18th November 2020 | Coronavirus

Information last updated 18 November 2020.

ENGLAND

UPDATE: New national restrictions for England (updated 9 November 2020)

CNHC sought legal advice on whether the complementary healthcare practitioners we register are included in the businesses permitted to remain open during the national restrictions in England introduced by the Government on 5 November.

The advice we received stated that CNHC Registrants in England meet the definition of “other…health services, including services relating to mental health” contained in Section 47, Part 3 of the Schedule to The Health Protection (Coronavirus, Restrictions) (England) (No. 4) Regulations 2020.

This legal advice has taken into account that in Sections 25D and 25E of the NHS Reform and Health Care Professions Act 2002 (as inserted by the Health and Social Care Act 2012) practitioners on Accredited Registers are defined as engaged in work that includes the provision of healthcare.

What does this mean for CNHC Registrants?
CNHC Registrants can continue to provide the therapies they are registered for, on a one-to-one basis, for an identified mental or physical health condition or injury that is causing them pain, or having an adverse impact on their mobility or their quality of life. You must be able to evidence that your therapeutic intervention is supporting your client with their condition. You can do this by recording their health condition and giving a clear rationale in your client’s care record for the treatment that you are providing.  

Mobile working
You cannot provide treatment to a client in their own home unless you have received a direct referral from a statutory regulated health professional.

If your practice is based in your home
If your practice is based in your own home you can continue to work from there as long as it is COVID-secure. You can find our advice on following government guidelines on working safely
here.

Face to face therapies
From 4 July 2020 the following restrictions have been eased:

  • The 2-metre social distancing rule has been relaxed to "1 metre plus" where 2 metres is not possible – but people will be encouraged to have mitigation in place to reduce risk of virus transmission.
  • Hair salons and barbers can reopen, but visors must be worn.

Registrants who can maintain social distancing of 2 metres, and who have full infection control measures in place, may return to work if that would be covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

'Hands-on' therapies (also known as close contact services)
From 13 July 2020 Registrants can return to practising 'hands-on' provided that they:

  • Do not treat highest risk zones. This is defined in UK Government guidance as "the area in front of the face where splashes and droplets from the nose and mouth may be present, which can pose a hazard”. 
  • Have full infection control measures in place.
  • Have confirmation that they are covered by their professional indemnity insurance.

The UK Government guidance for close contact services can be found here.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

UPDATE: Highest risk zones - on 13 August the UK Government announced that treatments to the face can resume on 15 August 2020.  (updated 12 August 2020)
UPDATEThe NHS COVID-19 Test and Trace app launched on 24 September 2020 for England and Wales. A NHS QR code and official NHS poster are available. CNHC Registrants in England providing close contact treatments (i.e. practising 'hands-on') MUST register for a QR code and display the poster from 24 September. Find out more here.


NORTHERN IRELAND

UPDATE: The Northern Ireland Executive has taken the decision to extend the circuit-breaker measures that were introduced on 16 October. Close contact services can resume by appointment on Friday 20 November. For more information read the Statement on Executive decisions – 12 November 2020(Updated 13 November 2020).
UPDATE: COVID-19 circuit-breaker measures announced (updated 16 October 2020)
The First Minister outlined the Northern Ireland Executive's decisions to the Assembly on 14 October 2020. The restrictions, which will come into force on at 6pm on Friday 16 October for an initial period of 4 weeks, include: “Closure of close contact services apart from those meeting essential health needs which will be defined in the regulations to ensure continuation of essential health interventions and therapeutics. This will not include complementary treatments.”

All CNHC Registrants with practices in Northern Ireland must stop working from 6pm on 16 October for the next 4 weeks.

A summary of the new restrictions can be found here

Face to face therapies
From 6 July 2020 Registrants who have practices in Northern Ireland can return to work provided:

  • They can maintain social distancing of 2 metres.
  • Have full infection control measures in place.
  • Have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local lockdown restrictions you cannot return to work yet.

Guidance for working safely in Northern Ireland can be found here

'Hands-on' therapies (also known as close contact services)
From 6 July 2020 Registrants who have practices in Northern Ireland can return to work provided they have full infection control measures in place and have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

Guidance for working safely in Northern Ireland can be found here


SCOTLAND

UPDATE: 5 tier system of local protection levels introduced (updated 18 November 2020)
A new system of local protection levels has been introduced from 2 November 2020:

Levels 0 and 1You can provide close contact services (i.e. 'hands-on' therapies where social distancing is not possible) including mobile services.
Levels 2 and 3You can provide close contact services from your premises, including a home treatment room. However mobile working is not permitted.
Level 4:  All CNHC Registrants providing close contact services must stop working. On 17 November the First Minister, Nicola Sturgeon, has announced that 11 council areas will go into the highest tiel of restrictions from 6pm on Friday 20 November 2020 for 3 weeks. The 11 council areas are: City of Glasgow, Renfrewshire, East Renfrewshire, East Dunbartonshire, West Dunbartonshire, North Lanarkshire, South Lanarkshire, East Ayrshire, South Ayrshire, Stirling, West Lothian.

Travel restrictions: Travel into and out of parts of Scotland that are in level 3 and level 4 areas will be against the law from Friday. The current guidance on non-essential travel has only been advisory but will become law from Friday.

  • People in level 3 or level 4 areas will not be allowed to travel outside those areas unless it is essential.
  • People from other parts of Scotland will not be able to travel into level 3 or 4 areas unless it is essential.
  • People in Scotland will not be allowed to travel to other parts of the UK unless it is essential.

As close contact services must close in level4, CNHC Registrant living in levels 0-3 cannot travel to work in tier 4. However, Registrants can travel from their home in tier 4 to work in a level 3 area but please be mindful of the national effort to control the virus and carefully consider if your travel is essential and within the law. More information can be found here.

Guidance
You can find additional guidance issued by the Scottish Government
 here, which includes specific guidance on mobile working.  

N.B Services offered in the ‘high risk zone’:  For levels 0 to 3 the Scottish Government's guidance states:
"The ‘high risk zone’ is defined as ‘the area in front of the face where splashes and droplets from the nose and mouth may be present, which can pose a hazard’. If treatments in the high risk zone cannot be carried out without the ability to be provided from the side of the face or behind the head and therefore require prolonged periods in the highest risk zone then they should not be offered."


You can check the protection level for your area and find out what you can and cannot do under each level here.
You can also use this postcode checker to find out which tier of protection applies to you.

Face to face therapies
From 15 July 2020 Registrants who have practices in Scotland can return to work provided:

  • They can maintain social distancing of 2 metres.
  • Have full infection control measures in place.
  • Have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

'Hands-on' therapies (also known as close contact services)

From 22 July 2020 Registrants who have practices in Scotland can return to work provided they have full infection control measures in place and have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

The Scottish Government's guidance on close contact services can be found here.

This guidance diverges from UK Government guidance for close contact services are as follows:
- No mobile services: Treatments can only be carried out at your own premises. You cannot provide close contact treatments in client's homes in Phase 3 of of the Scottish Government's Route Map
- High risk zones: The ‘high risk zone’ is defined as ‘the area in front of the face where splashes and droplets from the nose and mouth may be present, which can pose a hazard’. If treatments in the high risk zone cannot be carried out without the ability to be provided from the side of the face or behind the head and therefore require prolonged periods in the highest risk zone then they should not be offered in phase 3 of the Scottish Government’s Route Map


WALES

UPDATE: Coronavirus fire-break in Wales has ended (updated 9 November 2020)
The fire-break imeasures introduced on 23 October 2020 ended on Monday 9 November 2020. They have been replaced by new
national restrictions. CNHC Registrants providing close-contact services (i.e. working 'hands-on' where social distancing is not possible) can return to work under these new restrictions. 

Face to face therapies
From 13 July 2020 Registrants who have practices in Wales can return to work provided:

  • They can maintain social distancing of 2 metres
  • Have full infection control measures in place,
  • Have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

The Welsh Government's guidance on working safely can be found here

'Hands-on' therapies (also known as close contact services)

From 27 July 2020 Registrants who have practices in Wales can return to work provided that they have full infection control measures in place and have confirmation that they are covered by their professional indemnity insurance. 

Exception: If your practice is based in an area subject to local restrictions you cannot return to work yet. 

The Welsh Government's workplace guidance for close contact holistic services can be found here. It includes a restart risk assessment and a reopening checklist.

This guidance diverges from UK Government guidance for close contact services in relation to high risk zones. It states:
"practitioners are currently strongly advised not to perform treatments that will bring them within the ‘highest risk zone’ of clients (defined as the area in front of the face where splashes and droplets from the nose and mouth, that may not be visible, can be present and pose a hazard from the client to the practitioner and vice versa)".


CNHC ADVICE

CNHC advice on preparing to return to work and working safely can be found here


CONTACT US

If you have any questions or queries, please don't hesitate to contact us at info@cnhc.org.uk