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How do we implement the requirement for staff and visitors to be vaccinated by 1 May?

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 visiting workers should be vaccinated by 1 May 2020. NSW, like all States and Territories, has issued a Public Health Order giving effect to that decision.

Under Clause 5 of the Public Health (COVID-19 Residential Aged Care Facilities) Order 2020, people are not to enter or remain on premises of residential aged care facility if the person does not have an up-to-date vaccination against influenza, if the vaccination is available to the person.

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.

NSW Health is taking a reasonable approach to this requirement. If a person is attempting to access the vaccine but is having supply issues, or a person is allergic to the vaccine or has a medical reason for not being able to have it, then the vaccine is not ‘available’ to them. There are only limited medical contraindications for having the vaccine and providers must seek a medical certificate or similar evidence from a medical practitioner confirming that a person cannot have the vaccine for medical reasons.

In all 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.

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 see family?

A RACF is a resident’s home, and all NSW residents are prohibited under the Public Health (COVID-19 Restrictions on Gathering and Movement) Order 2020, from leaving their home unless for a reasonable excuse. The four main reasonable excuses are:

  • obtaining food or other goods and services
  • travelling for the purposes of work or education if the person cannot do it at home
  • exercise
  • medical or caring reasons.

In addition, Commonwealth and State and Territory bodies have jointly advised:

  • no external excursions for residents should currently be permitted (17 March - Australian Health Protection Principal Committee)
  • that those over the age of 70 (or over 60 for those with existing health conditions or co-morbidities, or over 50 for Aboriginal and Torres Strait Islanders) should self-isolate at home to the maximum extent practicable (29 March - National Cabinet).

RACF providers should wherever possible investigate other options for residents to maintain contact with friends and family such as phone or video calls and social communication apps.

If a resident does leave the facility, RACFs should assess them on re-entry for symptoms of COVID-19 and implement appropriate infection prevention practices if they are symptomatic. Further information is available in section 3.2.1 of the CDNA National Guidelines for the Prevention, Control and Public Health Management of COVID-19 Outbreaks in Residential Care Facilities in Australia.

Can residents go on excursions?

Organised excursions are not permitted. The Australian Health Protection Principal Committee advised on 17 March 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 5 of the Public Health (COVID-19 Residential Aged Care Facilities) Order 2020, persons are not to enter or remain on premises of a RACF if the person has a temperature higher than 37.5 degrees 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.

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, Patient Transport Services (PTS) are transporting people with suspected or confirmed COVID-19.

Under Clause 5 of the Public Health (COVID-19 Residential Aged Care Facilities) Order 2020, persons are not to enter or remain on premises of a RACF if the person has a temperature higher than 37.5 degrees 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 and private provider crews 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.

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 5 of the Public Health (COVID-19 Residential Aged Care Facilities) Order 2020, persons are not to enter or remain on premises of a RACF if the person has a temperature higher than 37.5 degrees 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?

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
  • making a care and support visit to a resident of the facility and it is the only care and support visit for the resident on the day,
  • 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), 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.​​​​

Current as at: Tuesday 14 April 2020
Contact page owner: Health Protection NSW