ABDO’s concerns about the General Optical Council’s (GOC) Education Strategic Review (ESR) have led the organisation to propose that the GOC should: commission the development of separate standards of proficiency for dispensing opticians and optometrists and require approved providers to ensure that students achieve these standards before qualifying and joining the GOC register; allow greater flexibility in the structure of educational delivery and assessment rather than insisting that all education providers incur the costs of moving to the new single point of accountability (SPA) model; extend the current consultation to allow respondents to comment on the financial impact analysis which the GOC has recently commissioned and postpone any decisions on changes to the system of education until the GOC addresses in full the concerns raised by ABDO and other stakeholders.
ABDO’s suggestions in more detail:
1. The GOC should commission the development of separate standards of proficiency for dispensing opticians and optometrists and require approved providers to ensure that students achieve these standards rather than simply providing guidance in the proposed ‘indicative document’. Enforceable ‘threshold standards’ would safeguard the public by providing the detail which is lacking in the proposed outcomes for registration about the clinical knowledge and skills required on entry to the professions. They would provide a benchmark, therefore, for both new providers and providers who wish to adapt existing approved qualifications. We would be happy to work with the GOC and other stakeholders to develop these standards.
2. The GOC should allow more flexibility as to the structure of educational delivery and assessment rather than insisting on the SPA model. The proposed standards for approved qualifications are unduly prescriptive in requiring there to be a single point of accountability for each route of registration and this is inconsistent with the GOC’s apparent desire to be outcomes-focused. A more flexible approach would enable ABDO and other professional bodies to continue to provide external, rigorous professional examinations that ensure consistent, high standards of attainment by students from a range of different education providers, without having to duplicate the management controls and quality assurance processes which those providers have already. The fact that ABDO’s Level 6 FBDO Diploma in Ophthalmic Dispensing is a qualification regulated by Ofqual would provide further assurance of high quality education. Under this more flexible approach, it would still be possible for education providers to act as a single point of accountability if they wished, although there ought still to be some form of independent, external assessment to ensure consistent, high standards.
3. The GOC should extend the current consultation to allow stakeholders four weeks following publication of the GOC’s financial impact analysis to consider this report and submit their consultation responses or, in the case of stakeholders who have submitted their responses already, to prove supplementary comments.
4. The GOC should postpone any final decision in relation to the ESR until it has addressed in full the concerns raised by ABDO and other stakeholders, including the widespread concern about the ability of education and qualification providers, and the optical sector as a whole, to fund the implementation of the changes that result from the ESR.
Tony Garrett, ABDO general secretary, said: “These suggestions should not be read as an expression of support for the GOC’s overall package of proposals, which, as we have said, are flawed, insufficiently justified, lacking any proper analysis of the impacts and being pursued with undue haste. However, ABDO remains committed to protecting the public by ensuring that student dispensing opticians are equipped for future roles and will continue to work with the GOC and other stakeholders in an effort to develop a new system that delivers tangible, affordable improvements in the quality of education throughout the UK and supports extended scopes of practice.”
ABDO continues to have concerns, and believes that the consultation was launched prematurely. First, there are serious flaws in the GOC’s proposals that create a serious risk of lower and inconsistent standard of education. Secondly, it was not reasonable to expect stakeholders to engage with the consultation during the current pandemic. Thirdly, it was not necessary to proceed with the consultation as a matter of urgency.
Read ABDO’s full response to the consultation here.