Vaccinations: what you need to know

Before any vaccine can be administered, it must first be approved for use in the UK by the Medicines and Healthcare Products Regulatory Agency (MHRA). The MHRA is the independent licensing and regulatory body for the supply and use of medicines and medical devices.

The MHRA will only be approve a vaccine  for supply in the UK if the expected standards of safety, quality and efficacy are met.

All vaccines go through robust clinical trials, safety checks and quality controls. All vaccines are tested through three phases of clinical trials to ensure they meet strict standards.

Phase one trials are to test initial safety, phase two is to test the immune response (production of antibodies) to different doses; and phase three is to test very large numbers of human volunteers for safety and effectiveness in preventing disease.

There are extensive checks and balances required by law at every stage of the development of a vaccine.

The MHRA ensures that all the necessary safety checks are carried out. These decisions will be based on the evidence of vaccine trials involving very large numbers of people.

As with any medicine, vaccines are highly regulated products. There are checks at stage in the development and manufacturing process.

The UK has some of the highest safety standards in the world and the MHRA is globally recognised for requiring the highest standards for quality, safety and medicines regulation.

The NIHR (National Institute of Health Research) and UKRI (UK Research and Innovation) have invested heavily in the Research & Development of a COVID-19 vaccine; the NIHR has provided priority support through its Clinical Research Network to recruit to and facilitate the studies at pace.

Government bodies across the 4 UK nations are regularly updating their guidance and information for health and care professionals.

Please remember to check regularly for any new statements issued, as well as being aware of guidance from your employer.

The Department of Health and Social Care and Public Health England

Public Health England (PHE) have developed a suite of guidance aimed at supporting health and care professionals with the delivery of the COVID-19 vaccinations, which can be accessed here: https://www.gov.uk/health-and-social-care/health-protection-immunisation

In particular, PHE have issued new guidance in their Immunisation against infectious disease handbook, otherwise known as ‘the Green Book’ which provides further detail about the vaccines, the dosage and schedule across the UK and recommendations for the use of the vaccine.

PHE’s COVID-19 vaccination information for health and care practitioners also includes detailed information about the background of the program, vaccine recommendations and eligibility, and vaccine administration issues.

PHE guidance for health and care professionals about receiving the vaccines can be accessed here: https://www.gov.uk/government/publications/covid-19-vaccination-guide-for-healthcare-workers/covid-19-vaccination-guide-for-healthcare-workers

The Department of Health and Social Services and Public Health Wales

Further information about the COVID-19 vaccination programme in Wales can be found on Public Health Wales’ (PHW) website here: https://phw.nhs.wales/topics/immunisation-and-vaccines/covid-19-vaccination-information/

PHW have also developed a suite of resources specially for health and care professionals, which can be found here: https://phw.nhs.wales/topics/immunisation-and-vaccines/covid-19-vaccination-information/resources-for-health-and-social-care-professionals/

Health Protection Scotland

Latest information and resources by Health Protection Scotland can be found here: https://www.hcpc-uk.org/covid-19/keeping-up-to-date/

Department of Health (Northern Ireland) and the Public Health Agency

Further information about Northern Ireland’s vaccination programme, as well as detailed guidance for health and care workers can be found on the Public Health Agency’s website here: https://www.publichealth.hscni.net/covid-19-coronavirus

Vaccines are prescription-only medicines, so there are certain legal controls on who can and cannot prescribe, supply and administer these.

There are several ways the vaccine is being administered, and different professions can administer in different ways. If you want to administer the vaccine, it is important you check how the vaccine is being administered in your local area and your own profession’s rights.

The most common ways vaccines are administered is via Patient Group Directions (PGDs). This is an instruction from a prescriber to a named individual to give a certain medicine to a group of people. The following professions on our Register can currently administer via PGDs:

• Chiropodists / podiatrists
• Dietitians
• Occupational therapists
• Orthoptists
• Paramedics
• Physiotherapists
• Prosthetist / orthotists
• Radiographers (Diagnostic and Therapeutic)
• Speech and Language Therapists

Vaccines are also administered via Occupational Health Schemes. These are typically used to vaccinate employees at their place of work. Exemptions to the normal restrictions that apply mean certain professions can administer a vaccine much like a PGD - in accordance with the written and signed instructions of a doctor. In 2020, the law was changed to allow more professions to administer via Occupational Health Schemes. On our Register, these are:

• Paramedics
• Physiotherapists
• Operating Department Practitioners

Different UK governments have published National Protocols for the administration and delivery of  COVID-19 vaccines approved for use. These protocols allow for non-registered health professionals to administer the vaccine under the supervision of an experienced registered health professional. The protocol extends the rights of HCPC registrants to administer the vaccine even if they are not legally allowed to administer other prescription-only medicines under a PGD.

A copy of the protocols can be accessed here:

England

Scotland

Wales

The national protocols for England, Wales and Scotland break the process of delivering the vaccine into stages.

Under the protocol, registrants in England and Wales with the ability to administer under a PGD or an Occupational Health Scheme can undertake tasks in Stage 1 – assessment of service users, obtaining informed consent and otherwise giving advice to the service user.  Stage 2, preparation of the vaccine, may be carried out by all registrants provided that they are appropriately trained and competent, and are under the supervision of a Doctor, Nurse or Pharmacist. The administration of the vaccine is covered in Stage 3 which includes all HCPC registrants, as does Stage 4 relating to record keeping.

In Scotland, all registrants are eligible to undertake any stage of the process.

For further information and clarity about the process established under the National Protocol, you should take a look at NHSE’s guidance on accountability and delegation.  

No matter which stage of the process you are involved in or which legal mechanism (PGD, OHS or the protocol) you work under, you must only work within your scope of practice – see our information on this below.

National protocols have the power to grant non-registered professionals or students the ability to administer the vaccine.

Each of the UK four nations is responsible for determining whether or not students can be involved with the administration of the COVID-19 vaccine.

First, it is important you check you are legally entitled to administer the vaccine before undertaking this work. This will depend on what mechanism your employer is using to administer the vaccine. For example, are they using PGDs, occupational health schemes or the national protocol to administer the vaccine? Different professions can use these, so it’s important to check what route your employer is using and if you can use this. o understand your profession’s rights in law.

The next check is to see if this is within your scope of practice. Even if you are legally able to administer a vaccine, this doesn’t guarantee it is within your scope of practice. Any registrant administering a vaccine must ensure they have the skills, knowledge and experience to do this safely and effectively.

This is especially important with a new vaccine. You will need to understand how the vaccine works, likely side effects and the impact it has on certain vulnerabilities, so you can correctly advise your patients. Patients will need to give informed consent to their vaccination and may have questions about this. Registrants will therefore need to get further training and support from their employer in order to safely administer a COVID-19 vaccine.

You will also need to ensure that your professional indemnity arrangement covers you to administer vaccines. Most indemnity arrangements are provided by employers, so speak to them in the first instance.

Further information on the medical entitlements of our professions and PGDs can be found here. You may also wish to take a look at NICE’s website, which provides detailed guidance on PGDs, including training and competency.

As a health and care professional, you may be more likely to be exposed to certain viruses. Getting yourself vaccinated is therefore the best way to protect yourself, your family, colleagues and patients.

HCPC is supportive of vaccination campaigns and other public health initiatives, and regularly promote these on our website. However, the HCPC does not set vaccination requirements for its registrants. This will instead depend on the specific context you are working in and the service users you support. Therefore, this is normally determined by local policies set by employers.

While the HCPC does not set specific requirements for registrants to be vaccinated, registrants have personal responsibility towards patients and the wider public. Vaccination protects patients and the public, as well as registrants and their colleagues. All registrants should ensure that they meet their HCPC Standards at all times and follow local policies in place as set out by their employer

We have a number of Standards in place that are relevant in the context of COVID-19 vaccination. These standards reinforce the personal professional responsibility for ensuring the safe delivery of care and a safe working environment for colleagues. Our Standards of Proficiency set out the need for registrants to establish and maintain a safe practice environment; to maintain the safety of both service users and those involved in their care; and to select appropriate personal protective equipment and use it correctly.

Our Standards for Conduct Performance and Ethics require our registrants to take all reasonable steps to reduce the risk of harm to service users, carers and colleagues and not do anything, or allow someone else to do anything, which could put the health or safety of a service user, carer, or colleague at unacceptable risk.

If you have any questions about what vaccinations you will need for your role, we would advise you get in touch with your employer. If you are a student, you will need to speak to your education provider / practice placement provider.

HCPC’s Standards can be found here.

While the HCPC does not set specific requirements for registrants to be vaccinated, registrants have personal responsibility towards patients and the wider public. Vaccination protects patients and the public, as well as registrants and their colleagues. All registrants should ensure that they meet their HCPC Standards at all times and follow local policies in place as set out by their employer

We recognise that some registrants may be unable to receive certain vaccines, due to underlying health conditions. If that is the case, we would instead expect the registrant to put in place other appropriate measures to manage the risk posed to them, colleagues and service users. 

If you have good reason not to be vaccinated, you need to be confident that measures are in place where you work to manage any risk of transmission that your health may pose to service users, and you need to take appropriate steps yourself to reduce risks and prioritise safety.

Yes, the MHRA have considered this and decided that getting vaccinated is just as important for those who have already had COVID-19 as it is for those who haven’t.

The HCPC expects every professional on our Register to adhere to our Standards of conduct, performance and ethics. These set out our expectations for personal and professional behaviour. This includes being honest and making sure that their conduct justifies the public’s trust and confidence in them and their profession. Registrants must also ensure any promotional activities they are involved must be accurate and not likely to mislead.

If a concern was raised about a registrant’s conduct, we would assess this against our Standards. Where we receive a concern that a registrant may be spreading or communicating messages that may constitute misinformation, particularly where those communications may impact public health or undermine public health messages, we may look at these concerns under our fitness to practise processes. We will also consider the context that registrants are working in; please see our joint statement on regulating during the pandemic for more information.

HCPC regulates across the UK and all HCPC's Standards and guidance apply equally to registrants in England, Northern Ireland, Scotland and Wales.

While every fitness to practise concern we receive is considered on its own merits taking into account the context, the HCPC does not make Covid-19 vaccination status a condition of registration. Turning down Covid-19 vaccination, in itself, would therefore not be considered a fitness to practise matter by the HCPC. 

The HCPC continues to strongly encourage all our registrants to take up the vaccine, if they are able to do so.