HCA Competency Standards
We have received a number of queries from practices where HCAs have been informed they must have an NVQ level 3 or equivalent qualification to enable them to be able to give flu vaccinations.
This we believe is based on the HCSW Training Standards document 2015 which is attached for information and states on page 6 that:
“It is recommended that only HCSWs who have achieved education and training to Level Three of the Qualifications and Credit Framework (QCF)4 or equivalent in England and Wales with at least 2 years’ experience as a HCSW should be considered for training in vaccine administration”.
Please note this is national guidance and is a recommendation only therefore the responsibility lies ultimately with the practice to make sure you keep patients and staff safe.
Fundamentally it is important that if anything untoward happened in your practice, the Partners could stand in front of a Coroner or Judge and justify that the training they had provided for their staff was sufficient to ensure they were competent, and confident to undertake the task given to them.
We have also clarified with the Clinical Negligence Scheme for General Practice whether staff would be indemnified to provide flu vaccinations if they have not undertaken the training as recommended, please see their response below:
Cover under the Clinical Negligence Scheme for General Practice (CNSGP) is linked to the form of contract that the services are provided under. It covers activities which are commissioned under a GMS, PMS or APMS contract or under a contract for the provision of enhanced primary care under Schedule 2L of the NHS Standard Contract (each a “Primary Care Contract”). Cover also extends to services that are delivered under a direct sub-contract to a Primary Care Contract. In either case, anyone engaged as a HCA by an organisation which holds a Primary Care Contract or direct sub-contract who delivers care under that contract will receive cover under CNSGP. If you are covered in this way HCA’s will receive cover for clinical negligence regardless of the qualifications they hold.
Please note, as set out on the NHS Resolution website, CNSGP does not cover Occupational Health tests/injections (including flu injections) arranged by a GP practice/contractor to staff for the purposes of their employment.
Irrespective of the arrangements for indemnity cover, it is for practices to ensure that their staff are competent and provide safe, effective care. The practice is not covered by CNSGP for support in relation to any investigations carried out by regulators such as the Care Quality Commission or General Medical Council. CNSGP provides cover for clinical negligence liabilities. Even if you are covered by CNSGP, you may want to consider whether alternative indemnity arrangements are required in relation to other risks or liabilities that may arise, e.g. fitness to practise investigations, and inquests.
Further information on the scope of cover of CNSGP can be found on our webpage which is being regularly updated - https://resolution.nhs.uk/services/claims-management/clinical-schemes/clinical-negligence-scheme-for-general-practice/
In summary HCAs who have not undertaken a NVQ level 3 or equivalent are able to give flu vaccinations, as long as the practice has provided sufficient training, deemed them competent to do so and provides clinical supervision to undertake these. They will also be indemnified to give flu vaccinations under the CNSGP scheme.