in any way connected to the registrant’s professional life. There was no evidence to suggest that the registrant’s conduct had impacted on patient safety, nor were there any other professional performance issues.

Outcome
The matter was then referred to the Case Examiners (CE). They noted that the registrant had self-declared in a timely manner. However, they also noted that the registrant did not provide any representations which meant the level of insight, remediation and likelihood of repetition was unknown. The material evidence suggested the incident was a one-off and did not cross the seriousness threshold to justify being referred to the Fitness to Practise Committee. However, given the circumstances and what appeared to be a lack of insight due to providing no representations, the CEs determined that the incident potentially damaged public confidence in the registrant and the profession. In view of this, the CEs issued the registrant a Warning because “the Registrant’s admitted conduct has fallen below the standard expected, to the extent that a formal response from the GOC is warranted.” The registrant then provided a response detailing regret, lapse of judgement, and ongoing remediation, and the CEs took note of this. However, in accordance with the Warnings Guidance, the CEs maintained their initial decision to issue a Warning.

Learnings
It’s positive that the registrant self-declared promptly. However, should you find yourself under investigation, you must respond to requests on time. In this case, the registrant should have provided representations in a timely manner and not belatedly following the issuing of a Warning. This would have allowed CEs to understand the registrant’s level of insight, their remediation and the likelihood of repetition.

Case study #2: - Self-referral of a student registrant who failed to disclose a criminal conviction.

Self-referral
The registrant received a criminal conviction in 2011, several years before joining the GOC register in 2019. After the registrant was advised by their professional body that even ‘spent’ convictions needed to be disclosed to the GOC, the registrant declared the conviction to the GOC.

Investigation
It was found that the registrant had failed to disclose the conviction on two separate occasions – firstly, when completing the student registration application in 2019; and secondly, when completing the student retention application in 2020. The GOC guidance for joining the register and retaining on the register both state a duty to declare all convictions, including ones that are spent. The registrant provided representations, saying the reason for not declaring their conviction was because their barrister had told them that they didn't need to declare it after six years. The matter was then referred to the Case Examiners (CE). The CEs found that the registrant's claim that they did not know they needed to disclose the conviction ultimately came down to their state of mind at the time the applications were made. In view of this, the matter was referred to the Fitness to Practice Committee (FtPC).

FtPC Hearing
The FtPC noted that the conviction involved dishonesty, and the registrant then went on to dishonestly omit the conviction from their student registration forms on two occasions. Whilst the FtPC acknowledged that the registrant’s conviction related to conduct which by then had occurred over 10 years ago, and the failure to declare convictions to a discrete period in 2019-2020, there was no testimonial evidence before the FtPC to demonstrate that the registrant had the character to work safely and effectively. In these circumstances, the FtPC concluded that there was an ongoing risk of repetition. Given the seriousness of the registrant’s failings and in the absence of sufficient remediation, the FtPC concluded that the registrant’s acts and omissions would be regarded as dishonest by the standards of honest and reasonable people and as such their fitness to train was impaired. Having concluded that a suspension order would be insufficient to protect the wider public interest, the FtPC determined that the appropriate and proportionate sanction was erasure. In reaching this conclusion they took into account the following extracts from our Indicative Sanctions Guidance: “a. Serious departure from the relevant professional standards as set out in the Standards of Practice for registrants and the Code of Conduct for business registrants;… f. Dishonesty (especially where persistent and covered up);… or h. Persistent lack of insight into seriousness of actions or consequences.”

Learnings

The registrant should have disclosed their criminal conviction at the time of registration, even if it was ‘spent.’ It’s important that all registrants disclose any convictions as soon as possible – honesty is always the best policy.
This registrant did not show insight into their actions. If you're called to appear before a FtPC, it’s best to provide appropriate testimonial evidence and show that you have undertaken sufficient remediation.

Useful links

Association of British Dispensing Opticians: ABDO is a representative membership organisation for dispensing opticians, including student dispensing opticians.

ABDO College: ABDO College provides programmes leading to professional qualifications awarded by the Association of British Dispensing Opticians.

Association of Optometrists: The AOP is a representative membership organisation for optometrists, including student optometrists, currently supporting over 82% of practising optometrists in the UK.

British Contact Lens Association: BCLA is a membership organisation that seeks to provide members, which include students, with access to training and relevant information, as well as the opportunity to communicate with others involved with contact lenses, whatever their role.

The College of Optometrists: The College is the professional body for optometrists, including student optometrists. It qualifies the profession and delivers the guidance, development and training to ensure optometrists provide the best possible care.

Optical Consumer Complaints Service: The OCCS is an independent and free mediation service for consumers (patients) of optical care and the professionals providing that care, which is funded by the GOC.

We hope you found this bulletin informative. Please contact us on focus@optical.org for any queries, comments or suggestions.

Read previous editions of FtP Focus.