Consultation responses

The College regularly responds to consultations from both sector and government organisations.

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We take the lead on influencing the agenda of policymakers to ensure that optometrists' skills are valued and used in designing eye care services, and we regularly contribute and comment on policy relevant to our members. Here are our most recent consultation responses:


Williams Review into gross negligence manslaughter in healthcare

Read the evidence we submitted to the Review in relation to gross negligence manslaughter and healthcare professionals (April 2018)

Over the counter prescriptions

Our response to a consultation on conditions for which over the counter items should not routinely be prescribed in primary care (March 2018).

GOC Education Strategic Review

Our response to the GOC's Education Strategic Review concepts and principles consultation (March 2018)

England Vision Strategy Priorities Consultation

Our response to the consultation on the England Vision Strategy Priorities, addressing problems faced by individuals with sightloss, and promoting good eye health (February 2018).

NICE quality standard - Serious eye disorders

NICE sought views on its topic overview on the eye disorders quality standard and this is our response (January 2018).

Department of Health – Promoting professionalism, reforming regulation

Our response to a consultation on what reforms are needed across the UK healthcare regulatory system in order to support workforce development while maximising public protection in a more efficient way (January 2018).



Northern Ireland Public Health Agency – Diabetic Eye Screening programme - December 2017

The Northern Ireland Diabetic Eye Screening Programme had undergone significant modernisation in the recent years and the Public health Agency is consulting on the latest phase of this modernisation. The most recent piece of work is examining the service delivery model and several options for change have been put forward for pre-consultation. Following this pre-consultation, the Public Health Agency will consider the feedback received with a view to proposing a final model which will be put forward for further consultation.


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NICE guideline – Care and support of older people with learning disabilities - December 2017

NICE seeks the views on its recommendations to help commissioners and providers identify, plan and provide for the health and social care needs of older people with learning disabilities. It covers integrated commissioning and planning; service delivery and organisation; providing accessible information, advice and support; care planning; and supporting access to health and care services. The College welcomes the inclusion of eye health as a consideration for health and social care professionals, family members and carers when providing care and support of older people with learning disabilities.


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“Better Health for All Londoners”, the Mayor Of London’s strategy to reduce health inequalities - November 2017

The College responded to the Mayor of London’s strategy to reduce health inequalities on 30 November 2017.

Echoing the See The Gap report, the response asserts that impaired vision can have negative implications for mental health, can hinder educational achievement and cause social isolation, all of which can serve to widen the health gap among deprived communities.  The response also stresses that ageing, smoking, genetic dispositions, and socio-economic status can all affect eye health.

The College recommends that effective vision screening for children should be an obligatory commissioning practice across all London Boroughs, and suggests a public awareness campaign to convince the public of the importance of visiting their optometrist regularly, regardless of symptoms.


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Department for Business, Energy and Industrial Strategy – Call for evidence: Laser pointers - October 2017

The Department for Business, Energy and Industrial Strategy seeks evidence on the market for laser pointers, and how they are used, to fully understand what impact any measures might have on businesses, enforcement bodies and the general public. The Government is concerned that, in recent years, there have been an increased number of reported incidents of the deliberate misuse of laser pointers with consequences which could have been fatal – examples include shining laser beams into the cockpits of aircraft and young children suffering permanent eye damage as the result of having beams from ‘toy’ pointers shone directly into their eyes. The Department for Business, Energy and Industrial Strategy is considering whether further measures, for example restrictions on advertising, greater awareness raising, and introducing controls relating to the supply, ownership and/or use of laser pointers would help tackle the problem.


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All-Party Parliamentary Group on Eye Health and Visual Impairment - Inquiry into capacity problems in NHS eye care services and avoidable sight loss in England - September 2017

The inquiry will look at how the commissioning and planning of eye health services, from the national to local level, can be improved to ensure that capacity will meet demand for eye health services to prevent avoidable sight loss. The APPG will consider the evidence to produce a report with a clear set of practical recommendations, and showcase best practice from eye health and other areas of healthcare for those with responsibility for eye health commissioning and planning both nationally and locally, on how to ensure there is strategic and joined-up service delivery, and that can deliver capacity to meet existing and projected future increases in demand to prevent avoidable sight loss at national and local level.


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Driver and Vehicle Licensing Agency - The Motor Vehicles (Driving Licences) Regulations 2013 (SI No 258) - September 2017

The Driver and Vehicle Licensing Agency (DVLA) seeks views on their review of the Motor Vehicles (Driving Licences) Regulations 2013 (SI No 258) in relation to eyesight and driving. These regulations amended the minimum vision standards for driving in the UK. The College of Optometrists recommended that:

  • All drivers aged 17-59 have a vision check every five years
  • All drivers aged 60 and over have a vision check every two years
  • All drivers aged 70 and over should have a mandatory sight test upon renewal of their driving licence


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General Optical Council - Fitness to practise complaints strategy: policy for consensual disposal of cases - September 2017

The GOC seeks views on a proposed change of policy to introduce a process for the consensual disposal of fitness to practise cases. Consensual disposal is a case management tool that will be used by the GOC to identify and process cases which may be suitable for concluding without a contested hearing. The GOC will not seek to dispose of a case by consent unless they are satisfied that to do so will not adversely affect public protection or be detrimental to the wider public interest.


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General Optical Council – Accreditation of Prior Learning policy - September 2017

This GOC seeks views on its draft Accreditation of Prior Learning (APL) policy. The purpose of this policy is to outline the circumstances in which GOC-approved education providers can implement APL arrangements on an individual basis or part of a general group arrangement. APL is a process that allows individuals to be recognised for the skills and knowledge they have gained through previous learning. APL arrangements are used by education providers to determine whether training and assessment can be waived for an individual on entry to a course and is generally considered on an individual basis



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This guideline covers diagnosing and managing age-related macular degeneration (AMD) in adults aged 18 and over. It aims to optimise service organisation and identification of risk factors, and improve diagnosis, management and review of this condition. It also aims to improve support and availability of information for people with AMD. The College’s response mainly highlights the important role optometrists play in the detection and management of AMD.


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London Assembly Health Committee eye health consultation - July 2017

The London Assembly Health Committee seeks views and information on eye health and preventing sight loss in London to examine how to reduce health inequalities among Londoners. Regular sight testing and early detection of eye conditions can prevent sight loss. There are significant health inequalities in relation to access to eye screening, eye health advice and treatment services in London. Take up of regular eye screening in London is low, particularly for some at-risk groups. The Mayor has a duty to produce a strategy to promote the reduction of these inequalities. Access to appropriate prevention, diagnostic and treatment support for eye health in London is currently variable both geographically and across socio-economic boundaries and demographic boundaries. Eye health and sight loss are also affected by a number of lifestyle factors. The Mayor’s election manifesto included specific pledges to support Londoners to adopt healthier lifestyles.


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NICE consultation on Glaucoma - July 2017

NICE seeks the views on its recommendations to address uncertainty and variation in clinical practice by giving clear recommendations on testing for chronic open angle glaucoma and ocular hypertension, and on effective diagnosis, treatment and reassessment to stop these conditions progressing. The College's response highlights five areas which we consider as having the potential to improve the quality of care:

  1. The tests required before referral should be commissioned as an extended community service
  2. The NICE recommendation to provide results of all examinations and tests with the referral should be also commissioned as an extended community service as this is outside the GOS contract.
  3. Repeats measures are not mandated within the GOS contract and would need to be commissioned as an extended community service.
  4. The diagnosis of chronic open angle glaucoma could be made by a suitably qualified health care professional with the relevant experience.
  5. The recommendations for a specialist qualification (according to case complexity) should be considered to apply equally to those healthcare professionals working within a consultant-led service and those working independently of consultant ophthalmologist supervision.


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NICE Quality Standard Topic Overview - Black, Asian and other minority ethnic groups: promoting health and preventing premature mortality - July 2017

NICE is consulting on the topic overview for the Black, Asian and other minority ethnic groups: promoting health and preventing premature mortality. This quality standard will be relevant in all age groups and all settings. The College highlighted the evidence of the higher prevalence of eye disease in the non-white population of the UK, and the important role optometrists have in raising awareness of eye health and encouraging uptake in minority populations.


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NICE cataracts in adults guidance consultation - June 2017

NICE seeks the views on its recommendations to improve care before, during and after cataract surgery by optimising service organisation, referral and surgical management, and reducing complications. The College's response highlights four areas which we consider as having the potential to improve the quality of care:

  1. To commission the pre-referral decision for cataract surgery as an extended community service
  2. To commission the postoperative assessment – which is also outside the GOS contract – as an extended community service
  3. To include positive visual and refractive outcomes after a cataract surgery into the guidelines
  4. To identify who is accountable for patients if they have been discharged for follow-up cataract surgery in the community

Download our response


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General Optical Council - Equality, diversity and inclusion scheme - April 2017

The General Optical Council (GOC) has launched a consultation seeking feedback on its proposed Equality, Diversity and Inclusion (EDI) Scheme, which is designed to ensure these principles are embedded throughout its work. The scheme includes proposals to ensure fair access to GOC services; to ensure that all staff, registrants, Council and committee members are adequately trained and informed of their duties in respect of equality, diversity and inclusion; and to gather more data to better understand the makeup of the optical professions.


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Optical Confederation consultation on refractive surgery - April 2017

The Optical Confederation has launched a consultation on new standards to promote best practice in the refractive surgery sector. The standards follow the adoption of the General Medical Council’s Guidance for doctors who offer cosmetic interventions, and give a framework for how this can be implemented in the refractive surgery sector.


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Welsh Government - Together for a dementia friendly Wales 2017-22 - April 2017

The Welsh Government seeks views on developing and implementing a national dementia strategy for 2017 – 2022. The consultation focuses on the key themes and actions to be included in the strategy, the services available for people living with dementia, and the evidence of existing good practice.


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GOC's education review: Call for evidence - March 2017

This consultation sought the views of a wide range of stakeholders on the plans for an education strategic review to ensure that education programmes and qualifications leading to GOC registration equip students to meet patients' future needs. The consultation was set in the context of rapid technological change and the increased prevalence of enhanced services, which are altering the roles that optometrist and dispensing opticians play in delivering eye care. 

Download our response: 


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GOC Strategic Plan 2017-2020 - January 2017

This consultation sought the view of a wide range of stakeholders about the GOC’s draft strategic plan which aimed to ensure opticians were equipped for the roles of the future, that its regulation was targeted at the risks to the public’s health and safety and that it developed into an organisation that the public, registrants and all its stakeholders found accessible in engagement and increasingly easy to work with.

Download our response:


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