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Vaccination as a Condition of Deployment (VCOD): new regulations for CQC registered services

From the 1st of April 2022, all staff and volunteers working in face-to-face service delivery roles will need to be fully vaccinated against COVID-19 to continue working or volunteering in CQC-registered health and social care settings. “The Vaccination as a Condition of Deployment (VCOD)” rules do not apply to those who are exempt on medical grounds.

To qualify as fully vaccinated, all staff and volunteers will need to have received their first dose of the vaccine by 3rd February 2022. Some individuals will need to have also received their booster dose of the vaccine. Everyone who is working in these settings will need to provide evidence of vaccination or exemption to continue in their role.

This new legislation will apply to all health and social care services that are regulated by the Care Quality Commission (CQC), which includes:

  • Care homes and hospices,
  • Children’s services,
  • Community and home services,
  • GP surgeries,
  • Mental health services, and more.

Examples of the types of CQC-registered activities include:

  • Personal care,
  • Accommodation for persons who require nursing or personal care,
  • Accommodation for persons who require treatment for substance misuse,
  • Assessment or medical treatment for persons detained under the Mental Health Act,
  • Transport services, triage, and medical advice provided remotely,
  • Maternity and midwifery services,
  • Services in slimming clinics,
  • Nursing care,
  • Family planning services and more.

More information on CQC-registered activities can be found here.


VCOD in the Voluntary Sector

For voluntary sector organisations delivering health and social care services, this may be a challenging time, particularly where there are inequalities in interest, uptake, and/or access to the vaccine. It is, therefore, a good idea for voluntary sector organisations to plan for any potential implications that the new regulations will bring to organisation management. NCVO has outlined all the key implications for volunteers, staff, and organisations in their blog post “Preparing for Vaccination as a Condition of Employment and Volunteering”. It also contains information on how organisations can plan and prepare for these changes to come into effect.

This post from NHS England, provides resources for engaging and communicating with staff to increase vaccination uptake where this appears to be low.

The NHS has also outlined the relevance of this legislation to the voluntary sector and the roles that may be affected.

Relevance for the VCSE sector:

  • VCOD applies to front-line workers, as well as non-clinical workers not directly involved in patient care but who nevertheless may have direct, face-to-face contact with Patients.
  • ‘Workers’ has a broad meaning here, including independent contractors, employees of subcontracted organisations, and volunteers.
  • VCOD applies regardless of the individual’s employer. It therefore affects staff and volunteers in VCSE sector organisations deployed in patient-facing CQC-regulated roles.
  • This includes where they are deployed in healthcare settings or provide advice or support for the purpose of carrying out a CQC-regulated activity. It applies regardless of how they are funded.

The roles in scope:

  • The individual is deployed for the provision of a CQC-regulated activity AND the individual will have face-to-face contact with patients or service users, including incidental contact.
  • Individual organisations are responsible for assessing which roles are in scope. If you are still unsure, you may wish to consider taking your own independent legal advice on your specific circumstances and contractual arrangements.
  • Responsibility of the CQC-registered person to ensure that they have systems and processes in place to evidence and monitor that all relevant ‘workers’ are fully vaccinated against COVID-19.

Click here for more information on VCOD from NHS England