Extension of compulsory vaccinations – our consultation response

The Department of Health and Social Care (DHSC) has been consulting on whether or not the government should extend the existing statutory requirement for those working or volunteering in a care home to be vaccinated against coronavirus as a condition of deployment to other health and social care settings.

The consultation sets out that ‘a requirement to be vaccinated would apply to all those that are deployed to undertake direct treatment or personal care as part of a Care Quality Commission (CQC) regulated activity’. It also seeks views on whether professionals and volunteers who do not directly undertake treatment or personal care should be included in the scope of the proposed policy.

We have consulted with a wide range of our members to form a sector-wide response to this consultation. Whilst there are a range of opinions amongst our membership, the majority of respondents to our call for organisations’ position on this consultation are in favour of the proposal to extend compulsory vaccinations as a condition of deployment to health and wider social care settings including domiciliary care services. In order to convey the view of the housing association sector as a whole, however, rather than responding to the consultation’s questionnaire, we have written to DHSC to ask that they take into account the range of views that exist on this matter.

In our letter we ask the government to consider the following factors:

Time to measure impact

• Some members are concerned that there has not yet been enough time to measure the impact of the compulsory vaccination requirement for care homes. In light of this, the government might consider delaying the proposed requirement until it becomes clearer that wider social care settings are going to be able to manage the challenge of delivering it.

Guidance

• Members identified a need for clear guidance around the systems of proof of vaccination amongst both staff and volunteers delivering care directly, and especially for external personnel entering the affected settings, such as cleaners and maintenance staff, if they are to be included in the scope of the requirement.

Impact and implications

• The most significant reservation that members have around the proposed extension of compulsory vaccinations to wider social care settings is the detrimental impact it may have on an already acute staffing crisis.
• There is an additional layer of complication for those members who are landlords providing housing within which CQC-regulated care and support services are delivered. This is because in these settings, residents have a tenancy or licence to occupy their own property and so will ultimately have control over who enters their home, regardless of the providers’ rules governing the building as a whole.

Our letter also includes our recommendations which take into account the variety of opinions our members shared:

• We feel that waiting to get to a stage where the effects of the 11 November deadline for care home vaccination can be assessed before extending the requirement is a sensible approach.
• If the proposal is introduced, then we recommend that compulsion is not extended to staff in extra care and supported living settings, other than those who are delivering CQC registered care services.
• We recommend clearly stating a uniform method of proof of vaccination and providing clear guidance around the exact scope of the requirement.
• Lastly, we ask that the government carefully factor in the wider pressures facing the social housing and social care sector at present while considering the outcome of this consultation.