GP practices need to be aware that paid for travel vaccinations are not covered within the scope of GP state indemnity (the CNSGP scheme).
This is a change to the previously stated position. The scheme scope document has been updated to clarify this and states the following points.
- Travel vaccinations funded by the NHS (for which there is no charge to patients) are covered under CNSGP.
- Travel vaccinations and immunisations for which patients have to pay a charge are not NHS services and therefore not covered under CNSGP.
- NHS England has clarified that 'whilst GMS and PMS contracts allow GP practices to administer and charge for certain vaccinations, when the patient pays for the vaccine or immunisation they are considered private health services, not NHS services.'
- This follows the Department of Health and Social Care (DHSC) taking legal advice having previously understood that 'vaccinations and immunisations, paid for or not, were NHS services'. However, having considered the issue carefully, the DHSC has 'concluded the administration of paid for vaccinations and immunisations are not NHS services so cannot be in-scope of CNSGP'.
However, the DHSC has confirmed that it is committed to ensuring 'any general practice staff who were administering travel vaccinations and immunisations (where patients were charged a fee) and who understood themselves to be covered under the CNSGP for such activities, are not financially at a disadvantage as a result of any claims, or potential claims, against them as a consequence of relying on the incorrect information.'
As a result, general practice staff can contact NHS Resolution for access to support for claims for administering paid for travel vaccinations for the period between 1 April 2019 and 31 July 2019.
State indemnified GPs who are MDU members and receive claims arising from travel vaccines administered on or after 1 August are reassured that a number of fee paying activities, including providing travel vaccinations to registered patients is included in the MDU's state indemnified category of membership. You can approach the MDU for assistance and indemnity in the usual way.
For further information see themdu.com/mindthegap
This guidance was correct at publication 05/07/2019. It is intended as general guidance for members only. If you are a member and need specific advice relating to your own circumstances, please contact one of our advisers.