Brian Caldwell-White, Case Manager at Medical Protection, and Dr Emma Davies, Medicolegal Consultant at Medical Protection, look at the various considerations when controlling risk during this year’s flu vaccination programme 

Managing this year’s influenza vaccination programme, while keeping patients and staff as safe as possible, is a challenge for many practices. Some options include drive-through clinics – similar to the COVID-19 testing stations – and using alternative sites such as village halls, to reduce the number of patients coming to the practice premises.

Making changes to the provision of a service is a business decision and we would not endorse a particular way of working over another. However, we are able to offer some general guidance on what to consider when making plans for this season’s flu clinics.

Health and safety

As there is a risk that a patient being given a flu vaccination may have an allergic reaction or syncopal episode, you will need to ensure that the clinics are staffed with providers who are able to detect the signs and symptoms, and treat any adverse events.

It is also crucial to ensure that medical records are available to those clinicians involved and that all the necessary equipment, such as emergency resuscitation equipment, is readily available. Other questions to ask are:

• Are the premises fit for purpose?
• Are they clean?
• Are there trip hazards?
• Are they accessible to those with disabilities?

In addition, there is some jurisdiction-specific guidance, as follows:

England

According to the NHS General Medical Services Directions there are a number of issues that practices need to consider.[i] There are contractual and statutory standards with which practices should comply.

You should approach the British Medical Association (BMA) for advice, as well as the Local Medical Committee (LMC) or local area team of the Clinical Commissioning Group (CCG) regarding this matter, and keep abreast of the latest developments in the 2020/2021 flu vaccination programme given by the Department of Health & Social Care (DHSC) and Public Health England (PHE); the latest updates on how to prepare for the 2020/2021 flu season, considering COVID-19, can be found on the NHS England website.[ii]

Wales

According to the Primary Medical Services (Enhanced Services) (Wales) Directions there are a number of issues that practices need to consider.[iii] There are contractual and statutory standards with which practices should comply.

You should approach the British Medical Association Welsh Council (BMA) for advice, as well as the relevant Welsh Local Medical Committee (LMC) or local area team of the Clinical Commissioning Group (CCG) regarding this matter, and follow the latest developments in the 2020/2021 flu vaccination programme given by the Department of Health & Social Care (DHSC) and Public Health Wales (PHW).[iv]

Scotland

Practices may wish to review the National Health Service (General Medical Services Contracts) (Scotland) Regulations 2018, as there are a number of issues to consider. Of particular relevance is Schedule 3, which outlines the Minimum Standards for Practice Premises.[v]

You should approach the British Medical Association (BMA) or your Local Medical Committee (LMC) for further advice and guidance on the issue. The latest developments in the 2020/2021 flu vaccination programme are available on the Health Protection Scotland (HPS) website.[vi]

Northern Ireland

You should investigate the Health and Personal Social Services (General Medical Services Contracts) Regulations (Northern Ireland) 2004 for guidance. According to General Medical Services Contracts Regulations (Northern Ireland) 2004, there are a number of issues practices will need to consider.[vii]

You can approach the British Medical Association (Northern Ireland Council) (BMA) and your Northern Ireland Local Medical Committee (NILMC) for further advice and guidance on the issue. Practices can keep abreast of the latest developments in the 2020/2021 flu vaccination programme from the Public Health Agency.[viii]

Patient information

It will be important to make it extremely clear to patients that your flu campaign will be run from different premises to ensure that they attend the correct location. Should this not be made clear, it is possible that complaints may arise.

Patient dignity

Are the alternative premises able to preserve patient dignity and modesty? If you are providing a drive-through service this may be more difficult to achieve without careful planning.

Patient accessibility

It would be worth ensuring, if you are considering a drive-through alternative, that provisions for alternative ways of vaccinating certain groups of patients (for example, disabled patients, non-vehicle owners) are put in place, and it is made clear to these groups that contingency plans are in place.

Planning permission/contractual requirements

Consideration should be given about whether the intended location that a practice is planning to utilise is suitable for its required purpose. The Health Board premises team may be a useful source of information in confirming this. Practices will also need to consider if this will be a temporary leasing of the proposed site, or a more permanent spread across two locations. It is important to ensure that these additional premises have public liability insurance cover in place. 

Indemnity advice for practices in Scotland and Northern Ireland

It is important that practices ensure that they have appropriate indemnity arrangements for all staff undertaking vaccinations. In addition, if vaccinations are to be undertaken off-site, then it is essential that Health Board approval is sought and obtained. Provided such approval has been obtained, the practice and clinicians would be entitled to seek help from Medical Protection, in the event of any matters arising. 

Every employee administering the vaccine should be appropriately trained and competent to do so and, where applicable, acting in accordance with delegated authority under the terms of a patient specific or patient group direction.

Practices involved in administering vaccinations should ensure protocols are in place covering:

•           Written instructions

•           Training of staff involved in administering the vaccine

•           Vaccine dispensing and ‘cold chain’ transport

•           Obtaining valid consent

•           Dealing with any complications including anaphylaxis

•           Record keeping

Indemnity advice for practices in England and Wales

Where a vaccination is administered as part of NHS contracted clinical activity, Medical Protection would normally expect this to be indemnified under the Clinical Negligence Scheme for General Practitioners (CNSGP). Practices may wish to seek confirmation from NHS Resolution that they would indeed be indemnified for undertaking this work at a site other than the practice’s usual premises. Members would be able to approach Medical Protection for any non-claim issues arising from this work (such as complaints, for example).

If the practice provides vaccinations that are not part of an NHS contracted clinical activity, such as vaccinating staff, this has previously fallen outside the scope of CNSGP indemnity. Medical Protection members providing this service, provided they are appropriately trained and competent to perform this activity, need to ensure they are in the correct category of membership if they wish to seek assistance with matters arising from this activity.

Those members of practices holding membership with Medical Protection that includes indemnity for claims arising from acts/omissions of employees acting in the course of their employment can also look to us for assistance. As ever, the employee administering the vaccine should be appropriately trained and competent to do so and, where applicable, acting in accordance with delegated authority under the terms of a patient specific or patient group direction.

Practices involved in administering vaccinations should ensure protocols are in place covering:

•           Written instructions

•           Training of staff involved in administering the vaccine

•           Vaccine dispensing and ‘cold chain’ transport

•           Obtaining valid consent

•           Dealing with any complications including anaphylaxis

•           Record keeping