VODG responds to consultation into stopping movement of staff between care settings

VODG has today (23 November) submitted a response to the Department of Health and Social Care’s consultation into stopping the movement of staff between care settings.

In the adult social care winter plan the government committed to new regulations to limit staff movement between care homes, and between care homes and other health and care settings in order to minimise the risk of coronavirus (COVID-19) infections.

The government is now proposing new regulations that would temporarily modify regulation 18 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, which would mean residential and nursing care home providers in England must restrict the movement of staff providing personal care or nursing care in their services.

The VODG submission included the following key points:

• The proposal lacks nuance, is too narrow in scope and seemingly aimed at larger care home services. A more suitable policy would be one that allows for movement within COVID-19 secure settings, including regular COVID-19 testing, and in adherence to PPE guidelines and robust risk assessments.
• The principles underpinning the consultation overlook smaller community services and will have a significant and detrimental impact on them, and as a direct consequence, the people they support.
• This proposal is impractical in that it fails to recognise the reality of how disabled people live their lives and use services e.g., the interconnectedness of social care and education.
• It will make staffing services much more difficult at a time when resources are already stretched. Reliance on agency staff is neither affordable nor practical.
• Providers of disability services are already implementing various measures to ensure settings and services are COVID-19 secure. Staff are already wearing full PPE and carrying out infection control procedures in line with government guidance. Many are already limiting workforce movement.
• Consideration should be given to allowing smaller registered homes and services to form a management or geographical ‘cluster’ whereby small staffing pools could be created to cover services.
• The ICF is not covering all costs and there are further concerns that the funding will come to an end during the critical winter period.
• For people with learning disabilities and autistic people who live in care homes, this policy could massively affect wellbeing.

Dr Rhidian Hughes, chief executive of VODG, said:

“This proposal provides yet another example of how government continues to overlook the full breadth of the social care sector and the diverse range of settings that exist outside of larger care homes.

“This policy could have a devastating impact on smaller care homes, such as those for people with people with a learning disability, autism, sensory and/or physical impairments in which as few as four or five people might be supported by a small staff team.

“Instead of regulating to restrict staff movement between care settings and potentially inhibiting continuity of care, a more suitable policy, for settings of all sizes, would be one that allows for movement within COVID-19 secure settings, including regular COVID-19 testing, and in adherence to robust PPE guidelines and risk assessments.”

VODG also called for the following actions from government:

• Publish an equalities impact statement in relation to the proposals.
• Set out the inter-dependencies of the proposals for people who use social care, across children and adults services, and for people who directly employ their own staff.
• Include guidance within the policy as to what assessments will be undertaken by government to determine the cessation of these restrictions.
• The ICF to be maintained and increased in order to support providers through the winter period and until COVID-19 pressures begin to ease.