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

This business and regulatory impact assessment (BRIA) outlines the impact of new regulations enabling independent prescribing optometrists and ophthalmic medical practitioners to manage complex anterior eye conditions in the community. The changes aim to reduce hospital pressures, improve patient access, and support sustainable care.


Section 1: Background, aims and options

Background to policy issue

Sight loss charities estimate that there are currently more than 180,000 people in Scotland living with sight loss[5] – a figure projected to rise by 30,000 by 2030 due to ageing, comorbidities, and persistent health inequalities. This increasing demand places significant strain on health and social care services.

At the same time, HES are experiencing long waiting times, with many patients waiting over a year for hospital appointments, heightening the risk of avoidable sight loss.

In response, the Scottish Government is introducing GOS-SS, alongside the Community Glaucoma Service (CGS)[6], to shift care closer to home, reduce hospital pressures and improve access to timely treatment.

This aligns with commitments in the NHS Operational Improvement Plan and the Programme for Government 2025–26[7], which support community-based care and sustainable service delivery.

Purpose/ aim of action and desired effect

The primary purpose of GOS-SS is to expand the clinical role of IP optometrists and OMPs within community settings. GOS-SS aims to reduce unnecessary hospital visits, alleviate pressure on General Practice, and improve patient access to timely, expert-led care. This supports the Scottish Government’s broader strategy to shift the balance of care toward community-based services and contributes to improved health outcomes and system efficiency.

These outcomes support the National Performance Framework[8] by promoting health and reducing inequalities. By involving optometry practices in delivering enhanced services, the policy also fosters stronger collaboration between government and business in building a more resilient and inclusive health economy.

Data on hospital referrals and community activity can be measured to assess whether the policy is working and having the desired impact.

Options (considered so far / still open)

To address rising pressure on HES, a range of options were considered. These included maintaining the status quo, expanding existing HES capacity or introducing GOS-SS. The preferred option – GOS-SS – was identified as the most effective in achieving improved access, reducing referrals and delivering better patient outcomes.

While the status quo would require fewer resources, it risks ongoing strain on HES. Existing arrangements are not therefore sustainable.

Development of GOS-SS involved early and ongoing input from relevant stakeholders. This has helped shape the service so that it meets the needs of both patients and service providers and is adaptable to future changes.

Sectors / Groups affected

The group most significantly and positively impacted will be patients, who will be able to access timely treatment in a location closer to home.

These changes will also affect the community optometry sector and HES.

Community optometry practices with IP optometrists and OMPs who enter into arrangements with Health Boards for the provision of GOS-SS will need to adapt their business processes, staffing and training. These practices may look to expand their IP optometrist / OMP staffing, which will increase their revenue through GOS-SS fees.

HES departments will experience a reduction in referrals for acute anterior eye conditions, thus freeing up workforce capacity for more serious cases.

For organisations providing education and training to the community optometry sector, there is likely to be an increased demand for courses and/or appropriate education and training relevant to IP and anterior eye conditions. This may, in time, lead to an expansion of course offerings and further partnerships with NHS Education for Scotland (NES).

There are also some concerns with the introduction of GOS-SS:

  • Optometry practices without a regular working arrangement with an IP optometrist or OMP may feel disadvantaged, as they cannot offer GOS-SS and must refer relevant patients elsewhere to receive care. This could lead to an increase in some patients choosing to attend the other practice in future when accessing services.
  • The capacity to deliver GOS-SS depends on the geographical spread of IP optometrists / OMPs across Scotland, which can be more limited in rural and island areas. For example, there is currently no IP optometrist or OMP providing GOS in NHS Orkney’s area, meaning that GOS-SS cannot be provided there at the current time.

Contact

Email: eyecare@gov.scot

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