Managing risk when running a flu vaccination clinic offsite

Practices face a difficult task delivering flu immunisations this year. MDU medico-legal adviser Dr Kathryn Leask offers practical advice to those thinking of running a clinic in an alternative location.

(Photo: Getty Images)
(Photo: Getty Images)

Practices are well-versed in running flu vaccination clinics, but things will inevitably look a little different this year. For a start, it is more important than ever that patients, especially those who are particularly vulnerable, receive their vaccination.

The government has also expanded the criteria for patients who can be offered vaccinations this year.

Meanwhile, the coronavirus pandemic has led to changes in the way services are provided. Because of social distancing guidelines and the infection and prevention control measures that will be necessary, some practices are looking at alternative locations for providing flu vaccinations to patients.

If your practice is holding a flu vaccination clinic offsite, it’s important to consider how it will be run and how medico-legal risks will be managed.

CQC requirements

The CQC has recently published guidance that works through various examples and includes circumstances where clinics may be held at a location other than the practice.

Running a vaccination clinic from an existing practice or branch site, which is already listed in the conditions of registration with the CQC, does not require any further application or notification. However, clinics which are run from other sites or locations, such as a car park or local hall, will require you to inform the CQC that you are running the vaccination site as a satellite of your own practice. This will not in itself amount to a variance of your registration, however.

If you intend to work with other providers, such as a neighbouring practice, to deliver vaccinations to patients registered at both practices, it is the host practice where the vaccinations take place that will be responsible for carrying out the regulated activity and ensuring the quality and safety of the service.

The host practice which is already registered to carry out the vaccinations will not need to take further action. However, the practice using the host practice as a satellite will need to update their statement of purpose with the CQC.

Records and delegation

As well as ensuring you comply with the CQC’s guidance, there are other points to consider when carrying out a vaccination clinic in an offsite location.

For example, will the staff giving the vaccinations have access to the patient’s clinical records beforehand and how will records be kept if there is no access to the electronic record?

If you are delegating the task of administering vaccinations to other members of staff such as healthcare assistants or practice nurses, you must be satisfied that they have the knowledge, skills and experience to act in that role or that they will be adequately supervised, in line with GMC guidance on delegating.

Patient consent

As with any treatment the patient should provide their consent to having the vaccination unless you have reason to believe they lack mental capacity to make the decision at the time.

Older children should also be given all the necessary information they need to be able to provide their consent. As with all vaccinations, a person with parental responsibility should provide authority for young children who lack the capacity to provide their own consent.

It is important that patients understand in advance how the clinic will work and what to expect as this is unlikely to be similar any clinical situation they have experienced before.

Protecting patients' dignity

Patient dignity is another important consideration. If a patient were to become unwell during the vaccination, for example feeling faint or something more serious such as an anaphylactic reaction, where would they be treated? What facilities will be available in the absence of the usual practice treatment or consulting room?

Relevant equipment and medication will also need to be immediately available should a patient become unwell and staff present would need the competence and skill to provide the necessary care.

Learning lessons from the new arrangements

As with any change in practice it is important to reflect on what went well and what could have been done differently so that improvements can be made should any future clinics be held in this way.

If a clinical incident does occur, the practice should investigate this in the normal way, carrying out a significant event analysis and considering what lessons can be learnt and what action points may need to be addressed.

Any clinical negligence claim would be included in the Clinical Negligence Scheme for General Practice, and the MDU or your own medical defence organisation can also offer support with other medico-legal issues that commonly arise, such as responding to a complaint or adverse incident.

The MDU also has further guidance on the medico-legal considerations to running flu vaccination clinics here

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