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

Section 3: Costs, impacts and benefits

Quantified costs to businesses

Community optometry practices providing GOS-SS will encounter costs for the purchase of appropriate equipment and education and training for staff, both of which are considered to be relatively minimal. GOS-SS eye examination appointments are likely to be longer in duration than other GOS appointments. As a result, there is a requirement to set GOS-SS fees at an appropriate level to cover these costs.

The Scottish Government will fund GOS-SS via increased investment in the existing GOS budget. Remuneration to relevant optometry practices will be made on an item-of-service basis, which drives productivity and enables robust monitoring.

Other impacts

Practices not providing GOS-SS are expected to refer relevant patients to another practice participating in this service. There is a risk that, once such a patient has been referred, they may choose to continue to attend this other practice, potentially leading to a loss of business for the referring practice.

If GOS-SS fees are set too low, there is a risk that some practices may choose to focus on retail activities instead of clinical care. This could undermine the policy’s objective of shifting more eyecare into the community.

In order to negate these risks, GOS-SS fees have been negotiated and agreed with OS at an appropriate level.

Scottish firms’ international competitiveness

Not applicable

Benefits to business

The introduction of GOS-SS offers a range of benefits to optometry businesses in Scotland.

Enhanced Revenue Streams

GOS-SS introduces a revised fee structure that provides higher remuneration for IP optometrists and OMPs who have entered into arrangements with Health Boards for GOS-SS provision.

Fees have been set in the Statement at an appropriate level (£97.69 for initial appointments and £47.80 for follow-up appointments)^[9]. This represents an increase compared to standard and enhanced GOS supplementary eye examination fees and acknowledges the costs involved for businesses providing GOS-SS.

Expansion of Clinical Services and Patient Base

By enabling IP optometrists and OMPs to enter into arrangements with Health Boards to provide GOS-SS, practices are supported to expand the range of clinical services they offer. This may assist them to expand their patient base.

Support for Workforce Development

The policy may incentivise non-IP optometrists to undertake the IP postgraduate qualification. The Scottish Government is separately investing in the Scottish optometry workforce via UK-leading changes to the Master’s optometry undergraduate degree, which will enable optometrists graduating in Scotland from summer 2029 to be IP qualified. This will position the community optometry sector in Scotland as being one of the most attractive locations in the UK in which to practice optometry.

Strategic Positioning and Sector Resilience

GOS-SS is a commitment set out in the Scottish Government’s NHS Operational Improvement Plan. By embedding advanced care in community settings, the policy enhances Scotland’s reputation for integrated, patient-centred healthcare and supports the resilience of the optometry sector.

Small business impacts

It is not anticipated that GOS-SS will have a differential impact on small optometry businesses.

Investment

It is not anticipated that GOS-SS will have any bearing on future global investment in Scotland.

Workforce and Fair Work

From a workforce perspective, the policy offers opportunities to IP optometrists and OMPs who have entered into arrangements with Health Boards for GOS-SS provision to deliver a wider range of clinical treatment to patients. This could improve job satisfaction and enhance employment opportunities. The proposal has no impact on the Fair Work First principles.

Climate change / Circular Economy

GOS-SS is likely to support climate and circular economy goals by shifting care closer to patient’s homes, reducing travel and thus transport emissions.

Competition Assessment

The five Competition and Markets Authority (CMA) competition assessment questions have been used to assess competition considerations:

Will the measure directly or indirectly limit the number or range of suppliers?

No. GOS-SS will increase the number of suppliers by moving care from a small number of HES departments to a significantly larger number of community optometry practices.

Will the measure limit the ability of suppliers to compete?

This will apply only where an optometry practice does not have an IP optometrist or OMP regularly working at or from its location.

Will the measure limit suppliers’ incentives to compete?

Not applicable.

Will the measure affect consumers’ ability to engage with the market and make choices that align with their preferences?

No. Patients will have the choice regarding which optometry practice they attend to receive GOS-SS, and the SSI requires referring practitioners to take into account where the patient normally resides.

Will the measure affect suppliers’ ability and/or incentive to introduce new technologies, products or business models?

GOS-SS may lead to participating practices extending their opening hours as a means to generate additional NHS income.

Patients will receive treatment under GOS-SS at no charge, in line with the Scottish Government’s existing policy on the free universal provision of NHS eye examinations. Patients will also not be required to pay for any medication they receive as part of this service, in line with the Scottish Government’s existing policy on the provision of free NHS prescriptions. As such, there is no ability for suppliers to compete to attract patients under GOS-SS.

There is, however, a risk that practices providing GOS-SS have a competitive advantage in terms of ability to generate NHS income over those practices that do not provide GOS-SS. There is no restriction on the number of optometry practices that can provide this service as long as they meet the relevant criteria.

Consumer Duty

GOS-SS will have a positive impact on consumers (patients) by enabling them to receive care closer to home and potentially quicker than if they had been referred to HES. There are no identified harms to consumers as a result of GOS-SS.