The Government is proposing to make COVID-19 and flu vaccination a condition of deployment for health and social care workers, with the aim of protecting patients and others from harm. While we strongly agree with this aim, the Government has not provided adequate evidence of the proposed policy’s effectiveness, nor an evaluation of less intrusive measures, to justify mandating vaccination.
Before moving to a policy of mandating vaccination, the Government should thoroughly explore why some health and social care workers are not taking up the offer of a vaccine, and why there is variation in vaccine uptake across health and care settings and regions.
Vaccination uptake levels amongst health and social care workers are already high. According to the Government’s consultation document, for NHS Trusts, uptake rates vary from around 78% to 94% for both doses. In social care, 81% of domiciliary care staff and 75% of staff in other settings had received 1 dose of the vaccine as of 19 August. The consultation document implies that the intention is for all those deployed in providing direct care to be vaccinated. It will be important for stakeholders, not least health and social care staff themselves, to understand the justification for this objective and why the Government has opted for national-level interventions rather than targeted or regional approaches.
A recent study examining attitudes and behaviours among health and social care workers in the UK found that distrust in COVID-19 vaccination, healthcare providers, and policymakers are important factors influencing vaccine uptake. In addition, those who experienced employer pressure to get vaccinated felt this exacerbated their vaccine concerns and increased distrust. Mandating a vaccine is likely to have similar impacts, rather than address the concerns that health and social care workers have around COVID-19 vaccines. A full evaluation of why some people are still not taking up a vaccine, alongside an evaluation of the effectiveness of current measures in place, could help to identify the most effective ways to encourage uptake.
The policy has serious potential implications for staffing, given both health and social care workers are already in short supply heading into the busy winter period. Mandatory vaccination for care home workers comes into effect on 11 November and it is estimated that 7% of the care home workforce will choose to remain unvaccinated. If the policy is extended to other health and social care workers, many may choose to remain unvaccinated. Further reductions in staffing levels are likely to lead to significant disruptions to care which could affect patients in many ways. It will be important, for example, to consider how suddenly changing or losing a carer may impact patients and service users.
As we have seen throughout the pandemic, this will affect some people more than others. The Government acknowledges that Black health and social care workers and those who hold certain beliefs – religious and non-religious – may be more likely to feel unable to satisfy a statutory requirement to get vaccinated, which may ultimately result in them losing their job.
If further relevant or supporting evidence emerges as a result of this consultation, it will be important for the Government to set this out clearly, alongside the ethical considerations that have informed its judgements on this matter. If the evidence base remains weak, the Government should consider allowing more time to monitor the effects of making vaccination a condition of deployment in care homes before extending it to all health and care workers.
Danielle Hamm, Director of the Nuffield Council on Bioethics, said:
"We support the Government’s aim to increase vaccine uptake among health and social care workers in order to protect patients, service users, and co-workers from harm. All those working in health and social care should accept a primary responsibility to prevent avoidable harm to the people they care for. But we urge the Government to gather more evidence and explore other options more thoroughly before resorting to such a coercive approach.”
The Nuffield Council on Bioethics has submitted a response to the Government consultation highlighting these concerns. Our response draws on our previously published work on vaccine access and uptake, our in-depth inquiry into public health ethics, and a workshop held in May 2021 focusing on the proposal to make vaccination a condition of deployment for care home workers which informed the Council's response to the Government's consultation on this topic.
 Bell S et al. (2021) COVID-19 vaccination beliefs, attitudes, and behaviours among health and social care workers in the UK: a mixed-methods study MedRixv
 Department of Health and Social Care (11 July 2021) Statement of impact – The Health and Social Care Act 2008 (Regulated Activities) (Amendment) (Coronavirus) Regulations 2021, available at: https://www.gov.uk/government/consultations/making-vaccination-a-condition-of-deployment-in-older-adult-care-homes/outcome/statement-of-impact-the-health-and-social-care-act-2008-regulated-activities-amendment-coronavirus-regulations-2021