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News from 23 September Council

27 Sep 2010

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GOC considers low income retention fee

  • The GOC is developing proposals to introduce a reduced retention fee for practitioners earning a lower income. Work will now begin on looking at how a reduced fee could work in practice.
  • At the September Council meeting, members agreed that a reduced fee would be more beneficial to those earning lower incomes, than the ability to pay the standard retention fee in instalments.
  • The decision follows the GOC’s consultation in 2009 on the possibility of introducing a staged payment facility. Council considered the business case and impact assessment for whether a staged payments process should be adopted.
  • Members acknowledged that establishing a staged payments scheme would provide additional convenience and improved service for some registrants. However, introducing the facility would require changes to the Registration Rules, would need significant systems development, and incur ongoing administration and other costs.
  • Council noted that there would be significant costs involved to establish and maintain a staged payments facility. These costs would either need to be borne by all registrants regardless of whether they use the system, in the form of higher retention fees, or else an additional administration fee would need to applied to those wishing to pay by instalments. Since the proposal comes during a time of significant pressure to reduce GOC costs and retention fees, a staged payment facility could therefore end up disadvantaging those who it is intended to benefit, such as low income earners. Members also noted that despite recent fee increases, the GOC retention fees remain among the lowest of all the UK healthcare regulators. No other regulator with fees below £400 per annum currently offers a staged payment facility.
  • Council concluded that introducing a discounted retention fee for registrants on a lower income could potentially be more beneficial. A different fee for practitioners on a low income would positively benefit women practitioners, older people and disabled registrants.

GOC agrees proposals for revalidation

  • In June, Council agreed that the Continuing Education and Training (CET) scheme would be developed to provide a sound evidence-base for revalidation. 
  • At the September meeting, members agreed revised Principles and Requirements for the CET Scheme post 2012. These principles will now form the basis of a revalidation scheme for optometrists and dispensing opticians. Revalidation will be introduced from January 2013.
  • The proposals are informed by research carried out by Europe Economics on risks in optical practice, and by feedback obtained at stakeholder events with registrants, CET providers and other interested parties. 
  • Changes to the scheme are designed to ensure that registrants complete CET that is relevant to their scope of practice, undertaken regularly and involves some interaction with peers. 
  • Guidance to registrants will be issued to explain what will normally be expected, depending on each registrant's scope of practice.
  • The main changes include:

1. The three year CET cycle and 36 point requirement will remain.
2. Registrants will be expected to earn a minimum of six points per year. Annual checks will be used and reminders sent to registrants who are not on target. Any registrants who have not met the expected level and range of CET activity will be expected to justify why this is the case.
3. A wider scale of points will be introduced to reflect the nature of the activity. For example, interactive CET such as peer review, and clinical skills CET will carry a greater points value than attendance at lectures or text based distance learning activities.
4. Registrants will be expected to do CET across all relevant competency areas and in a range of modalities.
5. Optometrists will be expected to complete one peer review activity per cycle involving patient records and decision making.
6. Contact lens opticians will no longer be required to obtain additional specialist CET points in addition to their general points requirement. Instead they will be required to ensure that at least six general poinst per year are in contact lens CET and to undertake one peer review activity per cycle.
7. No shortfall period. Instead, the Registrar will have discretionary powers to apply conditional registration in certain circumstances.
8. These powers will also be used to deal with registrants who fail to meet the GOC’s expectations as to the nature of the CET activity to be undertaken (competencies and modalities). This may apply to registrants who are not working in practice but require GOC registration for other reasons (eg company directors, academics, those on maternity or career breaks or suffering serious illness).
9. There will be a limit on the number of points that registrants can gain through text-based distance learning each cycle.
10. Introduction of a facility for registrants to give feedback on CET activity when accepting pending points.
11. Registrants will also be expected to demonstrate that they have a development plan in place for their CET activity to ensure that they do meet the annual and three yearly targets and that the CET they choose to undertake is linked to their scope of practice.
12. A progress bar will enable registrants to track which competencies have been covered by their CET activities and which still need to be met.
13. Alternative approval process with an option to accredit CET providers in addition to individual CET events. This system follows the same principles as the GOC’s approval of training providers, and would be a much more efficient and effective system.
14. Every six years, optometrists and contact lens opticians who are working in practice, will be required to demonstrate that they have been subject to a clinical skills assessment in ocular abnormalities and ocular examination. This would still carry CET points which would count towards a registrant’s points total but only one such activity would be required across two cycles.

  • The GOC will now develop these proposals later this year.

GOC considers responds to the Department of Health’s report, ‘Liberating the NHS’ and the arms-length bodies (ALB) review

  • The GOC considered its draft response to the proposals set out in the Department of Health’s White Paper ‘Equity and Excellence: Liberating the NHS’ and the review of Arms-Length Bodies (ALBs). 
  • The key changes likely to affect the GOC are:
  • PCTs currently confirm the registration status and FTP history of registrants who wish to join performers’ lists. It appears that this role will be taken over at a national level by the NHS Commissioning Board. 
  • Local HealthWatch organisations will represent the interests of patients, taking over the role of LINks, PALs and PCTs. The GOC will need to develop strong working relationships with these groups, for example to ensure that information relating to complaints is shared. 
  • There may be implications for the GOC’s core competencies, and FTP investigations, if new quality standards for optometry are developed by the National Institute for Clinical Excellence (NICE)
  • It is unclear how the funding for CET currently available for optometrists will be accessed under the new arrangements. Any changes to the way in which CET is funded may have an effect on how registrants are able to meet their CET requirements, and any future proposals for revalidation.
  • Key issues arising from the ALB review are: the transfer of the CHRE from the ALB sector to self-funding status. The CHRE will need to demonstrate that any levy imposed on the GOC is proportionate. The GOC and all the other healthcare regulators will need to work closely with CHRE as they develop their fee and budget proposals, to ensure that the work carried out by CHRE is cost-effective, in the interests of patients and the public, and does not overburden the GOC and prevent it from carrying out its functions efficiently and effectively. The abolition of the Appointments Commission will have an impact on the recruitment of Council members. The GOC will need to engage with the development of transition arrangements for the Commission’s functions, and ensure that the new arrangements do not prevent the timely recruitment of new members when needed.

Fitness to practise adjudication and OHPA

  • The Government is currently consulting on whether it should proceed with the previous administration’s plans to establish the Office of the Health Professions Adjudicator (OHPA). The GMC planned to transfer the adjudication of its hearings to the new body, with the GOC to follow. 
  • Council is considering its response to the Department of Health’s consultation on this issue. 
  • The consultation outlines three options on how to proceed:
  • Option 1: Proceed with OHPA implementation as previously planned
  • Option 2: Repeal legislative provision relating to OHPA and, in separate legislation, take forward steps to enhance independence of adjudication and modernise existing processes at the GMC (and subsequently review whether to also do so for the GOC and other health regulators)
  • Option 3: Repeal legislative provision relating to OHPA and take no further action.
  • Option 2 is the Government’s preferred option ‘as it delivers the benefits expected from the implementation of OHPA to adjudicate on GMC FTP cases, but at a lower cost, giving the greatest net benefit overall’.

The Optician’s Registers: how should fitness to practise information be displayed?

  • The Council recently consulted on the accessibility of information about the fitness to practise of GOC registrants. In light of feedback from that consultation, and recommendations made by the CHRE, members agreed changes to the way FTP information will be made available. Changes include:

1. The records of suspended registrants will in future be included in the online public registers, with a note against their record clearly indicating the suspended status.
2. Struck off former registrants will not be included in the public registers, but additional clarification will be included on the GOC website.
3. In future, FTP Committee decisions will remain accessible in the ‘Past Hearings’ section of the GOC website only while a sanction is in force. In the case of hearings where no impairment is found, the decision notice and transcript be removed from the website after one year.
4. Including historical fitness to practise sanctions on a separate tab of registrants’ records of the public registers will be a medium-term GOC objective, dependent on organisational priorities and available budget.


Online retention: project update

  • Council received a project update on the implementation of online retention. 
  • It is anticipated that online retention will be available for individual registrants only this December, ahead of the 2011-12 retention period. Online retention will not be available for bodies corporate at the beginning of the retention period, and business registrants will be sent hard copy retention forms. After reviewing costs and schedules, a decision will be made on whether to proceed with developing the facility for registered businesses this year. 
  • A number of key benefits of the new system include: improved quality of data collection and customer service; lower administrative costs; and giving registrants much greater certainty and control of the retention process and over their data.

Measuring GOC performance

  • Council received a quarterly report on the delivery of key projects outlined in the annual 2010-11 business plan. Reports included: 
  • Promoting standards and guidance: a patient information leaflet, 'What to expect from your optician' has been published, aimed at explaining the professional and ethical standards that patients should expect when visiting their optometrist or dispensing optician. The leaflet is available from and has been promoted at the annual Citizens Advice Conferences (Scotland and England/ Wales). 
  • Improving witness and complainant support: guidance has been published to offer increased support to explain what happens if you are asked by the GOC to be a witness at a hearing of the Fitness to Practise Committee. Guidance for registrants designed to improve their understanding of the FTP system has also been completed and is due to be published online shortly. All guidance documents are available from 
  • Council also received a progress report against newly-configured Key Performance Indicators (KPIs), set against the strategic plan for 2010-15. These measures will support Council in its role to monitor the delivery of core work across all areas of the organisation: standards, education, HR, communications and information, registration, FTP, hearings and finance.

Items for information:

Equality and diversity action plan 2010-12

  • The Equality and Diversity Action Plan 2010-12 was approved by Council at its June meeting. An updated plan was presented to Council for information to show the GOC’s activity in maintaining and achieving satisfactory performance against the plan.

Next meeting: Thursday, 25 November 2010, 41 Harley Street.

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