The key points from our formal submission on 22 October:

• Our response was informed by direct feedback from trust leaders, and through a member survey which ran between late August and early October this year, gaining responses from 172 leaders in total from 114 trusts across the country (54% of all trusts).
  
  
• We are slightly supportive of the requirement for staff deployed across health and care settings to be vaccinated, including in the NHS. Our State of the provider sector survey of trust leaders found 58% in support, and 32% opposed to mandatory COVID-19 vaccinations, while 57% support mandatory flu vaccinations, with 33% opposed.
  
  
• Our slight support for the principle of this policy change comes alongside a series of significant caveats and concerns around the impact of a vaccine mandate on NHS staff, providers and patients. We anticipate a vaccination requirement for NHS staff would have a major impact on the workforce and the delivery of services based on conversations with trust leaders and the responses to our survey.
  
  
• There is near unanimous concern among trust leaders about the potential for additional staffing gaps in the NHS (94%), while 95% are concerned about the potential for additional staffing gaps in social care. A significant majority of respondents to our survey said they are either moderately or extremely concerned about the prospect of additional workforce shortages in both sectors.
  
  
• We believe a staged approach to a vaccination mandate, should it be confirmed, would help to mitigate the effects of this requirement to a degree. The first stage of a requirement should not be introduced prior to April 2022. This would allow more time for trust leaders to convince staff who remain hesitant and to properly communicate the many implications of this policy to staff at all levels throughout their organisations. It could also allow for more redeployment opportunities as managers seek to provide more information to those who remain unvaccinated. 91% expect to redeploy staff into different roles (away from frontline care) if vaccination becomes mandatory.
  
  
• Trust leaders have also worked hard to promote staff and patient safety by encouraging 100% vaccine take up, and the NHS as a whole is remarkably close to achieving this with almost 90% of staff now double vaccinated. Many trusts have told us they feel a voluntary approach has been an effective means of driving up rates of vaccination, and that sensitive but challenging one-to-one conversations with hesitant staff have helped to change minds in a number of places.
  
  
• Trust leaders have reported that concerning levels of vaccine hesitancy continue to be held within some ethnic minority staff groups. While there are potential benefits to a vaccine mandate for ethnic minority staff in the NHS, this condition of deployment – if implemented – would almost certainly have a negative impact on employment opportunities and working conditions for some ethnic minority staff. We are very concerned about the potential for a vaccination requirement to exacerbate the impact of existing health inequalities in our society.

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