Policy submissions

Our health policy experts work and speak up for you, so you and your patients can look forward to a positive future. Each year we analyse legislation, regulations, contracts and complex government and NHS policy on your behalf and respond to consultations. See our responses below.

Our member newsletter includes a list of live consultations we are analysing. You can contact the policy team if you want to participate or learn more on any consultation by emailing [email protected].

See our policy submissions below.

Consultation responses 2026

GOC discussion paper on registration fees, 17 July Open in new tab Download
DHSC consultation - Reforming the General Medical Council legislative framework, 22 June Open in new tab Download
OFNC Submission - Health Bill call for evidence, 12 June Open in new tab Download
Introducing Mandatory Eyesight Testing For Older Drivers, 11 May Open in new tab Download
General Optical Council (CPD) Consultation Paper – reforms to CPD, 16 April Open in new tab Download
NHS England Accessible Information Standard - OFNC response, 27 February Open in new tab Download
APPG for Health call for evidence, 27 February Open in new tab Download

Consultation responses 2025

NHS Payment Scheme, 16 December 2025 Open in new tab Download
NHS Standard Contract 2026-27, 16 December 2025 Open in new tab Download
NHS Productivity Commission call for evidence, 9 December Open in new tab Download
GOC - Indicative Sanctions Guidance, 13 November Open in new tab Download
10 Year Workforce Plan call for evidence, 7 November Open in new tab Download
DHSC Consultation - Extend medicines for optometrists and contact lens opticians, 13 October Open in new tab Download
GOC - Maintaining appropriate sexual boundaries and care of patients in vulnerable circumstances, 3 October Open in new tab Download
Sustainable CDCs Voluntary and Professional Membership Organisation, 4 September Open in new tab Download
Proposed amendment to the 2025/26 NHS Payment Scheme, 5 August 2025 Open in new tab Download
NHS Standard Contract 2025 - A further consultation, 28 April 2025 Download
PSAs Standards of Good Regulation and Standards for Accredited Registers, 18 April Open in new tab Download
NHS Payment Scheme consultation 2025-26, 27 February 2025 Open in new tab Download
NHS Standard Contract 2025-26, 25 February 2025 Open in new tab Download
GOC Business Regulations consultation, 22 January 2025 Open in new tab Download

Consultation responses 2024

NHS 10 Year Plan, FODO response, 2 December 2024 Open in new tab Download
Autumn Budget 2024/Spending Review submission, 10 September 2024 Open in new tab Download
GOC Strategy 2025-30, 10 July 2024 Open in new tab Download
GOC - revised standards of practice, 8 May 2024 Open in new tab Download
NHS standard consultation 2024/2025, FODO and NCHA joint response, 29 January 2024 Open in new tab Download

Consultation responses 2023

GOC - removing reference to a registrant's gender on the public register, 22 December 2023 Open in new tab Download
GOC - searching the GOC register, 22 December 2023 Open in new tab Download
Improving Integrated Commissioning in Health & Social Care, 31 October 2023 Open in new tab Download
GOC - Statement on verification of contact lens specifications and definition of aftercare, 24 October 2023 Open in new tab Download
DVLA driver licensing call for evidence, 20 October 2023 Open in new tab Download
Disclosure of industry payments to the healthcare sector, 16 October 2023 Open in new tab Download
In School Eye Testing for Pupils in Special Schools in England, 16 October 2023 Open in new tab Download
GOC Managing applications for GOC registration from optical professionals who have qualified outside the UK or Switzerland, 4 October 2023 Open in new tab Download
College of Optometrists: Guidance for Professional Practice public consultation, 4 October 2023 Open in new tab Download
DHSC consultation: Amendments to regulations 3A, 19 and 247A of the Human Medicines Regulations 2012 to support the ongoing delivery of COVID-19 and influenza vaccination, 27 September 2023 Open in new tab Download
Home Office mandatory reporting of child abuse, 14 August 2023 Open in new tab Download
Level 6 Ophthalmic Dispensing Apprenticeship Standard, 29 June 2023 Open in new tab Download
PSA annual review of GOC's performance 2022-2023, 26 June 2023 Open in new tab Download
FODO response to the Welsh Government consultation: Proposals to reform the ophthalmic services delivered in primary care in Wales, 19 June 2023 Open in new tab Download
GOC updating gender on the register, 17 March 2023 Open in new tab Download
PSA draft strategic plan 2023-2026 FODO and NCHA response, 24 February 2023 Open in new tab Download
Hewitt review call for evidence, 9 January 2023 Open in new tab Download

Consultation responses 2022

NHS Provider Licence, 9 December 2022 Open in new tab Download
MHRA fee increase consultation, 23 November 2022 Open in new tab Download
PSA - regulators performance in Equality, Diversity and Inclusion, 9 October 2022 Open in new tab Download
PSA annual review of GOC's performance - 2021-2022, 18 October 2022 Open in new tab Download
Primary Care response to Health Select Committee on ICSs, 5 August 2022 Open in new tab Download
GOC call for evidence on the Opticians Act and consultation on associated GOC policies, 18 July 2022 Open in new tab Download
MHRA new code of practice for Expert Advisory Committees, 24 May 2022 Open in new tab Download
Healthcare Regulation - deciding when statutory regulation is appropriate, 31 March 2022 Open in new tab Download
Provider Selection Regime: consultation on the detail of proposals for regulations. 28 March 2022 Open in new tab Download
Evidence Based Interventions List 3 consultation, 25 March 2022 Open in new tab Download
Consultation on proposed changes to the Guidance for Professional Practice, 21 March 2022 Open in new tab Download
NHS National Tariff 2022-23, 28 January 2022 Open in new tab Download
GOC Illegal Practice Strategy Review, 24 January 2022 Open in new tab Download

Consultation Responses 2021

Review of temporary provisions in the Human Medicines Regulations 2012 to support influenza and COVID-19 vaccination campaigns, 23 December 2021 Open in new tab Download
PSA consultation on its approach to reviewing the regulators - follow up, 21 December 2021 Open in new tab Download
GOC consultation - new requirement for contact lens opticians,13 December 2021 Open in new tab Download
DVLA consultation to change procedures for registered healthcare professionals, 6 December 2021 Open in new tab Download
MHRA consultation on the future regulation of medical devices in the United Kingdom - FODO, ABDO, AOP response, 25 November 2021 Open in new tab Download
FODO letter to the Institute for Apprenticeships and Technical Education and Trailblazer Group, 24 November 2021 Open in new tab Download
Extending free PPE to the health and care sector response, 31 October 2021 Open in new tab Download
GOC special entry to GOC register in AS, SP and IP categories, 6 October 2021 Open in new tab Download
PSA annual review of GOC's performance - 2020-21, 1 October 2021 Open in new tab Download
GOC Service of statutory notices by email policy, 23 Sept 2021 Open in new tab Download
GOC Remote Hearings Protocol, 23 Sept 2021 Open in new tab Download
GOC Hearings and indicative sanctions guidance 2021, 23 Sept 2021 Open in new tab Download
Review of Professional Regulators – stakeholders survey, 17 Sept 2021 Open in new tab Download
NI Department of Health consultation on duty of candour and being open – Response of FODO members in Northern Ireland, 31 August 2021 Open in new tab Download
GOC consultation on CET exceptions policy, 8 July 2021 Open in new tab Download
Regulating healthcare professionals, protecting the public, 16 June 2021 Open in new tab Download
Making vaccination a condition of deployment in older adult care homes, 21 May 2021 Open in new tab Download
System Oversight Framework 2021-2022 consultation. 14 May 2021 Open in new tab Download
NHS Provider selection regime consultation, 7 April 2021 Open in new tab Download
Value shifting consultation, 30 March 2021 Open in new tab Download
Health & Social Care committee enquiry - Department's White Paper on health social care, 23 March Open in new tab Download
AMD Commissioning Guidance Consultation, 18 March 2021 Open in new tab Download
GOC consultation on Speaking up guidance, 9 March 2021 Open in new tab Download
England Vision Strategy review, 18 Feb 2021 Open in new tab Download
Draft NHS Standard Contract 2021-22, 4 Feb 2021 Open in new tab Download
GOC consultation on CET Rules, 1 Feb 2021 Open in new tab Download
Building a strong integrated care system, 8 Jan 2021 Open in new tab Download
GOC consultation on COVID-19 statements, 7 Jan 2021 Open in new tab Download

Consultation Responses 2020

PSA review - Learning from Covid, 21 Dec 2020 Open in new tab Download
Temporary Amendments to HSC Framework Document, 4 Dec 2020 Download
Tariff Engagement Consultation, 4 Nov 2020 Open in new tab Download
HM Treasury fundamental review of business rates, 31 Oct 2020 Download
GOC - Acceptance criteria policy for GOC business registrants, 28 Oct 2020 Open in new tab Download
GOC - Education and training requirements for GOC approved qualifications, 20 Oct 2020 Open in new tab Download
Letter to The Lord Bethell re Medicines and Medical Devices Bill, 7 October 2020 Open in new tab Download
GOC consultation on lifetime registration number, 30 September 2020 Open in new tab Download
Amendments to the HCPC rules, 8 September 2020 Open in new tab Download
Revising, expanding and upholding the Caldicott principles, 3 September 2020 Open in new tab Download
CPD (CET) review proposals, 24 August 2020 Open in new tab Download
Temporary changes to the Optometry Quality Assurance Handbook, 6 August 2020 Open in new tab Download
College of Optometrists COVID-19 consolidated guidance and accompanying pandemic guidance table, 31 July 2020 Open in new tab Download
College of Optometrists recovery phase guidance - ABDO, AOP, FODO response – 26 May 2020 Open in new tab Download
Response to the Health Select Committee - Delivering core NHS primary services during the pandemic and beyond - 8 May 2020 Open in new tab Download
Letter to government regarding Covid-19 furlough arrangements - 1 May 2020 Open in new tab Download
Proposed changes to the NHS Standard Contract for 2020/21, 31 January 2020 Open in new tab Download
National Tariff Payment System 2020/21, FODO response, 22 January 2020 Open in new tab Download
GOC Draft Strategic Plan 2020-2027, FODO response, 17 January 2020 Open in new tab Download
Apprenticeship Standard for Optometrist, FODO response, 10 January 2020 Open in new tab Download

Consultation Responses 2019

MHRA's Draft Guidance "Distributor obligations under the Medical Device Regulation 2017/745 (MDR) and the In Vitro Diagnostic Device Regulation 2017/746 (IVDR)", OC response, 2 December 2019 Open in new tab Download
Plans to cease NHS Digital General Ophthalmic Services Workforce and Activity publications, OFNC response, 29 November 2019 Open in new tab Download
Advancing our health: prevention in the 2020s, FODO response, 14 October 2019 Open in new tab Download
GOC, Case Management meetings, FODO response, 25 October 2019 Open in new tab Download
Simplification of Partial Exemption and Capital Goods Scheme - Call for Evidence, FODO response, 26 September 2019 Open in new tab Download
GOC Consultation on disclosing confidential information about patients: draft guidance, FODO response , 13 June 2019 Open in new tab Download
Implementing the NHS Long Term Plan - proposals for possible changes to legislation, FODO response 25 April 2019 Open in new tab Download
Appropriate clinical negligence cover consultation, FODO response 28 February 2019 Open in new tab Download
GOC Education Strategic Review, draft education standards and learning outcomes, FODO response, 25 February 2019 Open in new tab Download

Consultation Responses 2018

Contracting arrangements for Integrated Care Providers, FODO response to NHS England, October 2018 Open in new tab Download
General Optical Council performance review, FODO response to the PSA, October 2018 Open in new tab Download
Health and Social Care Committee inquiry into the impact of a no-deal Brexit on health and social care – submission from the Optical Confederation, October 2018 Open in new tab Download
Developing the long term plan for the NHS, FODO response, September 2018 Open in new tab Download
A review of the standards of good regulation, FODO response to the PSA, September 2018 Open in new tab Download
CET: fit for the future – life long learning review, FODO response to the GOC, September 2018 Open in new tab Download
Draft quality standard on serious eye disorders, Optical Confederation response to NICE, September 2018 Open in new tab Download
Evidence based interventions, Optical Confederation and LOCSU response to NHS England, September 2018 Open in new tab Download
GOC consultation on draft standards for optical businesses, FODO response, August 2018 Open in new tab Download
GOC consultation on draft standards for optical businesses, draft standards with FODO annotations and amendments, August 2018 Download
Supporting primary care services – NHS England’s contract with Capita, written evidence to the Public Accounts Committee inquiry, June 2018 Open in new tab Download
Education Strategic Review, concepts and principles consultation, ACLM, FMO, FODO response to GOC consultation, March 2018 Open in new tab Download
Education Strategic Review, concepts and principles consultation, FODO response to GOC Consultation, March 2018 Open in new tab Download
Conditions for which over-the-counter items which should not routinely be prescribed in primary care, NHS England and NHS Clinical Commissioners, March 2018 Open in new tab Download
Dementia – assessment, management and support for people living with dementia and their carers, NICE, February 2018 Open in new tab Download
Quality standard on eye disorders, Optical Confederation response to NICE, January 2018 Open in new tab Download
Promoting professionalism, reforming regulation, Optical Confederation response to Department of Health and Social Care, January 2018 Open in new tab Download
Sustainability and Transformation Partnerships, Optical Confederation and College of Optometrists response to the Health Select Committee, January 2018 Open in new tab Download
Brexit, Medicines, Medical Devices, and substances of human origin , Optical Confederation and College of Optometrists response to the Health Select Committee, January 2018 Open in new tab Download

Consultation Responses 2017

Accountable care organisations and the NHS Standard Contract, Department of Health, November 2017 Open in new tab Download
Written submission to the GOC’s Head of CET and Standards, ahead of a formal consultation due later this year, November 2017 Open in new tab Download
Draft guideline on Suspected Neurological Conditions, NICE, September 2017 Open in new tab Download
Inquiry into capacity issues in NHS eye care services and preventing avoidable sight loss, APPG, September 2017 Open in new tab Download
Consensual disposal of fitness to practice cases, GOC, September 2017 Open in new tab Download
Response to GOC consultation on Accreditation of Prior Learning Policy, OC/ABDO, September 2017 Open in new tab Download
Draft guideline on Macular Degeneration, NICE, August 2017 Open in new tab Download
Glaucoma – diagnosis and management, NICE, July 2017 Open in new tab Download
Eye Health and preventing sight loss in London, London Assembly Health Committee, July 2017 Open in new tab Download
Management of Cataract in adults, NICE, June 2017 Open in new tab Download
Inquiry into managing demand in primary care – the case for a national strategy, APPG, April 2017 Open in new tab Download
Discretionary business rates relief, Department for Communities and Local Government, April 2017 Open in new tab Download
Building our Industrial Strategy, Department for Business, Energy & Industrial Strategy, April 2018 Open in new tab Download
Accessible information Standard – post implementation review, NHS England, March 2017 Open in new tab Download
Strategic education review, FODO response to GOC, March 2017 Open in new tab Download
Strategic education review, OC response to GOC, March 2017 Open in new tab Download
Survey on VAT and EU public consultation, March 2017 Open in new tab Download
Higher qualifications in glaucoma and low vision, College of Optometrists, February 2017 Open in new tab Download
Updated CVI form and explanatory notes, Department of Health, January 2017 Open in new tab Download
Three-year strategic plan 2017-2020, GOC, January 2017 Open in new tab Download

Policy Resources

FODO Group NHS England legislation position statement,18 April 2019 Open in new tab Download
Annotated highlights from NHS Long Term Plan for FODO and NCHA members, January 2019 Open in new tab Download
Preparations for Brexit briefing, January 2019 Open in new tab Download
Medical devices and no deal Brexit briefing, November 2018 Open in new tab Download
See the light: Improving capacity in NHS eye care, report of the All Party Parliamentary Group on Eye Health and Visual Impairment, July 2018 Open in new tab Download
Foresight Project Report, A discussion of the potential impact of technology on the UK optical sector to 2030, Report by 2020Health, March 2016 Open in new tab Download
Foresight Project Report summary, March 2016 Open in new tab Download
Optical Confederation evidence to the Health Select Committee on primary care services, September 20 Open in new tab Download
Call to Action for Eye Health, Optical Confederation Response, 2014 Open in new tab Download
Clinical Consensus Panel Report on the Use of Fluorescein in Primary Care, September 2013 Open in new tab Download

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