COVID-19 Vaccination as a Condition of Deployment: RPC Opinion
RPC opinion on the The Health and Social Care Act 2008 Regulations 2021 - COVID-19 Vaccination as a Condition of Deployment in Health and Care providers
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The proposed regulations would make being double-vaccinated against Covid 19 a condition of deployment for all health and adult social care staff and volunteers who have face-to-face contact with patients and who are directly involved in patient care, as well as ancillary staff such as porters or receptionists who may have social contact with patients but are not directly involved in their care. This requirement will apply to all those deployed to undertake CQC-regulated activity in either the public (NHS) or independent health, domiciliary care, and other adult social care settings.
The Impact Assessment (IA) on these proposals has been rated NOT FIT FOR PURPOSE (red) on both the assessment of the equivalent net direct costs to business (EANDCB) and the small and micro-business assessment (Samba). Our opinion is based on a comparison with the levels of evidence provided in other IAs that we considered fit for purpose. The opinion also finds that the IA’s cost-benefit analysis, wider impacts and monitoring and evaluation plan were weak, but the discussion of rationale and options was satisfactory. The RPC does not comment on Government policy objectives and nothing in this opinion should be interpreted as a verdict on the Department’s policy choices or recommendations for public health measures.
The IA was submitted for RPC scrutiny after the draft regulations had been laid before Parliament. At the request of the Department, the RPC agreed to undertake an expedited scrutiny of the IA, and to issue an opinion on it, to assist parliamentary scrutiny of the draft regulations.
The IA and associated documents can be found here.
Following the publication of our not fit-for-purpose (Red) opinion, the Department has published a note setting out its initial consideration of the concerns that we have raised in the opinion and repeating some of the points from the IA that we commented on in our opinion. In the note, the Department has said that it will consider what further information could be added to an updated IA to improve the analysis provided.