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Deadline for mandatory Covid-19 vaccinations approaches for health and care roles in England

NHS guidance for employers in healthcare in England outlines planning and preparation for the implementation of regulations around Vaccination as a Condition of Deployment (VCOD) for healthcare workers.

Mon 17th January 2022 The PDA

Although it is estimated that 90% of NHS staff have already been fully vaccinated, health and social care providers in England will soon be required to ensure that all those working in areas regulated by the Care Quality Commission (CQC), other than those who are exempt, are fully vaccinated against Covid-19 before the 1 April 2022.

Iterative guidance has been issued to NHS Trusts and Integrated Care Systems (ICS) to inform planning and preparation for the implementation of the new regulations around VCOD for healthcare workers. A letter outlining the process and signposting NHS organisations to resources and information to support conversations with their affected workforce was published on 14 January 2022 along with a frequently asked questions document.

Due to the interval required between first and second doses of the MHRA approved vaccines, the latest date to start a course of vaccinations is 3 February 2022. This is to receive a second dose by the 31 March 2022 deadline.

The regulations apply equally across both the public (NHS) and independent health sectors. This involves anyone who works in direct, face-to-face contact with service users. This will include front-line workers, as well as non-clinical workers not directly involved in patient care but who may still have direct, face-to-face contact with patients, such as receptionists, ward clerks, porters, and cleaners.

The PDA believes that encouraging and informing the NHS workforce is still the best way to increase vaccination uptake. The PDA also supports the calls from the Trade Union Congress (TUC) for the government to delay the implementation of this policy. At a time when the NHS is facing considerable workforce issues because of staff absences due to Covid-19, there is a significant risk around patient safety and the ability for essential services to be maintained should non-vaccinated staff be removed from frontline roles.

What is CQC regulated activity?

Examples of the types of activities CQC regulates include:

  • Personal care
  • Accommodation for persons who require nursing or personal care
  • Accommodation for persons who require treatment for substance misuse
  • Treatment of disease, disorder, or injury
  • Assessment or medical treatment for persons detained under the Mental Health Act 1983
  • Surgical procedures
  • Diagnostic and screening procedures
  • Management of supply of blood and blood-derived products
  • Transport services, triage, and medical advice provided remotely
  • Maternity and midwifery services
  • Termination of pregnancies
  • Services in slimming clinics
  • Nursing care
  • Family planning services.

Who is exempt from the regulations?

The guidance states that a person may be deployed in the provision of the regulated activity despite not having been vaccinated if that person is:

  • Under the age of 18
  • Clinically exempt
  • Exempt due to a short-term medical condition (which is an option that some pregnant women may choose to take; for pregnant women the exemption expires 16 weeks post-partum and so will allow them to become fully vaccinated after birth)
  • Has taken part or is currently taking part in a clinical trial for a Covid-19 vaccine.

Further information around determining if a worker is in scope of the regulations is available in appendix 1 of the guidance; ‘Workers Required to be Vaccinated as a Condition of Deployment – Flow Chart’.

What about other parts of the UK?

Northern Ireland’s Health Minister, Robin Swann has committed to a public consultation on the introduction of mandatory Covid-19 and flu vaccinations for new workers in the health and care sector. The Minister has also said that introducing such measures would be a significant development that should only be undertaken after careful consideration. The governments in Scotland and Wales have so far ruled out the introduction of such legislation, citing a high uptake of the vaccination by health and care workers. 

The regulation relates to the role and not to the individual worker, hence those who work across borders need to comply with the requirement if they want to work in England. Any individual living in England but only working in another nation must comply with the regulations relating to where they will work.

Support for PDA members  

The PDA strongly encourages its members to participate in the vaccination programme and continues to promote this stance through its #GetVaccinated campaign. The PDA recognises that as health professionals and educated scientists, pharmacists understand the balance between individual choice and the need to protect patients, colleagues, and themselves.

The PDA welcomes that those pharmacists who are medically exempt from the vaccination, will not be barred from working. The PDA also acknowledges that there may be a small number of pharmacists who for reasons other than medical exemption do not wish to have the vaccination.

As a trade union, the PDA will advise and support members who are affected by the introduction of the regulations about their individual employment status and rights if they no longer meet the conditions of deployment.

Any PDA members who are concerned about their employment should contact the PDA for advice.

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