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Staff movement: a risk management framework

17 December 2020


The Government is introducing legislation that will require care home providers to restrict all but essential movement of staff between settings in order to reduce transmission of COVID-19 – with a particular focus on care home staff.  At the same time, care homes are facing staff shortages due to sickness and the ongoing high vacancy rates.

This Care Provider Alliance briefing outlines a risk management approach (developed by CPA member, the Registered Nursing Home Association) that care homes can use to manage restrictions on staff movements. The briefing relates to CQC registered care homes with or without nursing in England.


In December 2020, the Prime Minster set out the revised Covid-19 Winter Plan with the key aim to keep coronavirus under control through this winter until the benefits of a significant vaccination programme are seen across health and social care to protect staff and those individuals that care providers keep safe with services everyday within community and residential care settings.

The Winter Plan includes a specific mention in relation staff movement within residential services:

“In the first wave, the movement between care homes of staff who were unwitting carriers was one cause of the virus being introduced to these settings. The Government is therefore introducing legislation, by the end of the year, that requires care home providers to restrict all but essential movement of staff between settings in order to reduce transmission.” (para 79, Section: Protecting the NHS and the vulnerable)

Research undertaken by University College London concluded that “infections in staff are a risk factor for infection in residents” within the Vivaldi Study published in July 2020.

Balanced against this need to minimise risk and any unnecessary staff movement, is the need to continue to operate services effectively through the pandemic, whilst also having 110,000 vacancies across the sector and in excess of 3,000 vacancies for registered nurses working in social care (Skills for Care workforce report).

Care services must be enabled to continue to operate and keep the people whom they care for as safe as possible within the constraints of the scarcity of the workforce, and the ongoing sickness and absences that services are managing daily throughout this winter period.

Developing a risk management framework§

A risk management framework can enable care homes to have a discussion with other agencies, such as their regulator or commissioner, about care home staff movement.

This framework can assist services to manage the situation and provide operational tools that - over time - can drive down the number of staff movements and hence reduce the transmission of the virus. Many providers have already been pursuing such actions without an overall structure to work within.

The key driver of the assessment must be for providers to continue to operate with enough staff who are also appropriately qualified to meet the needs of service users throughout all stages of the pandemic.

Key factors to consider§

The following factors which will affect staff movement over the coming months need to be considered within the risk management framework:

  • Changes to terms and conditions of staff contracts can take time and hence a requirement will be to define and report on those additional roles which staff undertake. This can be undertaken by careful employee management in the short term, whilst contractual changes are consulted upon in a longer timescale.
  • Recruitment of additional staff, either domestically or internationally, takes at least weeks and, more often in isolated areas, months. The use of bank staff will therefore still be required by providers.
  • On the positive side the availability of quicker COVID-19 test results, but via the less accurate, lateral flow tests are being rolled out to care home visitors. These could also be deployed for staff known to move between services.
  • The roll out of COVID-19 vaccinations to a significant proportion of care home staff, is also becoming a reality.

This document therefore creates a staff risk management framework, which will develop over time, to flag the actions and reviews which each provider should take to achieve the goal of minimising infection spread through staff movement.

Actions for initial assessment§

Care homes can use the following list of possible actions when carrying out their initial risk assessment. Care homes should:

  • identify staff who work across multiple care services and maintain, review and update their records on a monthly basis
  • start to consult with staff to add a condition to staff contracts which commits staff to notify their employer, if and when they undertake work in another care setting (including informal care) during the pandemic
  • continue to advertise and recruit staff who become available, either domestically or where appropriate, internationally
  • work with team leaders to identify options to change staffing arrangements and working patterns
  • hold individual one-to-one meetings with staff who have been identified as working between care services. Discuss options available such as changes to working patterns or roles to minimise or stop movement between services
  • use the Infection Control Fund 2 to remunerate staff to work for a single care service
  • consider the likely use of agency staff and, if that is determined to be likely, attempts to negotiate exclusivity arrangements with an agency with detailed agreements on testing, symptom checking and other infection control issues
  • consider recruiting volunteers / relatives to become staff members for the duration of the pandemic and for the exclusive use of their service
  • consider additional training to allow more staff to undertake processes, such as medication administration, to minimise reliance on specific members of staff
  • consider the use of cohorting different groups of residents and the effect that these measures have on staff movement between these groups.
  • ensure that all relevant staff are tested to the agreed schedule and consider the availability of using lateral flow tests for high risk staff on all shifts.
  • use the PPE portal to ensure sufficient PPE for all staff.

Working with notifiable agencies§

Providers should consider what formal and informal notifications are required during the period of the pandemic in relation to staff usage and movement. Care homes should work with notifiable agencies, including the Care Quality Commission, local authorities and CCG commissioners, to agree contingency arrangements in advance of situations arising.  This might include:

  • High absence rate of staff due to, for example, asymptomatic positive tests of staff members and the resultant self-isolation.
  • Identification of key members of staff who would be difficult to replace. For example, if a small care home with nursing has a very limited number of nurses on the staff, their absence will have a significant impact.
  • Identification of plans to manage higher levels of need than normal. For example, high numbers of residents with symptoms, or at end of life, or requiring one-to-one supervision.
  • Identification of the actual level of agency staff available in each local area.

It is likely that the following actions may support manging these situations:

  • asking existing staff to undertake additional shifts
  • reallocating staff from other roles (eg catering, domestic and laundry) to direct care or supporting roles
  • managers, deputy managers and administration staff providing care shifts
  • operating with a skeleton care staff with all other roles supporting.

Useful links§

CPA Coronavirus information and guidance

CPA Business continuity planning guidance and templates

CPA Infection Control Fund information

DHSC COVID-19 Winter Plan 2020/21



The CPA assumes no responsibility or liability for any errors or omissions in the publication of this communication. The information contained in this update is provided on an “as is” basis with no guarantees of completeness, accuracy, usefulness or timeliness. It does not constitute legal advice.