The updated consent wording from UKHSA has created significant uncertainty, particularly around the role of HCAs in vaccination clinics. This is a national discussion rather than a area-specific one, and at present there is no formal national clarification from NHSE or DHSC. The BMA is expected to publish guidance once they are able to secure a meaningful dialogue with the relevant national bodies.
In the meantime, a number of practices are exploring interim risk assessment approaches. Until clearer guidance is issued, our general steer is simply to ensure that any local process is documented, clinically robust, and defensible, given that we do not yet know how CQC will interpret this change.
As soon as there is authoritative national direction, we will share it with all practices.