The following article appeared on carehome.co.uk.
Brexit is fast approaching and care home should be making plans to prepare for the 29 March, even if the government does not.
Philippa Shirtcliffe, head of Care Quality at Quality Compliance Systems, which produces a management system where care providers can record their evidence, policies and procedures to make sure they are compliant with the Care Quality Commission (CQC), has come up with a series of tips for care providers.
- Appoint an individual to lead on the provider’s EU Exit
Appoint a person within the company who will be responsible for leading on the preparations for exiting the EU. QCS’s Ms Shirtcliffe advises that this person “should be senior enough to make decisions and recommendations to the board or senior leadership team”.
2. Review the Business Continuity Plan (BCP)
Care providers should have already reviewed the risks associated with an EU Exit. 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 you can adapt to meet your local needs and your services.
3. Partnership working
Care providers should work with local partners to review their plan, this will include health and local authorities. QCS warns it is vital to think about making sure there is always access to the care home and there will be 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 care providers, local authorities will be involved in ensuring robust contingency plans are in place and early communication is important. Managers should ensure staff understand what is happening and support is provided to care home residents and their families who may be concerned.
4.Test the Plans
QCS recommends care providers test any plans that are in place 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 said there is no need to stockpile medicine and the government has put contingency plans in place to ensure that pharmacies will have enough medication in the months after 29 March.
The UK imports 37m packs of medicine every month from the EU, which makes up three-quarters of the medicine used by people in Britain. In order to keep the supply of medicine flowing, seven new ferry routes have been set up to avoid the mayhem expected around Dover in the event of a no deal Brexit. Pharmaceutical companies have been asked to fly medicine in from the EU in the event of no deal. The NHS Supply Chain organisation is also holding extra stocks of medical products.
Ms Shirtcliffe says: “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.”
You can refer to the QCS suite of Medication Management Policies to ensure your teams are aware of what your organisational procedures are.
6. Medical Devices and Clinical Consumables
The same applies to medical devices as it does to medication. The Department for Health and Social Care (DHSC) again states there is no need to stockpile but QCS warns that your risk assessment as part of your Business Continuity Plan review should look at where supplies are coming from and check the usual ordering and maintenance process will still go ahead.
Care providers should keep up to date with information being issued by the DHSC incase there are any changes.
There are estimated to be around 92,000 EU care workers in the UK, making up seven per cent of the care workforce. This varies from region to region, with EU workers being two per cent of the care workforce in the north-east and 12 per cent in London.
A report by the Migration Advisory Committee has suggested that after Brexit, EU workers should be subject to the same visa rules as other migrants. Currently EU workers have freedom of movement and can travel and work within the European Economic Area (EEA) without visas.
The Committee recommends higher-skilled migrants should have greater access with visas only given to workers earning £30,000 or more. It said it was ‘not convinced there needs to be a work route for low-skilled workers’ from the EU, adding the only ‘possible exception’ to this rule would be seasonal agriculture as 99 per cent of these workers currently come from the EU.
Care providers fear this will prevent EU citizens coming to work in care homes in the UK. The government has said ‘low skilled’ workers from the EU will be able to apply for a year-long working visa post-Brexit.
QCS recommend that care providers assess the number of EU nationals in the workforce and publicise the EU Settlement Scheme to the team. “Business continuity plans should factor in the 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,” said Ms Shirtcliffe.
In addition, she advises that care providers look at who is on annual leave and any on call arrangements around 29 March.
8. Data Sharing, Processing and Access
Providers should follow advice from the Information Commissoner’s Officer (ICO) in the event of a ‘no deal’ scenario and explore how dependent the business is on transfers of personal data from the EU.
Complying with Data Protection laws and GDPR will still be a necessity after 29 March so care 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, according to QCS.
There may be contractual clause changes required for care providers who transfer data from the EU to the UK. You can get further advice on this from the ICO site.
9. Recognition of Professional Qualifications
QCS recommends informing all staff, regardless of whether they are EU citizens or UK citizens, that those whose qualifications have been recognised and who are registered before 11pm on 29 March 2019, that they will continue to be registered after this point.
The government has not as yet made a decision on future arrangements for care workers with an EU/EEA or Swiss qualification who apply to have their qualification recognised after 11pm on 29 March 2019.
10. Review Policies and Procedures and Processes
The UK is currently in limbo, with politicians resigning and a deadlock over Brexit. Having robust policies and procedures in place will help ensure your organisation retains an air of calm and stability. Whatever happens after 29 March, care providers will still have to ensure they are compliant with the Health and Social Care Act and evidence how they meet the five Key Questions from the Care Quality Commission.
There will undoubtedly be changes to policies and procedures and it is crucial care providers ensure they are kept up to date.
“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,” said Ms Shirtcliffe.
To find out more about QCS click here