NHS (General Ophthalmic Services) (Scotland) Amendment Regulations 2025: BRIA

Executive summary

Issue and why it needs to be addressed

Ophthalmology as a hospital specialty has significant waiting list pressures. Amongst other things, these waiting list pressures create a risk of otherwise avoidable sight loss occurring.

The Scottish Government is committed to identifying and implementing opportunities to shift more appropriate care into community settings closer to patient’s homes, helping to free up workforce capacity within the HES to manage patients with more sight-threatening conditions.

Intended outcomes

When fully rolled out and embedded nationally, GOS-SS will safely, sustainably and cost effectively move up to an estimated 20,000 unscheduled hospital appointments per annum into the community. This will provide additional HES workforce capacity to manage other patients waiting for appointments.

It is expected that the majority of patients experiencing a complex acute anterior eye condition will be managed closer to home under GOS-SS, instead of being referred to HES. They will therefore benefit from faster access to treatment and better continuity of care. The service will utilise the expertise of community optometrists who hold the IP qualification and OMPs.

A revised fee structure will be introduced to reflect the complexity and responsibility involved in delivering GOS-SS. This supports the sustainability of community optometry practices providing GOS-SS.

It is hoped that, in due course, an increasing number of community optometrists will be able to provide GOS-SS. From summer 2029, undergraduate optometry students in Scotland (like doctors, dentists and pharmacists) will be able to graduate as IP – the only UK nation where this will be the case. This will promote a greater contribution of professionals working in the community, supporting wider workforce sustainability.

Options

Introducing GOS-SS will ease pressure on HES and improve patient access. It supports the Scottish Government’s strategic goal of shifting care closer to home and benefits optometry businesses through higher remuneration.

Not introducing GOS-SS will risk the continuation of high HES waiting times, underused community expertise and capacity, and slower progress toward integrated care. While interim support or expanding existing hospital services could be considered as alternatives, these options are less sustainable than a nationally commissioned GOS-SS service.

The clinical conditions included within GOS-SS were assessed for their complexity and suitability for management by IP optometrists and OMPs. Their selection was informed by the success of a pilot carried out during the COVID-19 pandemic, where IP optometrists based in community optometry practices effectively managed similar cases. In addition, a number of Health Boards across Scotland already have local enhanced anterior eye condition services.

Input from the representative body for the community optometry sector in Scotland, Optometry Scotland (OS), has helped to ensure that the service accurately reflects the capabilities of IP optometrists.

Sectors affected

The introduction of GOS-SS affects a wide range of optometry businesses, from small privately owned practices to larger corporate chains.

Smaller practices can expand their clinical services and attract more patients by offering specialist care locally. The new fee structure for GOS-SS provides higher remuneration, helping small businesses to remain financially sustainable. It will encourage optometrists to obtain the IP qualification, thus allowing small practices to upskill their optometry workforce.

Larger firms with multiple locations are well placed to implement GOS-SS, especially in areas with high demand, and may benefit from economies of scale. They may also benefit from their ability to provide care up to seven days per week and via extended opening hours.

Engagement completed, ongoing and planned

There is broad support and consensus to this service from Health Boards (primary care and HES) and the community optometry sector. These stakeholders have been, and will continue to be, consulted, involved and informed in the work undertaken.

The Scottish Government consulted with OS, who advocated for a model that would empower IP optometrists to manage more complex acute anterior eye conditions within community settings. OS were keen to see GOS-SS building on the success of previous and existing models of care, where the profession had demonstrated their capability to deliver.

Anticipated impacts (intended and unintended, positive and negative) and mitigating actions

The changes overall are expected to be positive:

• Up to an estimated 20,000 unscheduled HES appointments annually will be safely, sustainably and cost-effectively moved to community care.
• This move will release HES workforce capacity for other patients.
• Provision of treatment via GOS-SS will also reduce pressure on General Practitioners, as IP optometrists and OMPs can issue an NHS prescription.
• Patients benefit from improved access to care closer to home, flexible appointments and greater continuity of care.
• The expansion of the range of services that an IP optometrist or OMP can deliver has the potential to enhance the trust that the public has in these professions.
• Optometry practices providing GOS-SS will experience increased revenue.
• The referral of patients between non-IP optometrists and IP optometrists, and the provision of feedback, will support professional collaboration.
• The service encourages IP optometrists and OMPs to work at the top of their professional license.

Negative impacts may include:

• Increased costs for the Scottish Government both on a non-recurring and recurring basis.
• Service availability may vary across Health Boards due to differences in the local workforce.
• Non-IP optometrists may feel excluded or under-supported as a result of the expanded scope of practice for their IP colleagues.
• The profession may feel initially resistant, with concerns over new business processes and transitional disruption.
• Implementation may temporarily slow existing services, causing confusion or frustration for both staff and patients during the adjustment period.

In order to mitigate any negative impact, the Scottish Government is working closely with delivery partners to establish the framework required for implementing these changes.

Enforcement / compliance

The legal framework for GOS-SS will be set out in the 2006 Regulations via amendments made by the SSI. In addition, the Statement^[4] will set out the arrangements for remuneration under GOS-SS. The Statement is a legal Determination issued by Scottish Ministers under regulation 17 of the 2006 Regulations that, amongst other things, sets out the fees payable under GOS. The Scottish Government will also issue operational guidance through PCA circulars and will make other adjustments as considered appropriate.

The payment mechanism for GOS-SS facilitates a valuable stream of data which can be used to support the review of the service by the Scottish Government and Health Boards.

GOS-SS providers will be expected to adhere to service delivery standards, with support provided to ensure understanding and compliance. Where non-compliance is identified, a supportive approach will be taken, prioritising guidance and improvement over punitive measures, in line with broader public service monitoring principles.

Recommendations / implementation plans

The Scottish Government has committed to this service in its NHS Operational Improvement Plan. Where clinically appropriate, Ministers have stated their intention to move eyecare services from HES into the community. This is considered a necessary action to help alleviate HES waiting list pressures and to deliver care closer to people’s homes.

Evaluation and monitoring of implementation / review of BRIA

The Scottish Government intends to review the impact of these changes with reference to both the community optometry sector and HES departments. It is not anticipated that the changes will be destabilising to either sector.