The Clinical Guidance Document – Patient Immunisation has just been updated and there’s a question that often gets asked as there’s so much conflicting information in it – that is, what vaccines can an HCA or HCSW (Healthcare Support Worker) actually undertake?

Background

Firstly, I must point out that there’s little guidance on this from the top of our industry, and if there is, then it’s not easily located, so there seems to be no definitive answer. Therefore, Practice Index has gone to the CQC directly to ask whether they’d have an issue with HCAs vaccinating patients with other vaccines than those detailed in GP Mythbuster No 57.

The section I’m specifically referring to is:

“The RCN supports HCAs to administer specific vaccines to adults and the nasal influenza vaccine to children. This is only if they are appropriately trained and have the support of a registered health care professional.

“The RCN does not support HCAs administering other vaccines. These include the remainder of the childhood vaccination programme or travel vaccines. This is due to the clinical decision-making involved.” 

To back up the RCN’s stance, the following is mentioned in the 2015 PHE document titled National Minimum Standards and Core Curriculum for Immunisation Training of Healthcare Support Workers; at page 3 it states that this document:

“Sets out a recommended minimum framework for developing training to meet the needs of HCSWs administering influenza, shingles and pneumococcal vaccinations to adults and the live attenuated intranasal influenza vaccine to children.” 

So, does that intimate that HCAs or HCSWs can only give these four vaccines?

Another myth busted!

An important point that must be highlighted here is that the RCN does not, and cannot, enforce policy; therefore, this can only then be a recommendation in Mythbuster 57. Furthermore, the above PHE document is now several years old and, of course, is pre-pandemic, when it’s noted that nobody complained that an HCA should not vaccinate the millions of patients during the mass COVID-19 vaccination programme.

So where does this lead us?

The more useful GP Mythbuster 19 advises on governance arrangements when considering using a Patient Specific Direction. It states that the prescriber must deem the HCA or HCSW to be:

• Assessed as competent
• Having the necessary knowledge and skills, and
• Having been delegated the task, they may follow a PSD

Then it further states that:

“Some organisations may extend or limit those who are authorised to supply or administer medicines under a PSD. This must be documented in their local medicines policies and governance arrangements. 

“The practice has a duty of care to the patient and staff. They are responsible for making sure staff are properly trained and undertake only those responsibilities written in agreed job descriptions. If expecting non-regulated staff, for example healthcare assistants, to administer medicines, those delegating the duty must make sure these staff are competent to do so safely. 

“A locally approved procedure or guideline would support the safe administration of medicines by a suitably trained and competent healthcare professional.” 

So, in short, this states that once trained, deemed competent and supervised, the HCA can undertake a much wider spectrum of vaccinations provided that they can be supported by a PSD. But as this isn’t exactly what the above intimates, we put this to CQC senior management, and asked: as the regulator, would they have any issues with an HCA or HCSW vaccinating any patient with a vaccine that was not one of those above-mentioned four, provided that it met the above criteria as detailed in GP Mythbuster 19?

We’ve had confirmation from the CQC that this is perfectly acceptable.

Of course, ultimately, it’s down to each independent practice to manage what you deem to be acceptable for yourselves, but hopefully this helps to clear up much misconception and confusion.

The updated Clinical Guidance Document – Patient Immunisation [PLUS] details all this information and is available now to PLUS members This updated document provides an A-Z of adult and child immunisation requirements.

For further reading on PSDs, please refer to the Patient Specific Directions [PLUS]

Mat Phillips