Across the UK, you should be confident to open up your services and practices, and to see patients face to face subject to your country's or region's lock-down restrictions and following the relevant safety and government guidance.
As an HCPC registrant you do need to do all you can to minimise risk to yourself, your patients and colleagues.
This framework provides you with a pathway to interpret national guidance and adhere to the legal, regulatory and professional requirements that govern safe physiotherapy practice.
Work through the seven factors below to help you decide the best way to deliver your service.
Legal, regulatory and professional responsibilities
You must work within the legal, regulatory and professional frameworks that guide the safe management of patients, the safety of the wider public and everyone who works in the practice environment for which you are responsible.
- Current Government guidance on business operation, social distancing and shielding. You must be clear that while the trajectory of change will be the same for each country/region the timescales will be different. You must, therefore, read the government guidance for the country/region in which you work.
- CSP’s Duty of Care guidance
- HCPC Guidance on Covid-19
- HCPC guidance on Adapting my Practice in the Community
- HCPC Standards of Proficiency – consider how they relate to your practise, and practices
- The CSP considers the law and regulatory requirements and interprets the impact of these for the profession in a range of advice and guidance tools. We will endeavour to keep all up to date.
- Demonstrate through documented evidence that you are compliant with Health and Safety at Work Act (HASAWA) in relation to Covid-19 and your duty to provide asafe workplace in the United Kingdom and Northern Ireland.
- Demonstrate through documented evidence that you are compliant with Health and Safety Executive (HSE) requirements in relation to Covid-19 and your duty to provide a safe workplacein the UK and Northern Ireland.
- Put procedures in place to manage staff self-monitoring of Covid-19 symptoms including any need to self-isolate
- Put procedures in place to manage staff access to testing for Covid-19
- Implement Standard Operating Procedures (SOPs) that clearly demonstrate how you are:
- Identifying risk
- Managing risk
- Establishing a safe environment
- Implement Standard Operating Procedures (SOPs) to show that:
- The clinic has a decision-making process for offering virtual and/or face-to-face appointments
- The clinic has robust record keeping procedure for both virtual and face-to-face appointments
- Implement a system to identify which patients are in the clinic at any one time should the need for contact-tracing arise
Risk assessment of the working environment for which you are responsible*
To fully understand the areas in your environment that need attention you should undertake a risk assessment. You should document this and demonstrate the steps you will take to mitigate risks.
Assess the risk of your working environment
Ensure your documentation shows the measures you have taken to mitigate the potential risks to your patients, yourself, and your colleagues
Have a look at the HSE’s risk assessment template
Demonstrate your clinical reasoning skills to reduce footfall and exposure using virtual measures where possible such as remote triage/history taking.
- Use appropriate PPE (see PPE section below)
- Follow your government’s guidance on social distancing.
- Consider if you can conduct sessions outdoors
- Consider how people enter and leave your premises
- Adapt your waiting rooms to ensure patients do not overlap (one in, one out) and people are kept apart
- Consider installing screens and barriers at receptions areas
- Develop a protocol for when patients ask to be accompanied by a relative
Develop a protocol for when patients ask to have a chaperone and/or translator present
Place relevant posters in the clinic to raise awareness
Remove all non-essential items from waiting rooms and consider how you will clean non-disposable items such as clipboards and pens
Implement hand decontamination facilities (hand-washing and hand sanitiser)
Develop a policy and protocol for cleaning clinic rooms after each patient
Train all clinic staff in infection control procedures
Consider reducing the numbers of appointments offered to allow for cleaning between patients
Implement policies and procedures for cleaning of phones, desks and other tools used by staff in clinical areas
*If you work in people’s homes or a care home you may not have ultimate responsibility for your work environment but you should still follow guidance on how to work safely.
Infection prevention and control (IPC) measures
You must follow Public Health England (PHE) Covid-19 infection prevention and control (IPC) guidelines.
- Develop protocols and systems to manage and monitor and any risks that the clinic environment may pose
- Develop a protocol for cleaning clinic rooms after every patient and other clinic areas as required
- Procure all appropriate cleaning products
- Provide suitable accurate signage on Covid-19 IPC for people coming into clinic
- Implement telephone screening of all patients before their appointment to ensure those with suspected Covid-19 symptoms do not enter the clinic to reduce the risk of transmitting infection to other people
- Train all your staff so that they are aware of and discharge their responsibilities in the process of preventing and controlling infection
- Put a system in place to manage the occupational health needs and/or obligations of your staff in relation to, symptom management and self-isolation
- Put in place appropriate hand decontamination (hand-washing and hand-sanitising) facilities
- Procure a sufficient supply of relevant PPE suitable for the clinic activities undertaken and patients who may be treated
- Procure the correct colour-coded waste bags
- Implement arrangements for the storage of waste bags before collection
- Procure appropriate services to collect and dispose of waste in line with current legislation
- Train all your staff in appropriate hand decontamination processes, PPE requirements and waste collection, storage and disposal
You must provide and use appropriate personal protective equipment (PPE) and have systems and policies in place that govern its use.
- Consider how to communicate to patients the need for them to wear face coverings if they attend for face to face appointments
- Know the PPE that any non-clinical staff in your practice will be required to use, including for any cleaning that must be undertaken
- Know how to risk assess for the correct level of PPE at each consultation
- Ensure all the necessary PPE is available and utilised
- Train yourself and your staff how to don and doff PPE
- Put in place appropriate processes and methods to dispose of PPE
- Develop and document a PPE protocol that includes all the processes and procedures for safe and appropriate management of PPE
If you are working in a domiciliary and or care home setting
- Know how you will transport PPE supplies
- Know ‘sessional use’ of PPE in domiciliary settings and care homes
- Know how you will dispose of PPE
- Have a process in place for hand decontamination
Initial contact and triage should be conducted via remote means during the pandemic.
- Remote triage should include screening questions to establish whether the patient is experiencing symptoms of COVID-19, has been tested as positive or has household members with the same
- In order to decide whether to see a patient face-to-face you should could consider the risk to the patient, yourself, others in your clinical setting or the patient’s household
- Check for COVID-19 Risk Factors
- It is advisable to keep a record of how you clinically reasoned your decision.
- Document advice and assessment findings in the patient’s clinical record
Patient risk assessment and clinical reasoning
You should use your professional judgement to make reasoned decisions as to the best means of treating each patient
- Undertake a Covid-19 symptom screening check at virtual triage assessment
Identify if your patient is vulnerable or not
- Ensure you have the appropriate PPE to wear
- Ensure the patient is able to comply with social-distancing requirements including for those patients who request a chaperone to be present
- Ensure you have appropriate Infection Control and Prevention provisions in place
Patient consent for treatment
You should discuss with your patient the treatment options available to them including the pros and cons of remote consultations. This will enable you to gain and document informed consent.
- Explain the safety measures you have in place to address the risksof Covid-19 in attending a face-to-face appointment
- Discuss why a F2F appointment is clinically justified where this is the case
- Explain to patients the policy and procedures for attending clinic face to face
- Explain to the patient the close contact that may be required during a F2F session
- Discuss with patients attending face to face that they are required to wear a face covering
- Explain to patients the cleaning processes in place in treatment areas
- Document any questions individual patients raise related to attending face to face related to Covid-19
- Train all your staff in appropriate consent for treatment procedures