Update: Vaccination as a condition of deployment (VCOD) for all healthcare workers – Phase 2



Classification: Official

Publication approval reference: C1546


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14 January 2022

Dear colleague

On 6 January 2022, the Government made new legislation, approved by Parliament, which amended the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (“the 2014 Regulations”). As you will be aware, in accordance with these regulations, individuals undertaking CQC regulated activities in England must be fully vaccinated against COVID-19 no later than 1 April 2022 to protect patients, regardless of their employer, including secondary and primary care. The regulations will apply equally across the public (NHS) and independent health sector.

A 12-week grace period, beginning on 6 January, allows unvaccinated individuals to have had their first dose by 3 February 2022, in order to have received their second dose by the 1 April 2022 deadline.

Diagram showing deadlines between January and April 2022 for vaccination as a condition of deployment

Guidance for HRDs and organisations

Since the Department of Health and Social Care (DHSC) first made their announcement on 9 November 2021, NHS England and NHS Improvement has written to the system (10 Nov letter, 6 Dec letter) and has engaged with DHSC, NHS Employers, Social Partnership Forum and wider stakeholders to develop Phase 1 Planning and Preparation Guidance for the service alongside resources available to support staff vaccination uptake.

Today, to support you to meet the new regulatory requirements, we are sharing with you:

Phase 2 implementation guidance

This guidance focuses on the implementation of the new regulations inclusive of a redeployment framework and advice regarding formal steps for staff who remain unvaccinated on 1 April 2022.

Frequently Asked Questions (FAQs)

The FAQs include general information regarding the regulations, highlight the implementation timeline and what action is required, and address common questions and queries we have received.

VCOD Workforce Vaccination History Solution for Trusts

To assist Trusts with understanding the vaccination status of their workforce, we are providing a solution for Trusts to view the vaccination status of staff who are on the Electronic Staff Record (ESR) system.

To do this, we are undertaking an exercise on Trusts’ behalf, to match ESR data, using NHS numbers, with vaccination data held in the National Immunisations Management System (NIMS) – which includes data drawn from all point of care vaccination systems.

Following a successful import of ESR data into NIMS, a dashboard will be provided to each Trust detailing their workforce Covid and Flu vaccination uptake, drilled down to employee-level.

We appreciate that some staff in scope of VCOD will not be on ESR and that the vaccination status of these staff will not be included in the initial provision of data coordinated by NHSE&I. However, we hope it will go some way towards lessening the burden on Trusts in relation to collection of staff vaccination data and support Trusts with identifying those who will not meet the requirements of VCOD for 1 April 2022.

Please note this solution is currently only available to Trusts. Trusts who are already onboarded and using the NIMS Workforce solution will be unaffected as their existing data will be preserved.

PART 1 (Set up and onboarding 17 – 31 January 2022)

To enable access to the dashboard we need to onboard all Trusts with the intention that all Trusts will have access by 31 January 2022, through a rolling onboarding programme, beginning week commencing 17 January 2022.

The guidance for onboarding, including a number of actions that Trusts should take immediately and before 20 January can be found via the following link – NIMS Workforce Solution. You do not need to undertake Steps 1 and 2 of the NIMS Workforce Solution guidance until we progress to PART 2 below (the BAU solution). Please go straight to Step 3 (Reporting SPOC approval).

If you do not take action by 20 January, you may not have access to the dashboard until after 31 January 2022. 

Please ensure you follow the process instructions carefully because any mistakes can lead to a delay in gaining access to the dashboard.

PART 2 (BAU solution from February)

From February 2022, we will move to the NIMS Workforce Solution BAU process and will communicate further details on this in due course.

VCOD FutureNHS workspace

A VCOD workspace on the FutureNHS web platform has been set up to house all relevant policy information, guidance and supporting resources, and includes links to other resources, including communications materials to support vaccine confidence.

If you have an nhs.net or nhs.uk email you can self-register to join. For any other external email domains, you can join FutureNHS by asking to be invited by the workspace manager. Please contact nhsei.peopledirectorate@nhs.net with your request.

Next steps from NHS England and NHS Improvement

Please note this is iterative guidance which will be reviewed regularly to ensure any legislative changes are reflected, and feedback and queries from colleagues across the healthcare system are considered.

Additionally, a series of Teams Talks webinars and drop in sessions are being held with HRDs, CPOs and managers with HR responsibilities, with similar support for comms leads, to signpost available resources for the implementation of this policy and to support conversations with our affected workforce. Where systems are organising events to support staff uptake, please consider extending the invitation to primary care staff.

Please continue to remind your colleagues that our national  health and wellbeing resources are here when they are needed. For line managers, winter workforce preparedness and the Leadership Academy’s #ProjectM and #Winterwarmers provide practical guidance on how to ensure our NHS people are well-supported.

Thank you for your continued support throughout the vaccination programme and for everything you are doing to care for patients and support your colleagues at this time.

Yours sincerely,

Prof Em Wilkinson-Brice | Deputy Chief People Officer

Prof Stephen Powis | National Medical Director

Ruth May | Chief Nursing Officer, England

Dr Nikki Kanani MBE | Medical Director for Primary Care

Suzanne Rastrick OBE | Chief Allied Health Professions Officer, England

Dr Keith Ridge CBE | Chief Pharmaceutical Officer for England

Sara Hurley | Chief Dental Officer, England