The challenges for our clients and ourselves as a provider and staffing agency have certainly been extreme this year as we have had to adapt our working arrangements in order to limit the spread of infection and keep our staff and the individuals, we support safe. We have always had stringent infection control policies, processes and staff training in place, but of course these have needed to be strengthened and adapted this year in line with the ever-changing guidance which has been issued for the health and social care sector.
As a CQC regulated provider of services in our own right we have faced the same challenges as many of our clients and have been able to use our knowledge of the guidance to ensure that our agency workers have been equipped to meet the challenges in the same way as regulated workers. We set up a Coronavirus Information Hub on our website early in the pandemic and used this to keep our clients and staff on top of the latest changes to guidance and to offer one place to find all the up-to-date requirements at a time when things were changing almost daily.
We are familiar with the provisions of the ASC Winter Plan and the proposals to amend Regulation 18 of the Health and Social Care Act to limit the movement of staff between settings. We contributed to the November consultation on the subject from the viewpoint both of a service provider and also a supplier of temporary staffing. While the benefits to the control of infection with these limits is clear, we are also aware of the reality for providers and the challenges that their implementation will impose. We suggested a number of potential actions which would enable staffing agencies to assist providers rather than the current proposals which mean that agency workers are excluded except with specific exemptions. We proposed the availability of asymptomatic weekly testing for agency workers as a potential solution, which puts them on an equal footing with other workers and allows them to become part of a solution for providers with staffing challenges. We have also communicated with all of our clients offering the guaranteed exclusivity of agency workers to their services only by working together to find solutions that make this work, whether that is working together on the service deployment as a whole, or using the Winter Infection Control Fund to block book preferred staff. This is working well for some clients, and we have systems in place utilising exclusions on our booking software that ensure these staff cannot be placed elsewhere, as well as signed agreements with staff and clients which detail the arrangements in place.
In relation to the asymptomatic testing of agency care staff this is an area which we have, along with our trade body the Recruitment and Employment Confederation, been lobbying for as so far, they have been excluded from accessing these tests in a regular planned way. Some ENS staff have access to regular testing as they work within our CQC regulated supported living or domiciliary care services and we also have many agency workers who we have been able to place exclusively within one client service, and these staff are tested as part of the regular weekly client testing regime, however this does not account for every care worker. We have been in regular contact with all agency workers throughout the current pandemic in terms of the requirements for self-isolation and getting tested if symptomatic. This has been via the information hub on our website, social media posts, regular email updates as requirements have changed, and encouraging our workers to download the Care Workforce app from DHSC as a source of reference.
Our Coldharbour staff and booking database is used to record information regarding those staff who have been tested or been required to self-isolate and we can exclude them from being placed into work during this period. The system also allows us to very quickly trace the historic movements of an agency worker should we be made aware that they have tested positive or been in contact with a positive case, and in this way, we can follow correct reporting procedures and ensure that any clients are informed if there has been a potential risk to their service.
Going forward, we now have access to vaccinations for all of our agency workers and are using our database to record the vaccination dates and status for workers. We can share this information with our clients going forward should it become a requirement that agency staff are vaccinated before being accepted into a service.
We have been speaking with our clients on a regular basis and reminding them of the need to inform us should they have positive cases within their services in order that we can update our records and ensure staff are aware of the current situation and any additional infection control or PPE requirements before they attend their shift.
Our infection prevention control processes, delivery and monitoring are in line with all required legislation and good practice guidance, in particular the 10 criteria set out in the “Code of Practice for Health & Social Care on the Prevention and Control of Infections and Related Guidance”. The Health and Social Care Act 2008 (Regulations 2014) require that we consider this guidance as a CQC registered provider. In addition, since early 2020 when the Coronavirus pandemic was declared, we have been revising, updating and supplementing our existing policies and procedures with Public Health England, NHS and DHSC guidance regarding working safely and Covid-19 infection control measures. We have put in place a Covid-19 Business Continuity Plan.
We have a robust Covid-19 Risk Assessment document in place which has been shared with our workers on a regular basis and as changes have occurred. This details all the different risks associated with the spread of infection, and the controls and risk mitigations we have put in place to keep them, and the people they are supporting, safe. We have ensured that our office-based staff have been kept up to date with the guidance as well in order that they can provide the correct advice to our workers. We have an overarching “Infection Prevention and Control” policy which contains our aims, legislative framework, governance procedures and process overviews – these processes are then expanded upon in separate policy documents.
The below is a definitive list of all the Infection Prevention and Control policies we have in place: Food Safety / MRSA / Protective Clothing & Equipment / Dress Code / RIDDOR / Aseptic Technique / Clostridium Difficile / Handwashing / Isolation Nursing / Rotavirus and Norovirus / COSHH / Disposal of Sharps / Needlestick Injuries / Clinical Waste / Cleaning of Spillages. We ensure that these processes are delivered by having in place a robust training and competency assessment plan to ensure that all our staff are aware of the importance we place on effective infection prevention and control as the cornerstone of the safe delivery of care. We emphasise handwashing as the single most important infection control measure. Every ENS staff member must complete and pass an “Infection Prevention and Control” training course before commencing employment and this is refreshed regularly thereafter. The course covers the principles of IP&C, routes of infection, microorganisms, chain of infection, standard precautions (personal health & hygiene, hand hygiene, PPE, cleaning and sanitising, safe disposal) and legislation and guidance.
Our practical training competency assessments for clinical procedures all require staff to demonstrate an understanding of the infection control issues applicable and measures to be taken to reduce risk. We have provided staff with additional Covid-19 training resources to supplement our standard IP&C training, including updates to PPE guidance, social distancing, testing and self-isolation processes and PPE donning and doffing guidance videos.
We will continue to work closely with clients to ensure that we are finding solutions that ensure we can continue to provide temporary staffing solutions in a way that is safe and gives confidence that our agency workers are following all required procedures, whether this is changing clothes on arrival and departure, or wearing a client uniform – all of these can be accommodated. We can adapt our processes to ensure that any information regarding client protocols and policies, and individual service procedures, are recorded and shared in a timely way with all ENS agency workers.
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