Vaccination of people working or deployed in care homes

 

Please note that it is a requirement for all care home staff to have received their first vaccination by 16 September 2021. For staff that are yet to be vaccinated, they can access their jab via www.grabajab.net which has a list of walk-in clinics staff can access.

This email is also a  reminder that you need to regularly update all areas of the National Capacity Tracker – at a minimum, this should be every 48 hours.

Central Government continues to use this data on a daily basis to identify issues or raise concerns with Local Authorities to investigate further. Therefore, it is really important that the system is kept up to date, particularly vaccination uptake for staff, and residents where you are a care home provider.

The tracker is also a Government requirement and its regular use forms the basis for distributing additional funding support to providers, eg Infection Control Fund.

We appreciate that at times the system experiences data errors so if you notice this then please continue to raise your queries directly with the Capacity Tracker Support Team (tel: 0191 691 3729, email: necsu.capacitytracker@nhs.net and insert ‘Capacity Tracker’ into the subject line.

The guidance has been produced to help support the implementation of the regulations which require that anyone entering a CQC-regulated care home for people requiring nursing or personal care, to be fully vaccinated subject to certain exemptions. 
 
The Health and Social Care Act 2008 (Regulated Activities) (Amendment) (Coronavirus) Regulations 2021 were made on 22 July and come into force on 11 November. As such, the 16-week grace period has now begun. The 16 September represents the last date for care home workers to get their first dose so they are fully vaccinated by the time the regulations come into force.  


Some of the key points from the guidance are outlined below: 
 
Remit:
 
The regulations require that all CQC-registered service providers (or registered managers) of accommodation for those who require nursing or personal care in a care home must ensure that a person does not enter the care home unless: 

  • the person resides in the care home used by the registered person (a resident)

  • the person has provided the registered person, (or those acting on behalf of the registered person) with satisfactory evidence that:

    • they have been vaccinated with the complete course of an authorised vaccine (the individual can prove they are fully vaccinated)

    • they, for clinical reasons, should not be vaccinated (the individual is exempt for medical reasons);

  • it is reasonably necessary for the person to provide emergency assistance in the care home

  • it is reasonably necessary for the person to provide urgent maintenance assistance to the care home

  • the person is a member of the emergency services in execution of their duties

  • that a person is a friend or relative of the resident visiting the resident

  • the person is visiting a resident who is dying

  • it is reasonably necessary for the person to provide comfort or support to a resident in relation to a resident’s bereavement following the death of a relative or friend or

  • the person is under the age of 18.

 
The vaccination requirement only applies to people who go inside a care setting (the definition of 'care home' does not include any surrounding grounds). As long as someone is not entering the building, they would not need to show vaccination status. 
 
Evidence:
 
In order to enter a care home, individuals must be able to demonstrate that they have received a complete course of their COVID-19 vaccination.
 
The registered person at the care home needs to satisfy themselves of the identity of the person entering the care home and their corresponding proof of vaccination. 
 
An individual can demonstrate their vaccination status via one of three routes:

  • The NHS app

  • A web-based alternative to the NHS app

  • An NHS COVID Pass letter

 
The registered person should keep a record of: 

  • the vaccination or exemption status of staff members and the date that the status was last checked

  • the vaccination or exemption status of those entering the care home unless exempt and the date that the status was last checked

 
There is no requirement for registered persons to record the clinical reason behind the exemption - they should only record whether a person is medically exempt or not. 
 
Individuals entering a care home only need to demonstrate vaccination status on the first occasion they enter or register, and the registered person should record their status on the care home’s local system (for example IT system, paper file etc). All subsequent checks of individuals who have previously demonstrated vaccination status can be carried out via the records which will state the date and time the individual proved their status. Care homes will be able to use these records as proof of vaccination status, to reduce the burden of having to re-check every individual. Care home managers can also decide to check more often if preferred, but there is no requirement to do so. Records should be checked regularly to ensure they are up to date. 
 
The registered person will be able to share these records with CQC to demonstrate they have checked 3rd party medical exemptions. 
 
The regulations expressly state that a care home may process information about vaccination or medical exemption status, but this must be done in a way that is consistent with data protection legislation. 
 
Exemptions: 
 
There are a range of circumstances in which an exemption may be granted which will reflect the Green Book on Immunisation against infectious disease (COVID-19: the green book, chapter 14a) and clinical advice from The Joint Committee of Vaccination and Immunisation (JCVI). 
 
There will be a clear process for staff to follow if they think they may have a clinical reason to be exempt. This process will be aligned with certification for domestic events, exemptions from self-isolation for confirmed contacts and travel. Guidance for certification is being developed and we will add a link to this guidance here as soon as it’s published. 
 
We will be producing separate guidance for clinicians, which will align with guidance for vaccine certification in other public settings. This guidance will help clinicians to verify exemptions. 
 
Support:
 
A range of resources is available to support registered persons and staff to have conversations about vaccine safety & efficacy, as well as financial support to access to vaccination. Please see the Introduction of the guidance. 
 
Skills for Care has developed a dedicated one-stop webpage that is bringing together a range of support, information and resources together to support social care employers to continue to recruit and retain their staff in a challenging environment. 
Resources include: 

  • workforce planning and commissioning

  • people performance management

  • supervision guide

  • wellbeing resources

  • values-based recruitment and retention resources

  • workforce productivity model
     

If you have any questions, please don’t hesitate to contact us.