Response to making vaccination a condition of deployment in the health and wider social care sector

The College agrees that vaccination is among the safest, most effective and evidence-based approaches to help protect people from infectious diseases. As such, the College believes all health and social care workers in primary and secondary care, and their colleagues, should have all recommended vaccinations, unless they are medically exempt. Indeed, we believe that the over-whelming majority of optometrists are already vaccinated, and we would anticipate that there will be high uptake of the booster vaccine, when offered.

Evidence suggests that vaccine uptake is already high amongst frontline healthcare workers in general; with 92% of staff in NHS Trusts in England having had at least one dose (as of September 2021). Since the publication of these figures, many more workers will have come forward for vaccination. Furthermore, a large proportion of the relatively small numbers of healthcare workers who haven’t been vaccinated are likely to be exempt for medical reasons. We therefore believe that these proposals to make vaccination mandatory are disproportionate given the incredibly small numbers of healthcare workers that they are likely to apply to.

We believe that vaccine uptake will be maximized where optometrists and practice staff are supported to make their own decisions, having been provided with clear, evidence-based information on the benefit and value of vaccinations. Indeed, enforcing vaccinations may actually result in the opposite response, and discourage people from coming forward.

We therefore do not support mandatory vaccination as a condition of deployment in a healthcare setting. 

Whilst we would anticipate that only a very small number of optometrists will continue to refuse vaccination (whether mandatory or not), clear guidance needs to be given to employers as to what they are to do regarding an optometrist’s eligibility to work. Re-deployment to other duties may not be a feasible option for many optometrists, and the health system runs the risk of losing essential workers from the eye health sector at a time when it is already under-resourced.

Throughout the pandemic, hospital eye care services have been severely affected, which has resulted in patients not being treated, and now, a significant backlog of patients in the system who are at risk of permanent sight loss. Feedback from our members indicates that these cases of sight loss would have been avoidable were it not for increased waiting times and delays in review.

Mandatory vaccination could potentially worsen the current situation as more staff would leave the NHS, potentially with legal action against employers to follow. Reducing the workforce even more at this time could lead to a greater number of patients encountering loss of vision, and will not help to address the increasing backlog of patients. In addition, the NHS is heading into a potentially very difficult winter, and a loss in the workforce could have serious implications for patient safety.

We recognise that the proposals outlined in this consultation currently apply to optometrists working in Care Quality Commission (CQC) registered settings (e.g. NHS hospitals and private medical practices). However, given the critical role primary care optometrists continue to play in delivering eye care during the pandemic, we would like the DHSC to provide clarity on whether these proposals will be extended to primary care workers.

As the professional body for optometrists, the safety of patients, optometrists and their colleagues has always been the College’s priority. The pandemic has seriously affected the provision of eye care, and focused attention on the need to maintain stringent infection and prevention control measures, including access to recommended vaccinations, to protect patients and practice staff from harm.

Covid-19 vaccination is clearly an important tool in managing the pandemic; however, it is not a magic bullet. For example, regular lateral flow testing of front-line staff continues to be important, and we encourage all optometrists to undertake regular testing and to take appropriate action if they receive a positive result.

We believe that an over-emphasis on vaccination could result in a relaxing of infection control measures in healthcare settings (particularly in primary care) where workers may be given a false sense of security.

The College has been calling on NHS England / Improvement (NHSEI) to fund and make it easier for optometrists in England to access seasonal influenza vaccinations since the start of the pandemic. We recently led a sector-wide letter to NHSEI calling for primary care optometrists and colleagues to have free influenza vaccinations. We were therefore very encouraged by the recent announcement that the influenza vaccine would be funded this year for optometrists and all front-line primary eye care staff in England.

However, we would like to see this policy extended to future years, as without funding available, some employers will not fund influenza vaccinations for their staff. Locum optometrists in particular are at risk of not being vaccinated if their employers do not facilitate access.

Based on these reasons, we therefore do not support mandatory vaccination as a condition of deployment in a healthcare setting. We recommend that the Department of Health and Social Care:

• encourage all healthcare workers, including optometrists and colleagues who are vaccine-hesitant, to have the opportunity to fully understand the benefits of vaccinations, with risks explained proportionately, and given the autonomy to make an informed choice. Optometrists should be given time to discuss their concerns with their employer or occupational health team.
• ensure that optometrists and colleagues have priority access to all vaccines as frontline healthcare workers. Employers should make having vaccinations as easy as possible; for example by enabling optometrists to attend an appointment within working hours, or at a time and location that suits their needs.
• provide employers with the support to undertake a risk assessment for those who are medically unable to be vaccinated, or remain hesitant about vaccines, and consider how to mitigate risks to patients and prioritise patient safety.
• ensure that messaging around infection control measures and regular lateral flow testing is clear, and that they must continue to be practiced, regardless of whether optometrists have been vaccinated or not.