The aim of this guide is to provide Forum Central members with the information that you need to consider to inform your decisions about staff vaccinations.

Key points:

  • The regulations apply to health and social care workers working in CQC regulated services who have direct, face-to-face contact with service users. This includes wards and residential settings. It will therefore be necessary to include any of your staff or volunteers who are working on wards and in community teams alongside statutory colleagues. 
  • Regulations for residential and health care introduced will apply for ‘professional visitors’ including where staff provide support within such premises ie who do not directly deliver CQC services e.g. Advocates who go into hospitals.
  • This vaccination of people working in care homes document covers restrictions for entering a care home/care setting for local voluntary organisations. This guidance is aimed at service providers, registered persons, local authorities, workers (including agency staff) and residents of CQC-regulated care homes which provide accommodation for persons who require nursing and personal care. This guidance also applies to all professionals and tradespeople who enter these settings. 
  • There is no formal guidance for non-registered settings, so vaccination is not mandatory by regulation for community based social /community care /community provision
  • It is important to ensure you are engaging and consulting with staff & volunteers
  • You need to consider updating staff privacy notices and consider how long vaccination data will be retained, in line with data protection law and updating any data retention schedules covering staff data if you are planning to ask staff/volunteers for vaccination status
  • If you are still unclear, commissioners/funders of your service should be contacted
  • Let us know if you would like to join a discussion considering the potential merits of a sector wide consideration of redeployment approaches/opportunities to safeguard jobs especially in smaller providers who don’t have capacity or size of workforce to have the option to re-deploy as a way of retaining staff in the sector. 

Resources

NHS Healthcare worker guidance This includes a checklist on Page 29

Sample letters sent by NHS partners for info: sample NHS opt out letter and Sample NHS letter re Mandatory Covid Vaccinations Jan 22

Sample Vaccination policy from one of our members (anonymised) sample TS vaccine policy

Full Government guidance

Frequently asked questions

Making COVID-19 vaccination a condition of deployment in health and adult social care settings (domiciliary care and other CQC-regulated settings) is intended to:

  • Protect all those who use health and care services, a large number of whom are vulnerable, as well as the wider community.
  • Protect workers themselves by increasing vaccination rates. 
  • Help reduce COVID-19 related sickness absences.

https://www.england.nhs.uk/coronavirus/wp-content/uploads/sites/52/2021/12/C1470-vcod-for-healthcare-workers-planning-and-preparation-guidance.pdf

The Department of Health and Social Care, on 9 November 2021, laid regulations which amend the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (“the 2014 Regulations”), to provide that the registered person can only employ or otherwise engage a person in respect of a CQC regulated activity, if the person provides evidence that they have been vaccinated with a complete course of an authorised vaccine against COVID19 or, if otherwise vaccinated against coronavirus is also within a specified time period, vaccinated with a single dose of an authorised vaccine, subject to specific exemptions.

https://www.england.nhs.uk/coronavirus/wp-content/uploads/sites/52/2021/12/C1470-vcod-for-healthcare-workers-planning-and-preparation-guidance.pdf

The regulations were debated before Parliament on 14 December 2021 and were passed. They were approved by Parliament in January 2022 and come into force on 1 April 2022.

Workers who have face-to-face contact with service users and who are deployed as part of CQC regulated activity.

The regulations apply to health and social care workers who are deployed in respect of a CQC regulated activity, who have direct, face-to-face contact with service users. This include individuals working in non-clinical ancillary roles who enter areas which are utilised for the provision of a CQC-regulated activity as part of their role and who may have social contact with service users, but not directly involved in care (e.g., receptionists, ward clerks, porters, and cleaners), regardless of contracted hours or working arrangements. All honorary, voluntary, locum, bank and agency workers, independent contractors, students/trainees over 18, and any other temporary workers are also required to have the vaccination. 

https://www.england.nhs.uk/coronavirus/wp-content/uploads/sites/52/2021/12/C1470-vcod-for-healthcare-workers-planning-and-preparation-guidance.pdf

If you have face to face contact with service users as part of your job, you may need to have both vaccinations to continue in your role. 

The COVID-19 vaccines currently available are given in 2 doses. You must have the 2nd dose 8 to 12 weeks after the 1st dose Staff must have their first vaccination by 3 February to ensure they can have their second vaccination by 31 March and be fully vaccinated by 1 April 2022.

The team at the vaccination hub at Elland Road will answer all general questions about vaccines.  You can talk to one of the team either by booking an appointment with them here:

https://patient.inhealthcare.co.uk/selfenrol/v2/form. The staff at the vaccination hub are all trained to respond to concerns and will answer your general questions.

Alternatively, you can contact Dianne Colley  [email protected]

There is a lot of information available on the Internet, some reliable sources include:

https://www.leedsccg.nhs.uk/health/coronavirus/covid-19-vaccine/

https://www.gov.uk/government/publications/covid-19-vaccination-and-blood-clotting

https://www.bhf.org.uk/informationsupport/heart-matters-magazine/news/coronavirus-and-your-health/coronavirus-vaccine-your-questions-answered/covid-19-vaccines-and-myocarditis-should-you-be-worried

There is very helpful information available here:

Covid vaccine: Fertility and miscarriage claims fact-checked – BBC News

https://twitter.com/NHSuk/status/1464164107096150048?s=20

Both sources are clear that there is no evidence of impact on fertility in either men or women.

The Royal College of Obstetricians advises:

Vaccination in pregnancy against COVID-19 is strongly recommended and should be offered at the same time as the rest of the population based on age and clinical risk.

https://www.rcm.org.uk/media/5619/2021-11-02-coronavirus-covid-19-infection-in-pregnancy-v141.pdf

However, some pregnant women may prefer to wait to be vaccinated till after they have given birth, they can use MAT B1 certificates to show their COVID status, if they choose to use a medical exemption. Pregnant women do not need to apply for a medical exemption NHS COVID Pass if they have a MAT B1 certificate. For pregnant women the exemption will expire 16 weeks post-partum. This will allow them to become fully vaccinated after birth.

COVID-19 medical exemptions: proving you are unable to get vaccinated – GOV.UK (www.gov.uk)

The regulations will apply to all staff working in a CQC-regulated services in England, including those who are breastfeeding or planning to get pregnant, unless they have a medical reason not be vaccinated. 

Women who are planning pregnancy, are in the immediate postpartum, or are breastfeeding can be vaccinated with any Covid-19 vaccine, depending on their age and clinical risk group. 

All the vaccines are subject to rigorous testing before they can be given to the public. There is no evidence to suggest the vaccines can cause problems with fertility.

Some individuals are unable to be vaccinated. You can apply for proof that you have a medical reason why you should not be vaccinated or why you should not be vaccinated and tested.

If you get this proof of medical exemption, you’ll be able to use the NHS COVID Pass wherever you need to prove your COVID-19 status within England.

The possible reasons for exemptions are limited. Examples that might be reasons for a medical exemption are:

  • people receiving end of life care where vaccination is not in the person’s best interests
  • people with learning disabilities or autistic individuals, or people with a combination of impairments where vaccination cannot be provided through reasonable adjustments
  • a person with severe allergies to all currently available vaccines
  • those who have had an adverse reaction to the first dose (for example, myocarditis)

Other medical conditions could also allow you to get a medical exemption. Short-term exemptions will also be available for those with short-term medical conditions 

To get a medical exemption you need to phone the NHS COVID Pass service on 119 to ask for an NHS COVID Pass medical exemptions application form.

COVID-19 medical exemptions: proving you are unable to get vaccinated – GOV.UK (www.gov.uk)

Yes, unvaccinated staff can continue to work in all roles until the regulations come into force which is anticipated to be 1 April 2021.  All staff should review the Individual Risk Assessment and discuss any safety concerns with their line manager.

You can book an appointment at Elland Road, or walk in https://patient.inhealthcare.co.uk/selfenrol/v2/form

Or book an appointment local to you Book or manage a coronavirus (COVID-19) vaccination – NHS (www.nhs.uk)

There are pop up community vaccination clinics running across Leeds and you can find information on these here: walk-in vaccination clinics

The choice of vaccine will be dependent on the availability on the day, you can discuss what options are available with the clinical team at your appointment.

There is no indication at present that exemption on religious grounds will be permitted.

Religious organisations have released position statements to their communities and created dedicated pages on their websites to provide guidance about the current vaccines for eligible/at-risk individuals:

https://www.leedsccg.nhs.uk/health/coronavirus/covid-19-vaccine/information-for-local-communities-about-covid-19-vaccine/information-for-faith-groups/

If you received a UK approved vaccination overseas you are now able to register on COVID pass:

https://www.nhs.uk/conditions/coronavirus-covid-19/coronavirus-vaccination/tell-nhs-about-coronavirus-vaccinations-abroad/  

The guidance references that people whose vaccine is not on the approves list should read the information here:

https://www.gov.uk/government/publications/covid-19-vaccinations-received-overseas

The regulations relating to vaccination as a condition of deployment were passed in parliament on 14 December 2021.  When they are enacted in law all CQC registered providers need to apply the regulations, there is no opportunity within them to review immunity levels.  The regulations are clear, it is a legal requirement for staff deployed to deliver CQC regulated activity in service user facing roles to be fully vaccinated. 

The registered person needs to see proof of vaccination or exemption in order to confirm that staff and volunteers working are compliant with the regulations. Individuals can choose to use the existing NHS COVID Pass service to show the registered person their vaccination record or exemption status. 

Providing false information about exemption may result in disciplinary action. 

The Government has no plans at this time to make booster vaccines a condition of deployment. 

This is because booster doses are being delivered in a targeted way, and not everyone in the population is eligible at the same time depending on when they received their primary doses, making implementation unfeasible in the immediate term. 

There is however an increasing amount evidence with respect to waning immunity and the importance of booster vaccines in “topping up” protection. As such the government will continue to review the scientific advice and, if necessary, amend the regulations to include booster vaccines.