Accept our vote of no confidence in the GOC's ability to protect the public.

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The General Optical Council's overarching objective is to protect the public. Under the direction of the chair incumbent, the GOC has failed to protect the public, listen to stakeholders and will fail to maintain standards for education if left to their own devices. They have feigned responsibility for their failures and have a history of ignoring the advice of others. We also ask for a suspension to the routine examination of asymptomatic patients and that the Professional Standards Authority investigate our allegations as set out below and if found proved, present a
case to the Privy Council on behalf of the signatories.

Our claims are as follows:

1.1. Guidance delivered by the GOC has brought the profession into disrepute, caused patients to be denied care and resulted in a loss of faith in the GOC's ability to make decisions that support the eyecare needs of the public. In one incident the clear guidance given was to suspend ROUTINE eyecare. Registrants trusted their regulator and stopped providing routine services in a significant number of practices. The GOC was criticised for denying optometric care to a proportion of NHS patients, whilst at the same time suggesting private patients could continue to receive care. This clearly is not protecting the public.
This advice was later described by their own chief executive as having caused “confusion and concerns” amongst registrants.
The backlash caused the AIO to reach out to the GOC to ask for a revised statement. The GOC felt they should clarify their previous guidance. Many registrants however felt the original statement was perfectly clear when it was first delivered and that the GOC was instead backtracking on their error. The resulting suspension had a significant financial impact on those that followed the original advice and led to a denial of service to those who were entitled to an NHS examination. As a result, the GOC HAS brought the profession into disrepute and become its own risk to the public.

See: https://www.aop.org.uk/ot/professional-support/optical-organisations/2020/06/17/goc-seeks-to-clarify-statement-on-reopening-practices-following-criticism

1.2. In the original GOC/COVID/02 Statement, the GOC issued guidance relating to the supply of contact lenses. In this statement the GOC gave practitioners the autonomy to decide whether to issue contact lenses on expired specifications. Additional guidance also given removed the barrier of verifying the specification. This is contrary to the Opticians Act and was not approved by a quorum of two from the Privy Council. On this change the GOC suggested powers had been granted by a joint regulatory statement. As far as we are aware, the Opticians Act does not recognise joint regulatory statements as a means to modify the Act. Questionable responses followed from many professional bodies including but not limited to the British Contact Lens Association (BCLA) and the Association of British Dispensing Opticians (ABDO). This resulted in the unlawful sale of contact lenses by registrants who acted in good faith that the GOC’s word was law. This was and is a public health risk and now places the GOC in a position in which resulting concerns cannot be investigated without hypocrisy.

1.3. The GOC is quick to delegate responsibility to a number of bodies who are issuing conflicting
advice, including the College of Optometrists, the Association of Optometrists, NHS England and
the Optometric Fees Negotiation Committee (OFNC). This has resulted in:
(a) mass confusion over how much contact time a practitioner should have with a patient, with the
AOP suggesting at least an hour and the College of Optometrists suggesting as little time as
possible;
(b) unenforceable guidance that puts the onus on businesses to train optometrists on infection
control (which they are not qualified to do) and to supply their clinicians with PPE. Unfortunately
businesses are not required to register with the GOC. This, and in combination with the lack of
supplies, meant that the workforce was underprepared and undertrained.
(c) the GOC advising practitioners to follow the College of Optometrists 'Red-Amber-Green traffic
light system'. There was a consultation which ended 7th January which asked whether the GOC
should adopt this system? Despite it still being open for consultation, the GOC had already adopted this system and told its registrants to follow the College of Optometrists guidance. Unfortunately for many, the College of Optometrists had amended the system so that the current situation does not fall within the 'Red Phase'. This has caused many registrants to take to social media to express their concern. One registrant started a poll which asked whether the GOC was exercising its function in supporting the College's Amber guidance? Nearly 200 voted and, as it stands, 98% believe the GOC is not exercising its function of public protection. It is our
understanding that the GOC is awaiting guidance from NHS England, however their duty is not to
NHS England but to the public. This public poll supports that they are failing in this respect.

1.4. The GOC claim to have only engaged with a small number of stakeholders as they needed to
respond quickly. Despite this, the GOC’s Director of Strategy met with a team of Vision Express Executives twice and on one occasion was accompanied by the GOC’s Chief Executive. The goal of these meetings was to discuss a statement about sale and supply of contact lenses and what Vision Express would want. The Director of Strategy then met with the council member who had been delegated the responsibility for this guidance to discuss it. As mentioned earlier (1.2), this is not in the public's interest and the guidance was financially beneficial for Vision Express. Similar discussions were not had with the BCLA, who would have been the obvious choice if clinical opinion was required. In conversation with the BCLA, they said that as a result of the original guidance, they were working with the GOC to amend it.

2.1. At the start of the pandemic the College of Optometrists called for a halt to the Education Strategic Review. This advice was appropriate given the need for organisations to rethink how best to allocate resources to respond to the pandemic. As the regulator for optical professionals,
it is reasonable to expect that safety takes priority over a mass overhaul of education. We recognise the strain the pandemic has put on many organisations as they focused on how to best respond to this emergency, however, the GOC’s decision to not heed the advice of the College of
Optometrists placed unnecessary strain on stakeholders. The decision to press on regardless was widely criticized and caused a knock on effect as educational establishments had to deal with their own response to COVID and the change to remote teaching AND consider the appropriate response to the extensive rework of education. We are grateful for how they reacted at this time and performed their duties as educators in supporting their students, and are disheartened the Education Team was not reassigned to support them. The GOC’s response was inconsiderate and a poor use of resources that would have been better utilised helping academia formulate changes to examinations that would satisfy the requirements for entry on to the register.

2.2. The GOC is acting outside its remit to secure funding for Educational Establishments as part
of the Education Strategic Review. This has been acknowledged by the GOC within their own meeting notes. This is cause for public concern as it creates a conflict of interest between the GOC and those who benefit from the additional funding. This is not the first time the GOC has knowingly
acted outside their remit. A few years ago the GOC were criticised by the PSA for their 'Love your lenses' campaign and a concern was raised by the PSA surrounding a perceived conflict of interest. Regardless of whether it is beneficial to the public, this campaign is still running against
the advice of the PSA. This is not naïveté, this is contempt.

2.3. The Education Strategic Review was widely criticized by practitioners, professional bodies and educational establishments alike in the penultimate consultation. Despite this the GOC have pressed on to the dismay of stakeholders.

Conclusion

Despite these concerns being brought to the GOC by its registrants, by the public and through several petitions, the GOC has been defiant and has taken no responsibility for their performance. We ask the Professional Standards Authority to consider the facts laid out, to read the messages left by registrants below and on twitter and to recognise that in the opinion of the professionals and the public, the GOC has failed and needs to be held to account.

We ask for:

• a council that listens to key stakeholders;
• a council that puts a weighting on the views of academia when planning education;
• a council that does not work outside of its own remit to deliver their aims;
• a council that consults with clinical leads from professional bodies, not corporate bodies, on how to handle clinical matters; and
• a council that will preemptively take action to protect the public rather than to wait and react to the often inadequate guidance of others.

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We believe action needs to be taken now to address the concerns of the signatories below and ask the Professional Standards Authority to conduct a full investigation into the General Optical Council's performance.

We also ask that if the General Optical Council feels comfortable acting outside their remit to secure funding for an unwanted Education Strategic Review, then why should they not act outside their remit to demand additional funding as they suspend routine examinations in areas that are in lockdown.