Government guidance on Coronavirus changes frequently and it is important to ensure that your policies are up to date and in line with the latest guidance. The guidance should be considered in the context of your own service and your policies should be flexible, reviewed and updated regularly.
I have referred to eight examples of specific coronavirus policies that you might want to introduce, this list is not exhaustive and there are other areas you may want to consider. It would be sensible to append coronavirus polices to your existing ones as this will act as evidence to show that you have considered government guidance.
Coronavirus policies and potential areas each policy should consider:
- Infection prevention control
- Enhanced cleaning schedule
- Staff hand washing
- Isolation of service users with Covid-19
- Admissions policy – suspected or confirmed cases of service users being admitted to the service
- Testing for care workers with Covid-19 symptoms
- Testing for service users with Covid-19 symptoms
- Covid-19 related staff training
- Visitors
- Service users’ contact with family members – methods and frequency of enabled people to stay in contact with family and friends
- Health and safety risks
- Social distancing
- Environment – for example, visits taking place in well ventilated parts of the service
- PPE – whether it is deemed necessary and if so why/ why not?
- Medicine management
- Medicines in stock – sufficient quantities and controlled drugs as stock, future supply of medicines
- The re-use of medicines in care homes
- Inappropriate use of sedative medicines to enforce social distancing guidelines
- Delegating medicines administration
- Community pharmacy contacts – medicines awaiting return to community pharmacy
- PPE
- Access and availability to it – PPE supplies and information
- Staff training & guidance on using PPE
- PPE risk assessments for staff
- PPE risk assessments for service users
- Social distancing
- Challenges in relation to social distancing and practical ways that social distancing can be implemented
- Supporting service users who lack capacity with social distancing
- Inappropriate use of sedative medicines to enforce social distancing guidelines
- Updated staff handbook to take into account coronavirus related issues
- Staff reporting of their own coronavirus symptoms or a family members
- Complaints & whistleblowing – are staff able to raise concerns and what are the channels for doing this?
- Staff wellbeing – details about what support is available for employees
- Staff engagement
- How the service is proactively supporting staff who may be at increased risk of getting COVID-19
- The Mental Capacity Act 2005 and the Deprivation of Liberty Safeguards
On 4 May 2020, Mr Justice Hayden said that “there has been a striking and troubling drop in the number of Section 21A (MCA 2005) applications which has occurred, in some areas, alongside a significant reduction in referrals to advocacy services.” A coronavirus policy in relation to the MCA 2005 and DoLs should include:
- The continuing application of the fundamental principles of the Mental Capacity Act 2005
- DoLS and existing authorisations – Most changes to a person’s care or treatment during the pandemic period would not constitute a new or changed deprivation of liberty. However, a review may be necessary in order to decide if a new authorisation is needed to replace the existing one.
- DoLS and appropriate authorisations – consider the acid test: ‘is the person subject to continuous supervision and control?’ and ‘Is the person free to leave?’ Decisions about mental capacity and DoLS must be taken specifically for that person and not for groups of people
- Mental capacity assessments being undertaken remotely
- Impacts of the Coronavirus Act 2020 – deciding whether to use the MCA 2005 or public health powers to lawfully restrict a person’s movements
- Contact details for local health protection teams
- Staffing arrangements
- Suitable and sufficient numbers – plans for responding to unforeseen and critical staff shortages
- Agency use – comprehensive inductions for new staff
- Recruitment
- Staff training
Conclusion
Having specific coronavirus related policies, is a clear way to ensure that a service has effective assurances processes in place. Specific policies showing what dates policies have been updated and which government guidance has been considered will be crucial in terms of retrospective regulatory scrutiny, when we enter the “new normal” and when CQC resumes routine inspections.
