Coronavirus restrictions are progressively coming to an end. The latest guidance issued in England relates only to NHS services. While this does not mean that others need not consider the pandemic, it does mean that they must use their own judgement and risk assessments to decide how to best deliver a safe service.
The underlying theme of government advice for living with Covid-19 is that it remains a dangerous disease but people can make their own judgments about the risk of catching and dealing with it. Mandatory rules are being replaced with advice and individual responsibility. The government advise that the public should remain cautious, get vaccinated and boosted and protect people most vulnerable to Covid-19.
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 six factors below to help you decide the best way to deliver your service.
As restrictions ease and we move away from mandatory rules, many members are asking how they can make their vulnerable patients feel confident and safe when attending for physiotherapy.
We advise all members to risk assess their environment and take appropriate steps to make their clinic as safe as possible. You may choose to share your actions with your patients to reassure and ask patients who feel unwell in any way not to attend.
The actions clinics adopt going forward will very much be dependant on their own individual risk assessments and the vulnerability of the patients they serve.
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 a safe 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 infection prevention and control and your duty to provide a safe workplacein the UK and Northern Ireland.
- 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 digital/physical appointments.
- the clinic has robust record-keeping procedure for both digital and physical appointments
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.
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 require
- Train all your staff so that they are aware of and discharge their responsibilities in the process of preventing and controlling infection
- 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 whether you want to request patients wear a face covering
- Know how to risk-assess for the correct level of PPE at each consultation
If you are working in a domiciliary and or care home setting
- Know how you will transport PPE supplies.
- Know how you will dispose of PPE.
- Have a process in place for hand decontamination.
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.
- Identify if your patient is vulnerable or not.
- Ensure you have the appropriate PPE to wear.
- Ensure you have appropriate infection prevention and control 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.