FtP Regulations: Who decides what and when?

Careful analysis of the annual reports published by the General Optical Council (GOC) show that its total number of registrants has risen from 26,811 (in 2013-2014) to 33,705 (in 2023-2024), representing a 20% increase.^1-10  

A breakdown of the numbers for each registrant category is presented in figure 1. Although the data reveal a sizeable decrease in the number of student dispensing opticians over the last decade, figure 2 illustrates that the number of student optometrists has substantially expanded within the same period, from 2,736 to 5,307.^1-10  

Correspondingly, the proportion of optometrists has also increased, by around 5.4 times more than the proportion of dispensing opticians over the same period.^1-10 

Given the rate of expansion of the optometric workforce, it is imperative that practitioners fully understand the purpose of regulation and develop an awareness of the different decision makers that may become involved in considering complaints made to the GOC. 

This article shall outline what regulation is, the key functions of the GOC, the main pathways through which complaints against individual registrants are processed, and the roles of the three sets of independent decision makers who consider serious concerns, the case examiners (CEs), investigation committee (IC) and fitness to practise committee (FtPC). 

Figure 2: A graph of the percentage change in the number of registrants for each GOC registrant category between the periods of 2013-2014 and 2023-2024. Negative values represent a reduction, whereas positive values represent an increase

What does regulation offer? 

The fundamental purpose of the regulation of healthcare professions is to protect members of the public from the risk of harm whenever they engage with healthcare services. Statutory regulation specifically refers to healthcare professionals that are legally required to be registered with a professional regulator under the authority of a piece of legislation, such as the Opticians Act (1989).¹¹ 

 The job titles used by these professionals are also ‘legally protected’. Hence, it is a crime for an individual to misrepresent themselves as, or claim to be, a statutory regulated professional without the necessary registration with the relevant regulator.  

Consequently, employers are duty-bound to verify that individuals intending to work in regulated healthcare roles are fully registered with the appropriate regulator. 

Given the above, it follows that the public are aware that healthcare professionals who are registered with a statutory regulator are trustworthy individuals, who conduct themselves appropriately, and possess the necessary knowledge, skills and experience to practise effectively. 

Statutory regulation undoubtedly provides an effective and appropriate means of protecting the public from the risk of harm; consequently, other healthcare acts are used across a range of professions including medicine,¹² dentistry¹³ and pharmacy.¹⁴  

The regulation of these and other healthcare professions is critical, as many patients who regularly engage with and depend upon these healthcare services are potentially vulnerable due to a variety of reasons. 

Who oversees the GOC? 

The Professional Standards Authority (PSA) oversees the GOC as well as other healthcare regulators, including the General Medical Council, General Dental Council and General Pharmaceutical Council.¹⁵ 

The PSA’s core principles inform their Standards of Good Regulation,¹⁶ which include that regulators must act in a way that is: 

• Consistent: all the standards and rules must align and be applied fairly and consistently to each case
• Accountable: regulators must be able to justify their decision-making and always remain open to public scrutiny
• Proportionate: regulators should only intervene when necessary and their actions must be appropriate to the identified risk(s)
• Targeted: regulation must be focused on the problem and should minimise side effects
• Transparent: regulators must be open, make decisions based on impartial evidence and keep regulations simple. 

The PSA discharges its duty by evaluating the performance of healthcare regulators against its own Standards of Good Regulation and submitting an annual report to Parliament.  

The PSA’s independent annual performance review assesses how well a healthcare regulator has been protecting the public and promoting confidence in the profession. In total, there are 18 PSA Standards which are separated into five key categories:¹⁶  

1. General standards,  
2. Guidance and standards, 
3. Education and training, 
4. Registration, and 
5. Fitness to practise. 

What does the GOC do? 

The GOC’s governing legislation is the Opticians Act (1989), referred to hereafter as ‘the Act’.¹¹ The GOC’s main function is to promote high standards of professional education, conduct and performance among its registrants.¹⁷ Moreover, the GOC’s overarching objective in exercising its various functions is to protect the public.¹⁷ 

The GOC carries out several core functions, which include:  

• Setting the standards of performance and conduct expected from its registrants via its Standards of Practice (SoP)¹⁸
• Maintaining current, publicly accessible registers of its various registrants (see next section)
• Accrediting new educational courses for the optical  professions
• Approving qualifications that lead to registration
• Ensuring its professional registrants are keeping up to date, by undertaking and appropriately recording the prescribed amount of continuing professional development
• Investigating and taking any necessary action wherever a registrant’s fitness to practise, train or carry out business may be impaired.

Figure 3 presents the number of decisions from substantive fitness to practise (FtP) hearings, the number of new investigations opened and the number of complaints received by the GOC between 2013-2014 and 2023-2024. 

Table 1 summarises the GOC’s performance, as evaluated by the PSA, over the past five years.  

The GOC’s registers 

A statutory regulator’s register is more than just a list. Registers confirm that the professionals named on it have received the appropriate training and are suitably qualified to meet the regulator’s standards. Members of the public can therefore search for and view the details of any registrant prior to engaging with their services.  

The GOC keeps registers for the following categories of registrant:  

• Optometrists (including additional supply, independent prescribing and supplementary prescribing practitioners) 
• Dispensing opticians (including contact lens practitioners)
• Student optometrists
• Student dispensing opticians
• Bodies corporate (or ‘business registrants’) who conduct their business in optometry or dispensing optics. 

The GOC’s Standards of Practice (SoP) 

Eye care professionals are responsible for ensuring that they prioritise the health, safety and wellbeing of the public, and for upholding proper professional standards.¹⁸ Each practitioner is professionally accountable and personally responsible for their practice and for what they do, or do not do, no matter what direction/guidance they may have been given by their employer/colleague(s).¹⁸  

The public expects all healthcare professionals to always be able to justify their decision-making and actions, clinical or otherwise. The GOC’s SoP are an ethical framework, which guide and support practitioners to deliver safe patient care, to a good standard, by outlining key professional obligations.  

The GOC’s SoP are set to protect patients by reducing the risk of harm and to promote proper standards and conduct among the optical professions.¹⁸ This, in turn, reassures patients that their care and safety will always be each practitioner’s primary concern. 

Readers should also carefully note that the GOC’s SoP include standards relating to both their professional performance and personal conduct, for example, Standards 17.1 to 17.3.¹⁸ 

Patient-practitioner trust is a fundamental tenet in healthcare,  and this is properly reflected in Standard 16 of the SoP, which states:

‘16. Be honest and trustworthy

16.1 Act with honesty and integrity to maintain public trust and confidence in your profession.’    

Often, such patients may even be considered as vulnerable by reason of their health condition(s). These patients would not ordinarily reveal such sensitive information to a stranger; however, they view their optometrist as a trusted member of a regulated healthcare profession, who holds a unique collection of clinical skills and ethical values.  

Patients therefore expect their optometrist to be committed to continually applying these skills and values for the benefit of the public, as they are governed by a statutory body that accredits and regulates the practitioner’s activities.  

Hence, as the statutory body, the GOC establishes public trust in the wider profession by reassuring patients and the public, through its SoP, that optometrists are clinically competent and trustworthy.¹⁸ 

Given the above, whenever a complaint is made about a registrant’s FtP, the GOC will refer to their SoP to determine whether they need to take any necessary action to protect the public. Registrants must therefore be prepared to demonstrate that their decision-making was properly informed by the SoP, and that they have acted in the best interests of their patients.¹⁸ 

What route might a complaint made against a registrant take? 

Statutory grounds for impaired fitness to practise 

Section 13D (2)²² of the Act outlines the statutory grounds upon which the FtP of an individual optometrist or dispensing optician can be found to be impaired. In summary, these are: 

•  Misconduct (eg not referring a patient for further investigation and/or treatment)
• Deficient professional performance (excludes student registrants)
• A conviction or caution for a criminal offence
• Having accepted a conditional offer (by the procurator fiscal, in Scotland) or agreed to pay a financial penalty as an alternative to prosecution (in the UK)
• Adverse physical and/or mental health 
• A finding of impaired FtP by another regulatory body. 

The registrar, triage and investigation teams 

All complaints/allegations made against a registrant’s FtP are initially considered by the GOC’s registrar²³ and triage team. The registrar will only progress complaints that raise potentially serious concerns. 

 Equally, the registrar and triage team will identify complaints that do not require any regulatory intervention and bring them to a close. 

Wherever a serious concern has been identified, the registrar must direct that the case be investigated further by the GOC’s investigation team, which is led by an investigation officer. The investigation officer will not make any findings of fact. Rather, they ensure that all the necessary and relevant information has been obtained to assist the registrar and, should the matter be referred any further, the CEs, IC and FtPC.²³ Figure 4 highlights the different steps that the investigation team may take. 

Whenever a registrant receives a criminal conviction resulting in the imposition of a custodial sentence (whether immediate or suspended), the registrar must directly refer their case to the FtPC under Rule 4 (5) of the FtP Rules.²³ 

Requests and disclosures 

Registrants need to be aware that, upon opening an official investigation, the GOC will request the details of their current employer and notify them (under Sections 13B (2)²⁴ and 13C (2)²⁵ of the Act). Equally, the GOC will notify the Department of Health whenever any registrant is under investigation (under Section 13C (1 and 2)²⁵ of the Act).  

Section 13B²⁴ of the Act also gives the GOC the power to demand information and/or evidence from people or organisations, overriding the Data Protection Act (2018),²⁶ in order to assist them when requesting information about complaints/allegations made against a registrant.  

Finally, Section 13C (3)²⁵ of the Act gives the GOC the power to disclose information about a registrant’s FtP to anyone, if they consider that it is in the public interest to do so. 

The case examiners (CEs) 

If, after triage and investigation, the GOC’s registrar considers that the complaint/allegation is potentially serious and falls into one or more of the statutory grounds for impaired FtP, then they must refer the case to the independent CEs.²³  

Rule 2 (1)²³ of the GOC’s FtP rules cites that a CE is appointed as an ‘officer of the council’, by the registrar on behalf of the GOC, for the purpose of exercising the functions of the IC.  

The CE ‘team’ comprises one registered optometrist/dispensing optician (as appropriate) and one lay person. The CEs must review the case in private, ie nether the complainant nor the registrant can attend.  

The left-hand side of the diagram presented at figure 5 summarises the powers of the CEs (under Section 13E (1)(b)²⁷ of the Act). 

When deciding if a case should be referred to the independent FtPC, the CEs must consider the GOC’s overarching objective (defined in Section 1¹⁷ of the Act): 

(a) to protect, promote and maintain the health, afety and wellbeing of the public,  

(b) to promote and maintain public confidence in the professions regulated under this Act,  

(c) to promote and maintain proper professional standards and conduct for members of those professions, and  

(d) to promote and maintain proper standards and conduct for business registrants.’  

Readers should note that ‘limbs’ (b) to (d), above, are commonly referred to as ‘the public interest’. 

In making their decision, the CEs must carefully determine whether there is a realistic prospect of establishing that the registrant’s FtP is impaired. This step is better known as the ‘realistic prospect’ test (RPT)28 and involves careful consideration of two critical limbs: 

1. If the allegation was referred to the FtPC, is there a realistic prospect of finding the facts alleged against the registrant proved?  
2. If the facts were found proved, are they significant enough to indicate that the registrant’s FtP is, or may be, impaired to such a degree that justifies action being taken against their registration?

While applying the RPT, the CEs must be mindful of a number of factors,²⁸ including: 

1. i Proceeding with caution, as they are only able to work from documents alone, and a proportion of the evidence that they review will be ‘untested’ at this stage (eg key witnesses have not been cross-examined) 
2. That the presence of an interim order²⁹ should not be a factor in considering whether to refer the complaint/allegation to the FtPC, as an interim order does not constitute a factual finding made against the registrant
3. That they cannot make any findings of fact (this is the role of the FtPC (should the matter reach that stage))
4. That they cannot determine if a registrant’s FtP is impaired (this is the role of the FtPC (should the matter reach that stage))
5. That the FtPC will apply the ‘civil standard’ of proof, ie on the balance of probabilities,³⁰ when making its decisions after hearing all the evidence. 

If the CEs jointly determine that both limbs of the RPT have been met, then they must act in the public interest and refer the case to the independent FtPC for a public substantive hearing.²³  

The investigation committee (IC) 

The IC is composed of a mix of independent lay and registrant members. It has nine members in total: three optometrists, two dispensing opticians and four lay members.³¹ The IC must review each case in private, neither the registrant nor the complainant are permitted to attend. The right-hand side of diagram presented at figure 5 summarises the powers of the IC (under Section 13D²² of the Act). 

The arrows presented within figure 5 denote two pathways by which the CEs can refer a case to the IC,²⁸ these are:

1. Both CEs agree that it is necessary for the registrant to undertake a ‘health assessment’ and/or ‘performance assessment’; hence, they must refer the case to the IC, and
2. The CEs are unable to agree on what action should be taken; hence, they must refer the case (via the registrar) to the IC for a final decision. 

Regarding pathway a), a health assessment is appropriate if the complaint and/or a registrant’s representations raise concerns around whether the registrant’s health, which includes any condition(s) relating to substance abuse, is impacting upon their FtP.²⁸  

A performance assessment is appropriate if the complaint raises broader concerns about the adequacy of the registrant’s standard of work in certain areas of their practice, and that the decision makers would be assisted by an independent assessment of these areas.²⁸ 

The IC holds responsibility for specifying all of the areas in which the registrant must be assessed.³¹ The registrant will be sent a copy of the received assessment report(s) and will be given reasonable time to submit any comments on the report(s) to the registrar.³¹ 

Wherever the registrant cooperates with the assessment(s) requested by the CEs, the IC must refer the case back to the CEs, with the assessment report(s) and any comments provided by the registrant. The CEs shall then resume their decision-making.^{28, 31} 

Conversely, if the registrant does not cooperate with, or fails to submit themselves for any of the requested assessment(s), then the IC must consider the allegation for itself, drawing any inferences as it deems fit.³¹

Like the CEs, the IC must also consider the GOC’s overarching objective¹⁷ when deciding whether a case should be referred to the independent FtPC. Equally, the IC must also be mindful of various factors, including points i) to iv) referred to above, while applying the RPT during its decision-making.³¹ 

Finally, if the IC concludes that both limbs of the RPT have been met, then it must act in the public interest and refer the case to the independent FtPC for a public substantive hearing. 

Adjournments for further investigations 

Figure 5 highlights that, as part of their considerations, both the CEs²⁸ and IC³¹ can direct an ‘adjournment’ to obtain further evidence/information to assist in their decision-making. 

In either case, the registrar must undertake these investigations and provide any additional evidence obtained to the registrant and, where appropriate, to the complainant, giving them reasonable time to respond.^{28, 31}  

The registrar will then provide the CEs/IC with all of the additional evidence, together with any further comments.^{28, 31} The CEs/IC shall then resume their consideration of the matter. 

What happens during a Substantive FtP Hearing? 

Registrants are entitled to attend their substantive hearing and be represented by a barrister. Registrants need to be aware that, if they choose to not attend, their substantive hearing can take place in their absence.²³

At a substantive hearing, the independent FtPC comprises two registrant members (either two optometrists or two dispensing opticians) and three lay members, one of whom will chair the committee. In accordance with the FtP Rules,²³ the FtPC will make a number of key decisions, in private, across four discrete stages, these are: 

In these circumstances, the warning will advise the registrant about their future conduct and/or performance with respect to the facts found proved. The warning allows the FtPC to highlight to the registrant and the wider profession that certain behaviours, conduct or practice represents a departure from the SoP and is unacceptable.

Stage 4: If the registrant’s FtP is found to be currently impaired … which sanction (if any) should be imposed to protect patients, maintain public confidence in the optical professions and uphold proper professional standards and conduct.¹⁷  

Figure 6 outlines the powers, in relation to imposing a proportionate sanction, that the FtPC has under the Act.^{33, 34}  

In exceptional circumstances the FtPC might be justified in taking no further action.³² A finding of impairment with no further action is a legitimate way to ‘mark the seriousness’ of the registrant’s actions in the public interest, where imposing a restrictive sanction is unjustifiable.³² 

What is misconduct? 

There is no agreed definition for misconduct, however several authorities have provided practical guidance for decision makers.^35-37 In the case of Roylance,³⁵ Lord Clyde stated: 

‘Misconduct is a word of general effect, involving some act or omission which falls short of what would be proper in the circumstances …’ 

In the case of Remedy UK Limited,³⁶ Lord Justice Elias stated:  

exercise of professional practice such that it can properly  

be described as misconduct going to fitness to practise. 

otherwise disgraceful kind which may, and often will, occur  

[outside of] the course of professional practice itself, but  

which brings disgrace upon the [practitioner] and thereby  

prejudices the reputation of [their] profession.’ 

In the case of Calhaem,³⁷ Mr Justice Jackson stated: 

‘A single negligent act or omission is less likely to cross the threshold of “misconduct” than multiple acts or omissions. Nevertheless, and depending upon the circumstances, a single negligent act or omission, if particularly grave, could be characterised as “misconduct”.’ 

‘Fit’ to practise? 

A registrant is deemed to be ‘fit’ to practise if they have the relevant skills, knowledge, health, behaviours and character to perform their work and practise safely. 

In determining whether a registrant’s FtP is currently impaired, the FtPC will consider the GOC’s overarching objective,¹⁷ and the tests set out in paragraph 65 of the case of Cohen³⁸ (see figure 7) and paragraphs 74 and 76 of the case of Grant³⁹ (see figure 8).  

The FtPC will also evaluate the seriousness of the concern(s), which relates to how far the practitioner’s actions have departed from the SoP and/or the impact of a health condition on the registrant’s ability to practise safely. 

Figure 7: A summary of the key points from the case of Cohen.³⁸

The FtPC is required to look forward, not backward, as a concern identified in the past does not necessarily mean that there is current impairment.^{38, 40}  

In looking forward, the FtPC must take account of the registrant’s insight into the source of their misconduct, deficient professional performance, adverse health, conviction/caution, or determination by another body, and any remedial steps taken to reduce the risk of repeating their actions. 

Figure 8: A summary of the key points from the case of Grant.³⁹

What is the purpose of a sanction?  

Although it may have a punitive effect, the purpose of any sanction imposed following a substantive FtP hearing is not to punish the practitioner for their past misdeeds, but to protect patients, maintain public confidence in the optical professions and to uphold proper professional standards and conduct.¹⁷  

Figure 9 presents a detailed breakdown of the range of final outcomes from substantive hearings held between 2014-15 and 2023-24.^1-10 

Summary 

This article highlights the importance of statutory regulation in healthcare, including discussion around the role of the PSA. Descriptions of the various functions of the GOC were provided to help readers appreciate how the optical professions are regulated. This included outlining the GOC’s different registers and discussing the functions of the GOC’s SoP. 

This work provided explanations of the main pathways through which complaints against individual registrants are processed by the GOC. This included providing details about the roles of the GOC’s registrar, triage and investigation teams. The powers of the CEs, IC and FtPC were also explored. 

This piece outlined the statutory grounds on which an individual registrant’s FtP may be considered to be impaired. Explanations of the terms misconduct and current impairment were also provided, along with insight into how these are applied during the different stages of a substantive FtP hearing. The purpose of imposing a sanction was also considered. 

It is envisaged that this article will aid practitioners who want to learn more about how the GOC triages and investigates serious concerns, and the roles of the key decision makers, namely the registrar, CEs, IC and FtPC. 

Declaration Statement 

Dr Amit N Jinabhai is a current member of the GOC’s independent FtP hearings panel. This work represents the author’s knowledge and has been written and presented in a personal capacity only and does not reflect the views or opinions of the GOC.  

• Dr Amit N Jinabhai is an optometrist with a proven track record of excellence in optometric education and research. He has significant experience in regulatory decision-making and clinical auditing. He currently works as a locum and freelance consultant. 

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