HCAs can take ‘consent to proceed’ during vaccinations, says BMA amid UKHSA guidance concern
Healthcare support workers, including healthcare assistants (HCAs), are allowed to take the technical aspect of consent during vaccinations, the BMA has clarified, following concern around new UKHSA guidance.
GP practices were recently told to review their vaccination processes, after the UKHSA published updated guidance in June to specify that it is ‘outside the scope of practice’ of healthcare support workers (HCSWs) to ‘take informed consent’ for vaccinations.
GPs raised concerns that the clarification around informed consent will have a major impact on how practices deliver mass vaccination programmes.
Now the BMA’s GP committee has published new guidance on the requirements, and pointed out that the UKSHA clarification around the role of HCSWs ‘may not be in line’ with existing interpretation and could potentially ‘significantly impact’ upon the way in which practices design and deliver mass vaccinations programmes.
However, the GPC said that informed consent can be gained by a registered healthcare professional in advance of a vaccination clinic, and HCSWs may ‘check if patient well on the day’ and take ‘consent to the technical process of vaccination’.
They can seek agreement to administer a vaccine for which informed consent has already been gained by a specified registered healthcare professional, and this applies to HCSWs working under a national protocol for flu or COVID vaccines or where the vaccine has been prescribed.
The guidance added: ‘When operating under a Patient Specific Direction (PSD), the responsibility for seeking informed consent to vaccination lies with the prescriber i.e. registered healthcare professional.
‘This does not prevent a non-registered healthcare professional from administering vaccination and they can seek agreement to administer a vaccine (“consent to proceed”) where consent has already been obtained previously.’
It also pointed out that consent for immunisation can be broken down into two stages:
- Clinically consenting and agreeing to have the vaccination as a recommended procedure (i.e. reviewing the information provided, raising queries and having them answered, and consenting to the vaccination being performed) – this process should be done by a registered health professional
- Consent for the actual physical administration of the vaccine (“consent to proceed”) – this can be done by a HCSW
But these two stages ‘do not need to occur contemporaneously and in a co-located manner’.
The guidance added: ‘Those vaccinators undertaking Step 2 would need to confirm that the consent given in Step 1 was still valid, had been performed by a registered professional, and was appropriately documented in the patient notes prior to the vaccine administration.’
Leicester, Leicestershire and Rutland LMC has produced a step-by-step guide for practices to use AccuRx to collect consent in advance.
According to UKHSA, there is no requirement for consent to immunisation to be in writing, but it is ‘good clinical practice’ to record that a discussion has taken place and consent has been obtained.
Before beginning any treatment, healthcare workers should check that the patient still consents, and this is ‘particularly important’ if:
- a significant length of time has passed since the patient agreed to the treatment;
- there is new information available;
- there have been any significant changes to the patient’s condition; or
- the process of seeking consent had been delegated to a colleague.
Earlier this month, GPs practices in several areas of England were urged to check they are recording measles, mumps, rubella and varicella (MMRV) vaccinations correctly.
And a group of MPs said that the Government’s current vaccination strategy is ‘a failure’ and should be replaced with a new plan focusing on vaccination uptake in early years.
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