General Note
NHS Fife acknowledges and agrees with the importance of regular and timely review of policy/procedure statements and aims to review policies within the timescales set out.
New policies/procedures will be subject to a review date of no more than 1 year from the date of first issue.
Reviewed policies/procedures will have a review date set that is relevant to the content (advised by the author) but will be no longer than 3 years.
If a policy/procedure is past its review date then the content will remain extant until such time as the policy/procedure review is complete and the new version published, or there are national policy or legislative changes.
1. FUNCTION
1.1. The requirement for a local policy on staff screening is set out in
DL (2020) 1. This policy has been written in response to the DL and relates to the management of outbreaks at local level within NHS Fife. This is a separate issue from national management of larger outbreaks, epidemics or pandemics.
1.2. In respect of new or emerging infections, staff screening will still be conducted locally in line with this policy. However, additional staff screening (e.g. twice weekly PCR or daily LFD for asymptomatic staff as introduced for COVID-19) may be implemented nationally in response to larger outbreaks, epidemics or pandemics. In situations such as this, local implementation will be the responsibility of the NHS Fife Board in line with guidance from the Scottish Government/ Public Health Scotland and local consultation with Occupational Health, Infection Prevention and Control, Health Protection Team, Workforce Directorate and Senior Managers.
1.3. Where an outbreak is identified within NHS Fife or the Fife Health and Social Care Partnership, an Incident Management Team (IMT) may be convened in line with guidance from Public Health Scotland, “Management of Public Health Incidents: Guidance on the Roles and Responsibilities of NHS Led Incident Management Teams.”
1.4. In some circumstances, the IMT in charge of the management of an incident or outbreak of infection within the healthcare setting may decide that it is necessary to identify the carriage of infection amongst staff members.
1.5. The General Medical Council (GMC) identifies a professional responsibility to comply with screening activities.
1.6. The Nursing and Midwifery Council (NMC) has stated that participation in screening programmes is implicit in their NMC Code of Practice.
1.7. The Health Professionals’ Council also has standards regarding conduct, performance and ethics.
1.8. This policy should be read in conjunction with the National Infection Prevention and Control Manual, Chapter 3: Healthcare Infection Incidents, Outbreaks and Data Exceedance.
2. LOCATION
2.1. This Policy applies to all relevant staff across all areas of NHS Fife and the Fife Health and Social Care Partnership including domiciliary settings.
3. RESPONSIBILITY
3.1. It is the responsibility of the IMT and the Occupational Health & Wellbeing Service to implement this Policy in the event of a major outbreak of infection where the IMT judge it appropriate to screen staff.
4. OPERATIONAL SYSTEM
4.1. Principles of Staff Screening
4.1.1. The screening of staff may be one of the key elements required, based on the IMT’s Risk Assessment, to manage an incident or outbreak in order to protect the health and safety of patients, staff, family members and visitors.
4.2. The Decision to Screen
4.2.1. The decision to screen staff should not be undertaken lightly and the incident should at least satisfy the AMBER criteria in the ‘Healthcare Infection Incident Assessment Tool’ (HAIIT) (see Appendix 1).
4.2.2. The rationale for staff screening may include one or more of the following:
• To characterise the epidemiology of the outbreak in terms of time,
place and person
• To identify the likely source and index case with a view to
controlling the infection
• To assist with interrupting the chain of transmission of an outbreak.
• To confirm eradication of an outbreak
4.3. The final decision to screen staff lies with the IMT.
4.4. When a decision to screen staff has been made it should be communicated to:
• The Chief Executive
• Healthcare Associated Infection (HAI) Executive Lead
• The Directors of Acute Services and Health & Social Care
• Deputy Medical Director, for cascading as appropriate
• The Director of Workforce
• Employee Director
• Senior Managers
• Head of Communications
• Trades unions and representatives of professional bodies
• Occupational Health & Wellbeing Service
4.4.1. It is imperative a partnership approach to screening and the resultant communications is adopted.
4.5. What is screening?
4.5.1. Staff screening is a confidential process and should be undertaken by Occupational Health.
4.5.2. It will involve the collection of specimens from areas of the body where the organism is most likely to be found.
4.5.3. The laboratory testing will focus specifically and exclusively on the detection of the organism(s) suspected to be involved in the outbreak.
4.5.4. All staff should be given information and the opportunity to discuss any concerns with Occupational Health before signing a consent form for screening. The consent form will be issued by Occupational Health and kept confidential in the Occupational Health notes.
4.5.5. Confidentiality will be maintained throughout the screening process.
4.5.6. In exceptional circumstances and at the direction of the IMT, if urgent screening is necessary for patient/staff safety or maintaining critical organisational functions, there may need to be consideration of interim arrangements, using appropriate consent and governance, as Occupational Health Department staff are not available out of hours. Further liaison with, and all documentation should be sent to, Occupational Health at the earliest opportunity.
4.6. Who Should be Screened?
4.6.1. The IMT will make recommendations, following risk assessment, on which of staff should be screened, considering the nature, seriousness and location of the incident or outbreak.
4.6.2. The IMT may wish to categorise staff into
• ‘Hands on’ clinical staff with direct patient contact
• Staff with minimal patient contact
• Staff without direct patient contact but having contact with healthcare equipment or the ward environment
4.6.3. This may be used to identify different levels and priorities for screening in each category of staff.
4.6.4. The IMT should also consider alerting other organisations who have had contact with the patient such as the Scottish Ambulance Service etc.
4.7. Communication with Employees
4.7.1. The IMT, in collaboration with Occupational Health, Human Resources and the Communications Department, should provide guidance to staff on the following:
• Which specific organisms are being screened for?
• Details of the screening process including:
o the nature of specimens
o the confidential handling of specimens and results
o the follow up arrangements for staff who are detected as being infected or carrying the organism
• Information relevant to the organism involved
• Who are the target groups of staff?
• Timeframe for completion of the screening process
• What support is provided for staff?
• How confidentiality will be maintained
• Management of staff who refuse to be screened.
• Management of staff who test positive, including fitness for work decisions, absence and financial arrangements
• Handling of treatment failures and issues of redeployment
• Criteria for returning to work
• Treatment and post-treatment screening
4.8. Support for Staff
4.8.1. The IMT should ensure that staff are fully supported throughout the screening process.
4.8.2. Staff counselling services are available through Occupational Health & Wellbeing self-referral service and staff will be encouraged to use these services throughout the testing process.
4.8.3. Where one to one meetings are undertaken, staff have the right to have a Trade Union/ Professional Staff Association representative present or another NHS staff member of their choice.
4.9. Confidentiality
4.9.1. Labelling of Samples
To maintain medical confidentiality, Occupational Health use a coded numbering system which makes staff samples anonymous when being sent to the laboratory for testing.
4.9.2. Handling of Samples in the Laboratory
Laboratory specimens will only be processed under coded identifiers which will be provided by Occupational Health. The specimens must comply with the minimum data set as laid out in the Rejection Policy of the Laboratory Directorate. Once received, the specimens will be numbered by a different and unique set of consecutive numbers (7 digits plus a check letter) and entered in the laboratory computer system (Master Lab). There is an Outbreak Policy in the department to deal with this situation.
4.9.3. Handling of Results
After specimens have been processed, results will be entered in the computer by the Biomedical Scientist responsible for the work and will be validated by Consultant Microbiologists. The reports will be printed in the laboratory.
4.9.4. Communication of Results
The anonymised results will be returned to Occupational Health who will then communicate the results to the employee. If appropriate and with the staff member’s consent, named results may be sent to their General Practitioner (GP). If necessary, individual cases may be discussed anonymously with the IMT. However Occupational Health will normally be the only one to hold named information on screened staff.
4.9.5. SARS-CoV-2 (COVID-19)
Results are managed differently due to the prevalence of the infectious agent and the importance of self-isolation and other workplace mitigations. With staff consent, test results are shared with the manager and communicated to staff by a variety of methods including via public health and text message.
4.10. Management of Staff refusing to be screened
4.10.1. Once the IMT has decided that it is necessary to screen staff, all relevant staff should be encouraged to attend and take part in the screening process.
4.10.2. Refusal to take part in screening should be viewed seriously.
4.10.3. Where necessary, staff should be reminded of their professional responsibility to participate in screening.
4.10.4. Staff should be offered counselling and support.
4.10.5. Persistent refusal to participate may pose a risk to patients, staff and visitors. Depending on the seriousness of the outbreak or incident, the IMT may decide that it is necessary for the appropriate manager to restrict the staff member from certain duties pending more formalised arrangements if needed. Human Resources will be involved in any discussions regarding suspension in these circumstances.
4.10.6. A full review of employment options should be undertaken by the appropriate manager, with advice from Human Resources, as soon as possible and the staff member kept informed throughout this process.
4.11. Management of Staff Testing Positive
4.11.1. On receipt of positive results, a member of Occupational Health, under advice from IMT, should meet with the staff member and inform them of the result. Treatment should be initiated in consultation with the
staff member’s GP.
4.11.2. As soon as it is established that a member of staff is infected with the organism causing an outbreak, they may then be sent home or restricted from work activities as advised by Occupational Health. Where appropriate, the IMT, Department of Human Resources and the appropriate manager should also be involved in the decision.
4.11.3. The IMT will advise Occupational Health on the criteria for determining when employees are fit to return to work.
4.12. Role of Occupational Health & Wellbeing Service
4.12.1. The role of Occupational Health & Wellbeing Service includes:
• Implementation and co-ordination of the screening programme in consultation with the IMT.
• Development and application of the consent form as appropriate.
• Management of personal data, including appropriate identifier coding of laboratory specimens.
• Providing structured counselling to staff regarding testing and supporting the feedback of results.
• Advising Management / Human Resources on the staff member’s fitness to work.
• Arranging specialist referral if appropriate and liaising with the staff members’ GP.
• In consultation with the IMT, advising the appropriate manager when an employee is fit to return to work or advising on any appropriate
work restrictions.
4.13. Treatment Failure
4.13.1. If, following appropriate treatment the IMT, Occupational Health and the staff member’s GP conclude that the employee is not able to return to their original post, then a meeting should be convened between the staff member, their Trade Union/ Professional Staff Association representative, a senior member of the Human Resources staff and a representative of the IMT.
4.13.2. The purpose of this meeting is to explain and discuss why the employee is unable to return to their original post and to discuss the employment options i.e. redeployment.
5. RISK MANAGEMENT
5.1. A risk assessment will be carried out by the IMT on which categories of staff (if any) should be screened (see paragraph 4.4.1 above).
5.2. The policy then addresses the risks associated with the potential carriage of infection among members of staff during an outbreak of an infectious disease. The implementation of the policy will be monitored by the IMT.
6. RELATED DOCUMENTS
6.1. Healthcare Infection Incident Assessment Tool (HIIAT) – Appendix 1.
7. REFERENCES
7.1. Healthcare Associated Infection (HAI) and Antimicrobial Resistance (AMR) Policy Requirements
http://www.sehd.scot.nhs.uk/dl/DL(2015)19.pdf
7.2. Healthcare Associated Infection (HAI): Guidance for Staff Screening during Healthcare Associated Infection Incidents and Outbreaks.
https://www.sehd.scot.nhs.uk/dl/DL(2020)01.pdf
7.3. National Infection Prevention and Control Manual, Chapter 3: Healthcare Infection Incidents, Outbreaks and Data Exceedance.
http://www.nipcm.hps.scot.nhs.uk/chapter-3-healthcare-infection-incidents-outbreaks-and-data-exceedance/
7.4. Management of Public Health Incidents: Guidance on the Roles and Responsibilities of NHS led Incident Management Teams (2017)
https://www.nipcm.hps.scot.nhs.uk/media/1673/2021-07-shpn-12-management-public-health-incidents-v121.pdf
7.5. Appendix 14- Mandatory NIPCM Healthcare Infection incident Assessment Tool (HIIAT) (Jan 2022)
https://www.nipcm.hps.scot.nhs.uk/media/1866/2022-01-24-hiiat-v20.pdf
