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No Deal Brexit Guidance
As we move towards March 29th the date agreed for the UK to leave the EU, there are uncertainties about the impact Brexit will have. In terms of being practical however, whilst we can’t predict what will happen on or after March 29th, Health and Social Care providers need to ensure they continue to comply with legal requirements under the Health and Social Care Act 2012 and have robust business continuity plans in place. This QCS guidance document is to support providers to continue to achieve compliance.
The Department of Health and Social Care (DHSC) published on 21st December EU Exit Operational Readiness Guidance: Actions the Health and Care system in England should take to prepare for a ‘no deal’ scenario with a supporting cover letter. This is a good reference starting point and although the action cards in the document relate to GPs, Dentists and NHS providers, it is still relevant to providers managing Care Homes, Nursing Homes and Domiciliary Care and Supported Living Services. The following are areas that providers should review;
EU Exit Organisational Responsible Individual
Social Care providers should consider identifying someone in the business who can lead on the organisation’s EU Exit preparation. This responsible person should be senior enough to make decisions and recommendations to the board or senior leadership team. For providers running NHS services you will need to review the action cards in the Government Readiness Guidance as this clearly states the level of seniority within the business the RI will need and the activities, including any future reporting, that they will need to undertake.
Review the Business Continuity Plan (BCP).
Providers should aim to have reviewed the risks associated with an EU Exit by the end of January 2019. The risk assessment and BCP should review the key areas identified nationally (they may not all apply to social care but should be assessed). Any additional demands to services or disruptions should also be considered as should any locally assessed risks. The QCS Business Continuity Plan Policy and Procedure has a template that you can adapt to meet your local needs and your services.
Providers should work with local partners to review their plan, this will include Health and Local Authorities. Its important to think about access to premises and continuity of services in the event of any civil disturbances or transport issues. For providers working with CCGs and NHS England, it’s important to agree how communication will be handled. For social care providers, Local Authorities will be involved in ensuring robust contingency plans are in place and early communication is important. Managers should ensure that staff understand what is happening and support is provided to service users who may be concerned.
Test the Plans
Providers should test these plans by the end of February at the latest to ensure they are fit for purpose. Any changes to the plan should be made and communicated to staff and any partners working with your services.
The government had advised that there is no need to stock pile medicines and service users should be assured that the government has put contingency plans in place to ensure that pharmacies will have enough medications in the months after March 29th.
It is important that you are aware who needs support with ordering medication and make sure service users have their usual supply of medication so that medication can be administered as planned, this should be no different to your usual processes. please refer to the QCS suite of Medication Management Policies to ensure your teams are aware of what your organisational procedures are.
Medical Devices and Clinical Consumables
The same applies to medical devices as it does to medication. The DHSC advice is again that there is no need to stockpile but your risk assessment as part of your BCP review should consider where supplies are coming from and that the usual ordering and maintenance regime should be maintained. Provider should closely follow any communications from the DHSC in case there are any change to advice on this. The Distribution Of Safety Alerts Broadcasts, Rapid Response Reporting And Safety Notices Policy and the Management of Medical devices in the QCS system are useful document to review.
For social care providers the impact of the EU Exit is possibly one of the most concerning. Providers should assess the number of EU nationals in the workforce and publicise the EU Settlement Scheme to the team. Business continuity plans should factor in shortfall of EU nationals in addition to any existing plans for workforce shortfalls. The EU settlement scheme will be fully open by March 2019 and the Government has toolkits to support the publicising of the scheme. There is a cost associated with the EU settlement scheme and provider may want to consider if they wish to pay this for their employees to aid retention of staff.
The BCP should consider any services that might be vulnerable if there is a shortfall in staff and there should be good communication with commissioners to notify them of any concerns about business continuity because of workforce shortfalls.
The DHSC advise that providers review capacity in terms of annual leave and on call arrangements around 29th March. Consideration should be given to escalation procedures in the event the business continuity plan has to be activated.
The government website has more information on this and the link can be found here. QCS is working with our employment law team to ensure any amendments to existing policies are made
Data Sharing, Processing and Access
Providers should follow advice from the ICO on a ‘no deal’ scenario and should examine how reliant the business is on transfers of personal data from the EU. The requirement to comply with Data Protection laws and GDPR will still be necessary post 29th March so providers working with the NHS should make sure they undertake the self-audit of compliance by undertaking the annual Data Security and Protection Toolkit assessment. It should be completed by the end of March but given the exit date, completing it early will ensure any issues can be flagged and rectified promptly. There are potentially also contractual clause changes required for providers who transfer data from the EU to the UK and providers who believe this applies to them should check out the ICO site and seek further advice. QCS have a wide range of policies and procedures on GDPR and Data Protection to support compliance in this area which can be found under the GDPR in the Policy Centre.
Recognition of Professional Qualifications
This is a communication exercise, inform your staff that health and care professionals including UK citizens whose qualifications have been recognised and who are registered before 23:00 on 29 March 2019, that they will continue to be registered after this point.
Staff who apply to have their qualification recognised in the UK before 23:00 on 29 March 2019 will have their application concluded under current arrangements.
There is no decision from the Government yet on future arrangements for health and care professionals with an EU/EEA or Swiss qualification who apply to have the qualification recognised after 23:00 on 29 March 2019.
Review Policies and Procedures and processes
As we head towards a period of uncertainty, having robust policies, procedures and processes in place are critical. They provide a stable framework for staff to work within and set organisational standards. Whatever happens after 29th March, providers will continue to need to comply with the Health and Social Care Act and evidence how they meet the 5 Key questions.
Changes to policies and procedures are going to be inevitable either leading up to the EU Exit date or after. It’s important therefore for providers to constantly horizon scan and keep up to date not only nationally but locally too. Service users will still need a safe and compliant service with organisations ensuring continuity of care is maintained whatever happens on 29th March. QCS will aim to keep you up to date with any changes to policy and our subject knowledge specialists are supporting with ensuring the content reflects the fast pace of change.
*All information is correct at the time of publishing