VODG submits response to government consultation on mandatory vaccination

VODG has today submitted a response to the Department of Health and Social Care consultation on making COVID-19 vaccination a condition of deployment in older adult care homes.

The government is proposing to amend the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, to require older adult care home providers to deploy only those workers who have received their COVID-19 vaccination in line with government guidance. The proposal excludes those who can provide evidence of a medical exemption.

The proposed regulations would apply to any care home which has at least one person over the age of 65 living in their home in England and which is registered with the Care Quality Commission.

The VODG submission, which was informed by engagement with our member organisations, includes the following key points:

• As an infrastructure body, VODG sought to highlight the collective voice of multiple organisations and represent the full breadth of views put forward by members. Engagement with our members on this issue showed a fairly split consensus of support.
• VODG welcomes any move that strengthens safety in the sector so long as it is proportionate to the risks and does not curtail individuals’ freedoms. Policy also needs to reflect an in-depth insight and understanding of the breadth and scope of the social care sector, in tandem with what we are being told by scientists about the efficacy of the COVID-19 vaccine, individual and collective behaviour and its impact on transmission rates.
• Providers of social care services fully recognise their duty of care to the people they support (and those people’s families) but that this is a complex issue fraught with risk and the proposals could be divisive and damaging to the social care workforce and consequently to the people the workforce supports.
• Since the onset of the pandemic and before the introduction of the COVID-19 vaccine, providers have been implementing infection control measures to ensure their settings and services are COVID-19 secure. This is alongside regular COVID-19 testing and robust risk assessments.
• Many providers have been focussing on a ‘hearts and minds’ approach to encourage the uptake of the vaccine, which has been felt to be a safer, consistent and less contentious route. However, for other providers, particularly those with more vaccine-hesitant staff members, the proposal is seen as part of the overall mosaic of keeping people safe and a mandatory regulation would mean all the parts come together.
• The government could increase support for this proposal by presenting more robust facts to explain the science behind the proposal, particularly around the impact this proposal would have on transmission rates as well as the risks of transmission if this proposal is not implemented.
• Additional transparency is needed as to why this proposal would be implemented in older people’s services when there are arguably equivalent risks in some working age disabled adults, particularly those with co-morbidities, complex needs, and challenges with social distancing and the wearing of PPE.

Dr Rhidian Hughes, Chief Executive of VODG, said:

“Despite the roll out of the COVID-19 vaccination programme, the situation with the pandemic is still very precarious, particularly as new variants arise and concerns remain around increased infection rates.

“VODG welcomes the opportunity to put forward the views of members as part of the consultation process. However, while the proposal in itself has invited a fairly split consensus of support among our members with whom we consulted, it is agreed there is a lack of detail about how this proposal would be implemented and enforced as well as the practical considerations of its roll out. These are also ethical professional issues which government has a responsibility to address if it chooses to pursue mandatory approaches.

“Detail on the future outlook for this proposal is also missing, further reinforcing government’s ‘short-term, quick-fix’ approach to the social care sector in its attempt to be seen to be doing the right thing. The omission of any significant forward planning is concerning when the proposal has the potential to have a significant, and possibly detrimental, impact on the sector.

“While VODG supports any move that strengthens safety in the sector, the risk of transmission in residential or close contact settings is an issue not just for older people’s care homes. To target social care, and then only part of the sector, especially without additional investment to support organisations to roll out this proposal while maintaining safe and adequate levels of care is questionable. As such the proposals risks being very difficult, and costly, to implement.”