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How do we implement the influenza vaccination requirement for staff and visitors?

Due to the COVID-19 pandemic, the Australian Health Protection Principal Committee (AHPPC), the key medical decision-making committee for health emergencies, has advised that all residential aged care staff and visitors should be vaccinated against season influenza. NSW, like all States and Territories, has issued a Public Health Order giving effect to that decision.

Under the Public Health (COVID-19 Aged Care Facilities) Order (No 3) 2020​only certain people are able to enter a residential aged care facility. However, under Clause 6 of the Order, a person permitted to enter is not to enter or remain on the premises of residential aged care facility if the person does not have an up-to-date vaccination against influenza, unless: 

  • the vaccination is not available to the person, or
  • the person presents to the operator of the residential aged care facility a certificate in the approved form, issued by a medical practitioner, certifying that the person has a medical contraindication to the vaccination against influenza. 

For certainty, an up-to-date vaccination against influenza refers to the 2020 vaccine. While NSW Health considers there to be sufficient supply of the 2020 vaccine remaining, in a small number of circumstances the vaccine may not be considered available to the person if there are low local stock supplies.

See the approved Medical contraindication to the influenza vaccination requirements form

Under Clause 7 of the Public Health Order, the operator of a residential aged care facility (RACF) must take all reasonable steps to ensure a person does not enter the premises in contravention of the requirements.

There are only limited medical contraindications for the influenza vaccination.  Where a person has a medical contraindication to the influenza vaccine, they must present the operator with the approved form signed by a registered medical practitioner in which the medical practitioner certifies that the person has a medical contraindication to the vaccination against influenza. 

The contraindications included on the form are based on the contraindications and precautions for influenza vaccination detailed in the Australian Immunisation Handbook. 

In other circumstances, visitors and staff must be vaccinated with this season’s flu vaccine and providers should seek evidence from the staff member or visitor that this is the case (there are limited exemptions for emergency situations). 

Providers will need to seek their own legal advice regarding what to do if a staff member does not get vaccinated– they may need to re-deploy them until they are vaccinated, or the pandemic is over.

Further information is available at Department of Health - FAQs - Restrictions on entry into and visitors to aged care facilities

Can residents leave a RACF to attend family gatherings?

There are no restrictions in NSW under the current public health orders on people leaving their place of residence. However, Commonwealth and State and Territory bodies have jointly advised that external excursions for groups of residents not be permitted. (19 June 2020 - Australian Health Protection Principal Committee)

Individual residents should be permitted to leave the RACF to attend small family gatherings. The size of the family gathering should be in line with current jurisdictional advice and physical distancing and hygiene measures should be adhered to during the visit. The RACF should conduct a risk assessment for each visit, taking into account the local epidemiology, number of people attending and the feasibility of physical distancing.  The RACF should maintain a record of the visit location, number of people in the gathering and the date of visit. 

There is no requirement for routine testing on admission or re-admission, unless clinically warranted.  Clinical judgement should be applied — for example, where a patient is coming to the RACF from an area with known community transmission. Further information is available in the CDNA National Guidelines for the Prevention, Control and Public Health Management of COVID-19 Outbreaks in Residential Care Facilities in Australia.

RACF providers should wherever possible also facilitate visits to the RACF that are informed by the new Industry Code for Visiting Residential Aged Care Homes During COVID-19​, as well as facilitating alternative ways for residents to maintain contact with friends and family, such as through remote options like phone, video calls or social communication apps.

 

In the event a facility needs to return to a higher level of protection (for example, an outbreak of COVID-19 or local cluster in the community), facilities should cease all external excursions.

Can residents go on excursions?

The Australian Health Protection Principal Committee advised on 19 June that no external excursions for residential aged care residents should currently be permitted. 

Should RACFs check NSW Ambulance temperatures before allowing access to the RACF in an emergency?

Under clause 6 of the Public Health (COVID-19 Aged Care Facilities) Order (No 3) 2020​persons permitted to enter a RACF cannot enter on a particular day if the person has a temperature of 37.5 degrees or higher or symptoms of acute respiratory infection.

Under Clause 7 of the Public Health Order, the operator of a RACF must take all reasonable steps to ensure a person does not enter the premises in contravention of the listed requirements. 

While a RACF could argue that to comply with this order they cannot let anyone into the facility unless they first check their temperature, they also have a responsibility to not impede residents receiving the care they require in an emergency. 

RACF providers should note that since 24 March, NSW Ambulance staff are required to undertake wellness checks, including checking of temperatures, prior to the commencement of their shift.

In addition, NSW Ambulance has procedures in place to determine the suspected or confirmed COVID-19 status of all patients and the appropriate use of PPE at all times.

After a suspected or confirmed COVID-19 patient is transported, a thorough clean of the vehicle and equipment surfaces is completed using detergent/disinfectant wipes.

For this reason, it is NSW Health’s position that if there is an emergency requiring an ambulance call out, it is reasonable to allow paramedics into a RACF to provide care and treatment without requiring a temperature check first. 

Are Patient Transport Services transporting COVID-19 patients, as well as residential aged care residents? If so, should RACFs be screening them?

As part of their role in assisting NSW Health to manage the flow of patients in and out of hospitals, the NSW Health Patient Transport Services (PTS) may transport people with suspected or confirmed COVID-19.

Under Clause 6 of the Public Health (COVID-19 Aged Care Facilities) Order (No 3) 2020​​persons are not to enter or remain on premises of a RACF if the person has a temperature of 37.5 degrees or higher or symptoms of acute respiratory infection.

Under Clause 7 of the Public Health Order, the operator of a RACF must take all reasonable steps to ensure a person does not enter the premises in contravention of the listed requirements.

Public health facilities notify PTS if a patient has suspected or confirmed COVID-19 when making an online booking, and community patients are also screened over the phone using NSW Health recommendations for risk of infection. When transporting a patient with suspected or confirmed COVID-19, all crews must adhere to NSW Health Clinical Excellence Commission guidelines for standard, droplet and contact precautions and a surgical mask is also placed on the patient.

In addition, once a patient is transported to their required location, crews are required to complete an ‘infectious clean’ of the vehicle in accordance with best practice advice obtained from the NSW Health Clinical Excellence Commission. 

As well as these infection control measures for transporting patients, PTS have implemented procedures at the beginning of each shift to ask every staff member whether they have recent onset of respiratory symptoms or fever. Staff with symptoms are either excluded from work or assessed for COVID-19 and, if COVID-19 testing is recommended, staff are self-isolating until COVID-19 is excluded.

NSW Health Patient Transport Services (PTS) are now wearing masks whenever they are in contact with a patient to further minimise the risk of community transmission. This is consistent with the “amber” or “moderate risk” status of NSW Health as described in the CEC: COVID 19 Infection Prevention and Control Response and Escalation Fra​mework​

It is therefore NSW Health’s view that RACFs should continue to use PTS services, in the knowledge that staff are already screened before each shift and take all necessary precautions when they are transporting patients.

Should RACFs check the temperature of all visitors to the facility (outside emergencies)?

Under Clause 6 of the Public Health (COVID-19 Residential Aged Care Facilities) Order (No 3) 2020​persons who are permitted to enter a RACF under the Order are not are not to enter or remain on premises of a RACF if the person has a temperature of 37.5 degrees or higher or symptoms of acute respiratory infection.

Under Clause 7 of the Public Health Order, the operator of a RACF must take all reasonable steps to ensure a person does not enter the premises in contravention of the listed requirements. 

NSW Health considers that it is reasonable for a RACF to conduct temperature checks and symptom screening for visitors and staff of RACFs each day before they are allowed to enter care areas. The CDNA Guidelines state that visitors must stay away from the facility until symptoms such as fever have resolved.

Can RACFs continue to host students on placement?

RACF can continue to host students on placement. 

The Public Health Order outlines circumstances in which people can and cannot enter and remain on the premises of a RACF. Allowable reasons for a person, including a student, to be on the premises include being present for:  

  • providing goods or services that are necessary for the effective operation of the facility, whether for consideration or for free
  • providing health, medical or pharmaceutical services to a resident of the facility, whether for consideration or for free
  • providing personal care service to a resident, whether for consideration or free
  • making a care and support visit to a resident of the facility
  • end-of-life support for a resident of the facility.

Student placements can continue under the Order provided that the students meet the criteria in the Public Health Order that all staff and visitors need to meet including having 2020 influenza vaccination, if available to them (unless they have presented the approved form signed by a registered medical practitioner indicating they a medical contraindication), having a temperature below 37.5 degrees and not having been overseas in the previous 14 days or in contact with a confirmed COVID-19 case.

If these criteria are satisfied, hosting or not hosting student placements is at the discretion of the RACF as per usual arrangements.

Can a person who has not had a flu vaccination enter a RACF in an emergency?

Under the Public Health (COVID-19 Aged Care Facilities) Order (No.3) 2020​only certain persons are permitted to enter and remain on the premises of a RACF. However, such persons cannot enter or remain on the premises of a RACF if (a) during the 14 days immediately before the proposed entry, the person arrived in Australia from a place outside Australia, or (b) during the 14 days immediately before the proposed entry, the person had known contact with a person who has a confirmed case of COVID-19, or (c) the person has a temperature of 37.5 degrees or higher or symptoms of acute respiratory infection, or (d) the person does not have an up-to-date vaccination against influenza, (unless the person provides a medical certificate in the approved form, issued by a medical practitioner, certifying that the person has a medical contraindication to the vaccination against influenza).  It is an offence to fail to comply with the order without reasonable excuse. 

Under the Order, if a person is providing emergency management or law-enforcement functions in an emergency or providing goods or services to the RACF in an emergency (attending to urgent repairs) then the person is not required to be have an up-to-date vaccine against influenza. If possible, the officers/tradespeople should limit contact with residents and staff.

However, if such personnel are attending the RACF in a non-emergency or non-urgent situations (such as planned attendances), they do need to have been vaccinated against influenza, unless the person provides a certificate in the approved form, issued by a medical practitioner, certifying that the person has a medical contraindication to the vaccination against influenza. 

Under Clause 7 of the Public Health Order, the operator of a RACF must take all reasonable steps to ensure a person does not enter the premises in contravention of the listed requirements. It is an offence to fail to comply with the order without reasonable excuse.

Is there an approved form for people seeking confirmation of a medical contraindication to enter a RACP without a flu vaccination?

The Ministry of Health has developed an approved form for use by medical practitioners for people seeking confirmation of a medical contraindication to the influenza vaccination requirements set out in the Public Health (COVID-19 Aged Care Facilities) Order (No 3) 2020.

The approved form will be distributed to key stakeholders, including the Royal Australian College of General Practitioners and Primary Health Care Networks. See a copy of the approved influenza vaccine medical contraindication form​ for use by General Practitioners. 

Can hairdressers attend a RACF to provide services to residents?

Under the Public Health Order, persons providing personal care service to residents, such as hairdressers are permitted to enter a RACF. 

However, such persons cannot enter or remain on the premises of a RACF if (a) during the 14 days immediately before the proposed entry, the person arrived in Australia from a place outside Australia, or (b) during the 14 days immediately before the proposed entry, the person had known contact with a person who has a confirmed case of COVID-19, or (c) the person has a temperature of 37.5 degrees or higher or symptoms of acute respiratory infection, or (d) the person does not have an up-to-date vaccination against influenza, (unless the person provides a medical certificate in the approved form, issued by a medical practitioner, certifying that the person has a medical contraindication to the vaccination against influenza).  It is an offence to fail to comply with the order without reasonable excuse.

Persons entering RACFs should adhere to equivalent social distancing and hygiene practices as they have implemented in community settings.

Is there a time limit to how long a visit can be?

No - Spouses, close relatives and social supports are not limited in the number of hours that they spend with their spouse/relative. Visitors should practise social distancing where possible, including maintaining a distance of 1.5 metres. Visitors have a responsibility to supervise any children with them, practise hand hygiene and respiratory etiquette.

Is there a limit to the number of visitors a resident can have at one time?

Yes - Limiting visits to a maximum of two visitors at any one time per resident reduces the risk of transmission to residents. Visits should be conducted in a resident’s room, outdoors, or a specified area in the RACF, rather than communal areas with other residents.

Can Children under the age of 16 enter a RACF?

Yes - Children of all ages are permitted to enter RACFs — all visitors, including children, must adhere to restrictions on visitor numbers, social distancing and personal hygiene.

What is an essential caring function?

A care and support visit is defined in the Public Health (COVID-19 Aged Care Facilities) Order (No 3) 2020 as “a visit made to the resident, by no more than 2 persons together, for the purposes of providing care and support to the resident “

An essential caring function should be consistent with advice in the Industry Code for Visiting Residential Aged Care Homes during COVID-19 (updated 23 July 2020), which details that:

  • For all RACFs Principle 7 allows for certain circumstances which may require additional consideration for the following ‘social supports’ circumstances:
    • Principle 7 (b): Residents who have a clearly established and regular pattern of involvement from visitors contributing to their care and support (this could be daily or a number of times per week and, for example assisting a resident with their meals or with essential behaviour support such as for people living with dementia) must continue to have these visits facilitated.
    • Principle 7 (d): provision of support to maintain the mental wellbeing of the older person, where a serious mental illness is known or emerging and where the maintenance of social and family connection may contribute to relieving social and emotional distress for the resident.​​​​​​​​​​​​​
Page Updated: Wednesday 23 September 2020
Contact page owner: Health Protection NSW