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Policy submissions

Our responses to consultations and policy resources

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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 2024
NHS standard consultation 2024/2025, FODO and NCHA joint response, 29 January 2024
Consultation responses 2023
GOC - removing reference to a registrant's gender on the public register, 22 December 2023
GOC - searching the GOC register, 22 December 2023
Improving Integrated Commissioning in Health & Social Care, 31 October 2023
GOC - Statement on verification of contact lens specifications and definition of aftercare, 24 October 2023
DVLA driver licensing call for evidence, 20 October 2023
Disclosure of industry payments to the healthcare sector, 16 October 2023
In School Eye Testing for Pupils in Special Schools in England, 16 October 2023
GOC Managing applications for GOC registration from optical professionals who have qualified outside the UK or Switzerland, 4 October 2023
College of Optometrists: Guidance for Professional Practice public consultation, 4 October 2023
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
Home Office mandatory reporting of child abuse, 14 August 2023
Level 6 Ophthalmic Dispensing Apprenticeship Standard, 29 June 2023
PSA annual review of GOC's performance 2022-2023, 26 June 2023
FODO response to the Welsh Government consultation: Proposals to reform the ophthalmic services delivered in primary care in Wales, 19 June 2023
GOC updating gender on the register, 17 March 2023
PSA draft strategic plan 2023-2026 FODO and NCHA response, 24 February 2023
Hewitt review call for evidence, 9 January 2023
Consultation responses 2022
NHS Provider Licence, 9 December 2022
MHRA fee increase consultation, 23 November 2022
PSA - regulators performance in Equality, Diversity and Inclusion, 9 October 2022
PSA annual review of GOC's performance - 2021-2022, 18 October 2022
Primary Care response to Health Select Committee on ICSs, 5 August 2022
GOC call for evidence on the Opticians Act and consultation on associated GOC policies, 18 July 2022
MHRA new code of practice for Expert Advisory Committees, 24 May 2022
Healthcare Regulation - deciding when statutory regulation is appropriate, 31 March 2022
Provider Selection Regime: consultation on the detail of proposals for regulations. 28 March 2022
Evidence Based Interventions List 3 consultation, 25 March 2022
Consultation on proposed changes to the Guidance for Professional Practice, 21 March 2022
NHS National Tariff 2022-23, 28 January 2022
GOC Illegal Practice Strategy Review, 24 January 2022
Consultation Responses 2021
Review of temporary provisions in the Human Medicines Regulations 2012 to support influenza and COVID-19 vaccination campaigns, 23 December 2021
PSA consultation on its approach to reviewing the regulators - follow up, 21 December 2021
GOC consultation - new requirement for contact lens opticians,13 December 2021
DVLA consultation to change procedures for registered healthcare professionals, 6 December 2021
MHRA consultation on the future regulation of medical devices in the United Kingdom - FODO, ABDO, AOP response, 25 November 2021
FODO letter to the Institute for Apprenticeships and Technical Education and Trailblazer Group, 24 November 2021
Extending free PPE to the health and care sector response, 31 October 2021
GOC special entry to GOC register in AS, SP and IP categories, 6 October 2021
PSA annual review of GOC's performance - 2020-21, 1 October 2021
GOC Service of statutory notices by email policy, 23 Sept 2021
GOC Remote Hearings Protocol, 23 Sept 2021
GOC Hearings and indicative sanctions guidance 2021, 23 Sept 2021
Review of Professional Regulators – stakeholders survey, 17 Sept 2021
NI Department of Health consultation on duty of candour and being open – Response of FODO members in Northern Ireland, 31 August 2021
GOC consultation on CET exceptions policy, 8 July 2021
Regulating healthcare professionals, protecting the public, 16 June 2021
Making vaccination a condition of deployment in older adult care homes, 21 May 2021
System Oversight Framework 2021-2022 consultation. 14 May 2021
NHS Provider selection regime consultation, 7 April 2021
Value shifting consultation, 30 March 2021
Health & Social Care committee enquiry - Department's White Paper on health social care, 23 March
AMD Commissioning Guidance Consultation, 18 March 2021
GOC consultation on Speaking up guidance, 9 March 2021
England Vision Strategy review, 18 Feb 2021
Draft NHS Standard Contract 2021-22, 4 Feb 2021
GOC consultation on CET Rules, 1 Feb 2021
Building a strong integrated care system, 8 Jan 2021
GOC consultation on COVID-19 statements, 7 Jan 2021
Consultation Responses 2020
PSA review - Learning from Covid, 21 Dec 2020
Temporary Amendments to HSC Framework Document, 4 Dec 2020
Tariff Engagement Consultation, 4 Nov 2020
HM Treasury fundamental review of business rates, 31 Oct 2020
GOC - Acceptance criteria policy for GOC business registrants, 28 Oct 2020
GOC - Education and training requirements for GOC approved qualifications, 20 Oct 2020
Letter to The Lord Bethell re Medicines and Medical Devices Bill, 7 October 2020
GOC consultation on lifetime registration number, 30 September 2020
Amendments to the HCPC rules, 8 September 2020
Revising, expanding and upholding the Caldicott principles, 3 September 2020
CPD (CET) review proposals, 24 August 2020
Temporary changes to the Optometry Quality Assurance Handbook, 6 August 2020
College of Optometrists COVID-19 consolidated guidance and accompanying pandemic guidance table, 31 July 2020
College of Optometrists recovery phase guidance - ABDO, AOP, FODO response – 26 May 2020
Response to the Health Select Committee - Delivering core NHS primary services during the pandemic and beyond - 8 May 2020
Letter to government regarding Covid-19 furlough arrangements - 1 May 2020
Proposed changes to the NHS Standard Contract for 2020/21, 31 January 2020
National Tariff Payment System 2020/21, FODO response, 22 January 2020
GOC Draft Strategic Plan 2020-2027, FODO response, 17 January 2020
Apprenticeship Standard for Optometrist, FODO response, 10 January 2020
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
Plans to cease NHS Digital General Ophthalmic Services Workforce and Activity publications, OFNC response, 29 November 2019
Advancing our health: prevention in the 2020s, FODO response, 14 October 2019
GOC, Case Management meetings, FODO response, 25 October 2019
Simplification of Partial Exemption and Capital Goods Scheme - Call for Evidence, FODO response, 26 September 2019
GOC Consultation on disclosing confidential information about patients: draft guidance, FODO response , 13 June 2019
Implementing the NHS Long Term Plan - proposals for possible changes to legislation, FODO response 25 April 2019
Appropriate clinical negligence cover consultation, FODO response 28 February 2019
GOC Education Strategic Review, draft education standards and learning outcomes, FODO response, 25 February 2019
Consultation Responses 2018
Contracting arrangements for Integrated Care Providers, FODO response to NHS England, October 2018
General Optical Council performance review, FODO response to the PSA, October 2018
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
Developing the long term plan for the NHS, FODO response, September 2018
A review of the standards of good regulation, FODO response to the PSA, September 2018
CET: fit for the future – life long learning review, FODO response to the GOC, September 2018
Draft quality standard on serious eye disorders, Optical Confederation response to NICE, September 2018
Evidence based interventions, Optical Confederation and LOCSU response to NHS England, September 2018
GOC consultation on draft standards for optical businesses, FODO response, August 2018
GOC consultation on draft standards for optical businesses, draft standards with FODO annotations and amendments, August 2018
Supporting primary care services – NHS England’s contract with Capita, written evidence to the Public Accounts Committee inquiry, June 2018
Education Strategic Review, concepts and principles consultation, ACLM, FMO, FODO response to GOC consultation, March 2018
Education Strategic Review, concepts and principles consultation, FODO response to GOC Consultation, March 2018
Conditions for which over-the-counter items which should not routinely be prescribed in primary care, NHS England and NHS Clinical Commissioners, March 2018
Dementia – assessment, management and support for people living with dementia and their carers, NICE, February 2018
Quality standard on eye disorders, Optical Confederation response to NICE, January 2018
Promoting professionalism, reforming regulation, Optical Confederation response to Department of Health and Social Care, January 2018
Sustainability and Transformation Partnerships, Optical Confederation and College of Optometrists response to the Health Select Committee, January 2018
Brexit, Medicines, Medical Devices, and substances of human origin , Optical Confederation and College of Optometrists response to the Health Select Committee, January 2018
Consultation Responses 2017
Accountable care organisations and the NHS Standard Contract, Department of Health, November 2017
Written submission to the GOC’s Head of CET and Standards, ahead of a formal consultation due later this year, November 2017
Draft guideline on Suspected Neurological Conditions, NICE, September 2017
Inquiry into capacity issues in NHS eye care services and preventing avoidable sight loss, APPG, September 2017
Consensual disposal of fitness to practice cases, GOC, September 2017
Response to GOC consultation on Accreditation of Prior Learning Policy, OC/ABDO, September 2017
Draft guideline on Macular Degeneration, NICE, August 2017
Glaucoma – diagnosis and management, NICE, July 2017
Eye Health and preventing sight loss in London, London Assembly Health Committee, July 2017
Management of Cataract in adults, NICE, June 2017
Inquiry into managing demand in primary care – the case for a national strategy, APPG, April 2017
Discretionary business rates relief, Department for Communities and Local Government, April 2017
Building our Industrial Strategy, Department for Business, Energy & Industrial Strategy, April 2018
Accessible information Standard – post implementation review, NHS England, March 2017
Strategic education review, FODO response to GOC, March 2017
Strategic education review, OC response to GOC, March 2017
Survey on VAT and EU public consultation, March 2017
Higher qualifications in glaucoma and low vision, College of Optometrists, February 2017
Updated CVI form and explanatory notes, Department of Health, January 2017
Three-year strategic plan 2017-2020, GOC, January 2017
Policy Resources
FODO Group NHS England legislation position statement,18 April 2019
Annotated highlights from NHS Long Term Plan for FODO and NCHA members, January 2019
Preparations for Brexit briefing, January 2019
Medical devices and no deal Brexit briefing, November 2018
See the light: Improving capacity in NHS eye care, report of the All Party Parliamentary Group on Eye Health and Visual Impairment, July 2018
Foresight Project Report, A discussion of the potential impact of technology on the UK optical sector to 2030, Report by 2020Health, March 2016
Foresight Project Report summary, March 2016
Optical Confederation evidence to the Health Select Committee on primary care services, September 20
NHS Five Year Forward View, 2014
Call to Action for Eye Health, Optical Confederation Response, 2014
Clinical Consensus Panel Report on the Use of Fluorescein in Primary Care, September 2013