We respond to the GOC's COVID-19 statements consultation

Question 1: Do you agree that it is appropriate to align our COVID-19 statement framework with The College of Optometrists’ red/amber/green classification system?
Yes.

It allows clarification with an existing classification system that optometrists are already familiar with. It better supports them in understanding where and when the statements apply during a particular phase of the pandemic. Furthermore, having a single classification system allows a more consistent implementation of the statements as different parts of the UK experience local and national restrictions now and in the future.

Please note that, since this consultation was published, the College has reviewed and updated the definitions or red and amber, to help our members understand how they relate to each UK nation’s tiers/levels.  In order to enter The College’s Red phase, a nation’s government or health system should specify a restriction of routine primary care services. 

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Question 2: In the event of a similar emergency situation, should we apply the principles outlined in this statement again?
Yes.

However, this statement, whilst useful, created some confusion, especially over the need to ‘approve’ rather than ‘note changes.’ But now that the process is in place, in a future similar situation it shouldn’t create the same confusion. We would welcome more clarity on the process.

Question 3: What has been the impact of this statement on a) education providers, b) students, c) business registrants / employers, d) patients and the public, and e) any other groups?
Negative impact: see our response to question 2 above.

This statement created confusion and ultimately delays in submitting temporary change requests. These delays contributed to the relaunch of the Scheme taking over 5 months and as a result created stress and uncertainties for students not knowing if and when they could continue their route to registration.

We look forward to working with the GOC on this in the future.
 

Section 2.2: GOC statement on supply of spectacles and contact lenses during COVID-19 emergency (GOC/COVID/02)

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Question 4: Do you agree with the content of this statement?
Yes.

The risks of a patient attending practice and spreading/contracting Covid-19 should be balanced against the risk of supplying spectacles and contact lenses with an expired prescription; and optometrists should use their professional clinical judgement in doing so.

Question 5: Do you agree with our view that this statement should only apply to the red and amber phases of the pandemic?
Yes.

During green phase, an up-to-date clinical examination and prescription are possible and desirable as they will increase the clinical information needed to decide on whether to supply contact lenses/spectacles.

Question 6: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) patients and the public, and d) any other groups?
We can only comment on optometrists with reference to a).

Positive impact: Published guidance recommends that optometrists should remind their patients of the steps to take to minimise the risk of complications (including potentially switching to daily disposables and reducing/stopping overnight wear) while emphasising normal contact lens care behaviours (washing/drying hands, contact lens cleaning and disinfection, avoidance of water exposure to the contact lenses). Thus, optometrists were still able to deliver these key messages and advice to patients safely and effectively through remote consultations.

• Jones, L., Walsh, K., Willcox, M., Morgan, P. and Nichols, J., 2020. The COVID-19 pandemic: Important considerations for contact lens practitioners. Contact Lens and Anterior Eye.
• Zeri, F. and Naroo, S.A., 2020. Contact lens practice in the time of COVID-19. Contact Lens and Anterior Eye, 43(3), pp.193-195.

Section 2.3: GOC statement on contact lens aftercare during COVID-19 emergency (GOC/COVID/03)

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Question 7: Do you agree with the content of this statement?
Yes as it explains what the current legal framework already allows in terms of aftercare delivery.

Question 8: Do you agree with our view that this statement should continue to apply in all phases of the pandemic?
Yes as it explains what the current legal framework already allows in terms of aftercare delivery.

Question 9: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) patients and the public, and d) any other groups?
We can only comment on optometrists with reference to a).

Positive impact: The use of technology to deliver remote consultations has helped optometrists decide when a particular individual requires face-to-face care or can be managed remotely or referred appropriately – this applies to both eye and contact lens examinations. We agree that its use must be in line with the Opticians Act and GOC Standards. However, we are of the opinion that, after the pandemic is over, the use of technology should not be used as a tool to replace routine eye care, but to supplement it for the benefit of patients on an individual needs basis.

Section 2.4: GOC statement on our approach in fitness to practise for the service of documents and facilitating hearings during the COVID-19 emergency (GOC/COVID/05)

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Question 10: Do you agree with the content of this statement?
Yes.

Timely communication is vital for optometrists to help avoid distress/resolve issues. 

However, we suggest adding a requirement on the GOC to ensure that registrants have effectively received the communication. Although emails should be reliable, this is not always the case.

If something was sent by recorded delivery you would get proof of delivery. We would recommend at the very least a read receipt to confirm effective delivery of an email.

Question 11: Do you agree with our view that this statement should continue to apply in all phases of the pandemic?
Yes.

Question 12: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) patients and the public, and d) other participants in the fitness to practise process?
We can only comment on optometrists with reference to a).

This allows more flexible methods of sending important documentation, but this is dependent on optometrists’ access to internet/email, which may unfairly discriminate against those who do not have access to it.

Question 13: We are currently in discussion with the Department of Health and Social Care to underpin this statement with emergency legal powers that:

• allow fitness to practise notices to be served by email;
• clarify that hearing ‘venue’ includes audio and/or videoconferencing details; and
• enable the Hearings Manager to postpone or adjourn hearings.

What would be the impact of the GOC securing these powers?
These powers allow more flexible methods of fitness to practise notices and hearings, but this is dependent on optometrists’ access to the internet/email, which may unfairly discriminate against those who do not have access to it, and may lead to distress if there is a delay in receiving further communications.  Suitable alternative forms of communication must also be available for registrants who do not have access to email.

Question 14: Should the GOC have further powers to start substantive hearings with three Fitness to Practise Committee members (rather than five as we currently do)?
Yes.

This would align the process with other regulators.

Question 15: We currently have to start substantive fitness to practise hearings with five committee members. What would be the impact of the GOC securing the powers to start substantive fitness to practise hearings with three committee members?
Having fewer registrants on the panel may affect the objectivity of the decision. It is important to maintain a fair and effective process, with clear and transparent guidelines to achieve this.

Section 2.5: GOC statement on Continuing Education and Training (CET) during the COVID-19 emergency (GOC/COVID/06)

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Question 16: Do you agree with the content of this statement?
Yes.

This flexibility allows optometrists to focus on delivering eye care. Therefore, a waiver of the minimum of 6 CET annual points is welcomed.

Question 17: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) CET providers, d) patients and the public, and e) any other groups?

We can only comment on optometrists with reference to a).

Positive impact: Our members have continued to achieve CET and we have not seen a notable dip in numbers.

Our members have not had as many opportunities for achieving CET points this past year.  Additional infection control and PPE requirements mean that many optometrists are spending longer hours in practice.  Some optometrists have been unable to work and this may affect their ability to access in-house CET opportunities. Similarly, businesses and employers may not have been in a position to offer planned CET.  However many members are also expanding their scope of practice through involvement in new enhanced and shared care pathways, so are still able to progress professional development in other ways.

The College has converted our face-to-face events to online webinars and peer discussion groups where possible, but it should be noted that online peer discussions cannot accommodate the same numbers as our prior face-to-face sessions. This, along with interactive CET overall, is the most likely area where optometrists will find it difficult to meet the necessary CET requirements. 

Question 18: The three-year CET cycle offers sufficient flexibility for registrants to complete their overall CET requirements for 2019-21. We are not intending to reduce the overall requirements for the cycle or remove the annual six point expectation for the year 2021 as the CET scheme ensures patient safety and public protection. Do you agree?

We do not have the GOC data on how far interactive and peer discussion requirements have been met compared with this stage in previous cycles but, as per our comments above, these areas may require the GOC to consider introducing some flexibility. We suggest this might be something the GOC revisits in its review of the CET statement in January 2021.  The above factors will continue to apply well into 2021.

Section 2.6: GOC statement on optometrists, dispensing opticians and students working in different settings during the COVID-19 emergency (GOC/COVID/07)

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Question 19: Do you agree with the content of this statement?
Yes.

This statement is based on existing legislation. There is no legal barrier to optometrists working in non-eye healthcare roles provided they have sufficient training, competence, supervision, and insurance/indemnity in place. If working in national health services in non-eye healthcare, the Coronavirus Act 2020 may allow indemnity cover.

However, we believe that this statement should be developed further, with more substance and clarity added. For example, greater clarity should be included on scope of practice in the context of the COVID-19 pandemic and whether registrants would be deemed to be practising under their current registration. 

It would also be helpful to include a link to the e-learning resource for the UK health and care workforce that has been developed by Health Education England. 

Question 20: Do you agree with our view that this statement should continue to apply in all phases of the pandemic?
Yes.

Question 21: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) patients and the public, and d) any other groups?
We can only comment on optometrists with reference to a).

Negative impact: This statement may lead to a possible confusion on the responsibilities as a registrant for eye health care provision versus a non-eye health care role. An example of this would be the administration of vaccinations. The Human Medicines Act is clear that optometrists cannot administer medicines parenterally unless under direction of an appropriate practitioner (physician, dentist, IP nurse, and IP pharmacist): The Human Medicines Regulations 2012.

As mentioned in our comment above, we believe that this statement should be developed further, with more substance and clarity added to cover such situations. 

Question 22: Should this statement become a permanent GOC policy position independent of the COVID-19 emergency?
No.

While we acknowledge that this would be a welcome recognition of the professional skills and experience of optometrists to support non-eye care colleagues/services, we believe optometrists should prioritise the delivery of eye health and care services where possible. The pandemic has negatively impacted capacity within secondary eye care, which could lead to more patients experiencing unnecessary sight loss.  Optometrists can play a key role in managing patients through existing and newly developed enhanced care pathways, and so we expect that this will lead to an increased demand for optometrists in the near future.  While we recognise that some members may not be able to currently work as optometrists during this difficult period, we hope this will resolve as routine services routine and new services are commissioned.

Section 2.7: GOC statement for CET providers on CET provision during the COVID-19 emergency (GOC/COVID/08)

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Question 23: Do you agree with the content of this statement?
Yes.

Question 24: Do you agree with our view that this statement should continue to apply in all phases of the pandemic?
Yes.

Question 25: Do you agree that we should continue to allow online CET provision until the end of the current CET cycle (31 December 2021)?
Yes

Online CET would be a welcome option in the long-term, as some optometrists may not be able to attend face-to-face CET events/peer discussions for a variety of reasons (cost, travel, time).  Online CET would allow more registrants to access and benefit.

Question 26: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) CET providers, d) patients and the public, and e) any other groups?

We can only comment on optometrists with reference to a).

Very positive impact: It has enabled our members to participate in online CET and maintain and develop their competence, skills and knowledge during the pandemic.

Section 2.8: GOC statement on verification of contact lens specifications during the COVID-19 emergency (GOC/COVID/09)

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Question 27: Do you agree with the content of this statement?
No.

We note the GOC states that a contact lens specification has to be verified with the person who provided it unless the sale is made by or under the supervision of a registered optometrist, dispensing optician or medical practitioner (an ‘appropriate practitioner’). 

This is not correct. Verification is only required if – as well as being conducted under general direction – the seller does not have the original specification (Opticians Act 1989 s.27(3)(a)(i)). 

The requirement for verification was introduced in 2005 as a patient protection measure, to reduce the chance of patients being supplied with incorrect lenses, as well as to ensure that lenses are not supplied beyond the expiry date of the specification. To relax this provision – as well as requiring a change to primary legislation – would need the GOC to show there is a need for this during the pandemic.

The current situation is that contact lenses may currently be supplied: 

• By or under the supervision of the patient’s contact lens fitter – verification is not necessary.
• Under the general direction of the patient’s contact lens fitter (who will have their specification) – verification is not necessary.
• By or under the supervision of an appropriate practitioner – verification is not necessary
• Under the general direction of an appropriate practitioner who has the patient’s original specification – verification is not necessary
• Under the general direction of an appropriate practitioner who does not have the patient’s original specification – verification is necessary.

It is of note that all of these methods can be used to supply the patient with lenses remotely, without the patient needing to attend the practice. 

As verification was introduced for the protection of the public, and lenses can be supplied remotely under the first four bullet points above, we see no reason to relax the verification requirements at this time.

Question 28: Do you agree with our view that this statement should continue to apply in only the red phase of the pandemic?
Yes as the majority of - if not all - practices will be open and contactable during amber and green phases.  

Verification is for patient safety, so it should not be removed unless there is a good reason for this.

Question 29: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) patients and the public, and d) any other groups?
We can only comment on optometrists with reference to a).

Positive impact: Patients can access their contact lenses with minimal disruption; but optometrists must make a professional clinical judgement to supply them where verification is not possible – this takes time and careful decision making, so optometrists must be given sufficient time to do so.

Section 2.9: GOC statement on infection prevention and control during the COVID-19 emergency (GOC/COVID/11)

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Question 30: Do you agree with the content of this statement?
Yes.

Infection prevention and control is required as part of GOC Standards of Practice (and The College of Optometrists Guidance for Professional Practice) even in normal circumstances.  

Question 31: Do you agree with our view that this statement should continue to apply in all phases of the pandemic?
Yes.

Infection prevention and control is required as part of GOC Standards of Practice (and College Optometrists Guidance for Professional Practice) even in normal circumstances.

Question 32: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) patients and the public, and d) any other groups?

We can only comment on optometrists with reference to a).

Positive impact: Infection control practices are important for prevention of spread of all pathogens, and so standardised processes/procedures to do so are welcome. The adoption of more thorough and visible IPC enhances the clinical role of optometrists and increases patient confidence in the care they receive.

However, we recommend that registrants are given sufficient time to comply with this statement before and after each consultation as donning/doffing PPE and ICP procedures take time.  For example, there needs to be sufficient time to appropriately disinfect the examination room, clean/disinfect/dry hands and put on/take off PPE between patients. Suitable PPE should also be provided.

Pult, H., 2020. COVID-19 Pandemic: Survey of future use of personal protective equipment in optometric practice. Contact Lens and Anterior Eye.

Question 33: We propose to make this statement a permanent GOC policy position to apply in the event of any future pandemics/emergencies to support our standards. Do you agree?
Yes.

Section 2.10: Joint GOC / General Pharmaceutical Council (GPhC) statement on redeployment of optometrists or dispensing opticians within pharmacy practice during the COVID-19 emergency (GOC/COVID/12)

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Question 34: Do you agree with the content of this statement?
Yes, although we do not see the need for this statement.

As mentioned in our response to question 19 above, this statement is based on existing legislation. There is no legal barrier to optometrists working in non-eye healthcare roles provided they have sufficient training, competence, supervision, and insurance/indemnity in place.

Question 35: Do you agree with our view that this statement should continue to apply in all phases of the pandemic?
Yes.

Question 36: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) patients and the public, and d) any other groups?

Please see our response to question 21 above.

Section 2.11: GOC statement on use of technology during the COVID-19 emergency (GOC/COVID/13)

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Question 37: Do you agree with the content of this statement?
Yes.

This statement is based on existing legislation. The Opticians Act 1989 does not place any restrictions on what equipment, products, or technology registrants can use.

Question 38: Do you agree with our view that this statement should continue to apply in all phases of the pandemic?
Yes.

Question 39: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) patients and the public, and d) any other groups?
We can only comment on optometrists with reference to a).

Positive impact: The use of technology to deliver remote consultations can help optometrists decide when a particular individual requires face-to-face care or can be managed remotely or referred appropriately – this applies to both eye and contact lens examinations. We agree that their use must be in line with the Opticians Act and GOC Standards. However, their use requires competence and/or appropriate training to deliver this safely and effectively. 

We believe that, after the pandemic, the use of technology should not be used as a tool to replace routine eye care, but to supplement it for the benefit of patients on an individual needs basis.

Question 40: Should this statement become a permanent GOC policy position independent of the COVID-19 emergency to support our standards?
Yes.

This is similar to how some GPs were undertaking remote consultations before the pandemic (Hammersley et al., 2019). While remote consultations were shown to be positively received and improved efficiency, there were issues related to ensuring technology was appropriate e.g. resolution sufficient to view clinical signs; ability to send/receive images/correspondence; safety and protection of patient data (Sharma et al., 2020). Furthermore, this technology was reported as only suitable for managing problems not requiring physical examination (Sharma et al., 2020). In optometry, unless a diagnosis is not in doubt, physical examination through assessment of visual function is invariably required, so the approach must be tailored based on individual need. 

Although remote consultation technology improves efficiency (as the patient does not have to attend practice); it still requires significant time for optometrists to exercise professional judgement and manage patients appropriately. Thus, we are mindful of optometrists’ concerns relating to the provision of sufficient clinic time to provide this service, and seek reassurance from the GOC that they will support the principle that optometrists should have sufficient time to safely deliver eye care and exercise professional judgement for patient benefit during remote consultations, given that clinical information is limited.

Hammersley, V., Donaghy, E., Parker, R., McNeilly, H., Atherton, H., Bikker, A., Campbell, J. and McKinstry, B., 2019. Comparing the content and quality of video, telephone, and face-to-face consultations: a non-randomised, quasi-experimental, exploratory study in UK primary care. British Journal of General Practice, 69(686), pp.e595-e604.

Sharma, S.C., Sharma, S., Thakker, A., Sharma, G., Roshan, M. and Varakantam, V., 2020. Revolution in UK General Practice Due to COVID-19 Pandemic: A Cross-Sectional Survey. Cureus, 12(8).

Section 2.12: GOC statement on service of registration notifications during the COVID-19 emergency (GOC/COVID/14)

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Question 41: Do you agree with the content of this statement?
Yes.

This allows more flexible methods of sending important documentation, such as registration notifications.

However, we suggest adding a requirement to ensure that registrants have effectively received the communication. Although emails should be reliable, this is not always the case.

If something was sent by recorded postal delivery you would get proof of delivery. We would recommend at the very least a read receipt to confirm effective email delivery.

Question 42: Do you agree with our view that this statement should continue to apply in all phases of the pandemic?
Yes, but as mentioned above, we would recommend adding a read receipt to confirm effective email delivery.

Question 43: What has been the impact of this statement on a) optometrists and dispensing opticians, b) business registrants / employers, c) patients and the public, and d) any other groups?
We can only comment on optometrists with reference to a).

Positive impact: It allows an easier and quicker access for registrants to important GOC documentation.

Question 44: We are currently in discussion with the Department of Health and Social Care to underpin this statement with emergency legal powers to enable us to issue registration notices by email if the registrant has provided us with an email address. What would be the impact of the GOC securing these powers?
Optometrists will be able to receive faster communications with reduced environmental footprint; but this is dependent on optometrists’ access to internet/email which may unfairly discriminate against those who do not have an easy access.  Steps would need to be put in place to ensure all optometrists have equal access. 

Question 45: Are there any other areas that the sector requires specific guidance on or any legislative changes to support care during the COVID-19 pandemic or any future similar pandemics/emergencies?
The sector would requires specific guidance to support the reassurance to optometrists that they will be supported in decision making for patients who are managed through remote consultations. While optometrists will be expected to exercise professional judgement based upon individual need, they will do so in good conscience for the patient/public benefit due to limited clinical information.

Question 46: The main route we have used in supporting registrants through the COVID-19 pandemic is signposting to guidance and production of our COVID-19 statements. Do you feel our approach to supporting registrants during COVID-19 has been effective?
When the pandemic started, the GOC acted early, rightly signposting to guidance and producing additional statements and easements to support registrants. However, feedback from our members indicated that registrants found some of these statements confusing. Since then we have sought to work more closely with the GOC to ensure that there is clarity and parity across College and GOC recommendations, and will continue to work in this way for the benefit of members/registrants.

We have had direct contact with the GOC since March 2020 on how arrangements for optometry education could appropriately be modified so that it could continue to be delivered safely and effectively in the context of COVID-19. During this time, we have valued the GOC’s receptiveness to considering changes that we have put forward to better support registrants. However, we would have valued more transparency in the GOC’s governance and sign-off processes for considering and approving temporary changes to education arrangements. We have observed that the complexity of the GOC’s temporary change processes have delayed responses to the needs presented by the pandemic.

Submitted: January 2021