Guidance

How healthcare providers can prepare for Brexit

What providers and commissioners of healthcare services can do to manage the risks of a no-deal Brexit.

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This guidance sets out the actions that healthcare providers should take before and after Brexit. Doing this will help to plan for and manage potential service disruption to healthcare in case the UK leaves the EU without a deal.

This guidance is for commissioners and healthcare providers, including hospitals, care homes, GP practices and community pharmacies.

It is based on the advice contained in the Brexit operational readiness guidance issued for healthcare providers in December 2018.

You can also see guidance for adult social care providers.

Supply of medicines, vaccines, medical devices and clinical consumables

UK healthcare providers should:

  • not stockpile any medicines or vaccines beyond usual stock levels

  • not write longer NHS prescriptions

  • reassure the public that they don’t need to stockpile

Stockpiling could cause shortages in other areas and put service users at risk.

Chief and Responsible Pharmacists are responsible for ensuring their organisation doesn’t stockpile medicines unnecessarily.

To help with any local supply issues, take this action before the UK leaves the EU:

  • if your organisation currently relies on receiving products from the EU with short lead times of 24 to 48 hours, plan for longer lead times of up to 5 days

  • make sure you are prepared to receive stock deliveries outside normal hours

The government is working with industry to make sure that there is a continued supply of medicines, vaccines, medical devices and clinical consumables when the UK leaves the EU.

The Department for Health and Social Care (DHSC) has asked pharmaceutical companies that supply the UK from or through the EU or European Economic Area (EEA) to maintain and replenish an extra 6 weeks of stock on top of their usual buffer stock.

Read more about what businesses supplying medicines and medical devices should do to prepare for a no-deal Brexit.

Supply of non-clinical consumables, goods and services

Make sure your business continuity plan and contingency plan include any risks and issues with the supply of non-clinical consumables, goods and services.

Non-clinical goods and services include:

  • IT service agreements and infrastructure
  • waste management
  • facilities management
  • service maintenance contracts
  • laundry services
  • food and catering

Contact your local resilience forum representative if you have any concerns.

Business continuity plans

Make business continuity and contingency plans and review them regularly. Keep the plans up to date and consistent with other local contingency plans, in particular those being developed by your local resilience forum.

Make sure you also have plans in place for the months after Brexit to ensure continuity of care for service users.

Workforce

Actions:

  • review your capacity and activity plans regularly.

  • make sure your business continuity plans cover the supply of staff you need to deliver services before and after Brexit

  • you don’t need to change existing EU staff employment contracts after Brexit even if there is no deal

  • you must notify your local commissioner as soon as possible if there is any risk to service delivery

The EU Settlement Scheme

Tell any staff who are EU citizens about the EU Settlement Scheme. Help staff to apply if they need support.

Through the EU Settlement Scheme, EU nationals can register for settled status if they have been in the UK for 5 years or pre-settled status if they have been here for less than 5 years.

The scheme is free and it’s simple to register. The deadline for applications is 31 December 2020 if there is a no-deal Brexit or 30 June 2021 if the UK leaves the EU with a deal.

Irish citizens are not required to apply for the EU Settlement Scheme, although there are some circumstances where they may wish to. Non-Irish family members of Irish citizens will need to apply.

Recognition of professional qualifications

The government put in place legislation to ensure that professional qualifications from institutions in the EU, Norway, Iceland, Liechtenstein and Switzerland will still be recognised by all professional regulators in the health and social care sectors when the UK leaves the EU, including:

  • the Health and Care Professions Council

  • the General Medical Council

  • the Nursing and Midwifery Council

  • the General Pharmaceutical Council

  • the General Dental Council

This means health and care staff from the EU, Iceland, Liechtenstein, Norway and Switzerland who are currently practising in the UK can continue to do so.

Applications made before the UK leaves the EU will be concluded under current arrangements as far as possible.

Health and care staff from the EU, Iceland, Liechtenstein, Norway and Switzerland who apply for recognition after the UK leaves the EU will have applications concluded under similar rules. This means UK regulators will continue to accept qualifications that they currently must accept automatically. Qualifications that are not accepted automatically will continue to be assessed against the standard of UK qualifications, as is currently the case.

For any professional registration queries, please contact the relevant professional regulator.

Research and clinical trials

Clinical trials and clinical investigations supply

Sponsors of clinical trials or investigations should review their supply chains. Make sure you have arrangements in place to assure supplies after Brexit.

Chief investigators of clinical trials or investigations should contact trial sponsors to understand their arrangements for ensuring supply continues.

Those responsible for recruiting patients for clinical trials should continue to do so. Only stop recruiting for trials when advised by a trial sponsor, the organisation managing the trial or investigation, or by formal communications such as from the government.

Contact your trial sponsors if you are an organisation involved in clinical trials or clinical investigations in the UK, including recruiting patients. Find out about the sponsors’ supply chain plans for investigational medicinal products and medical devices as soon as possible.

Follow the usual process for getting regulatory approval to carry out clinical trials.

EU research and innovation funding schemes

Successful bids for EU programme funding until the end of 2020 will receive their full financial allocation for the lifetime of the project.

Clinical networks

In a no-deal situation, UK clinicians would have to leave European Reference Networks (ERNs).

The government and NHS England are in contact with healthcare providers who participate in the ERNs and no action is required right now.

Data sharing, processing and access

Currently, personal data can be transferred freely between the UK, the EU and other ‘adequate countries’. These are countries that the EU defines as having an adequate level of data protection.

Data will continue to flow from the UK to the EU unaffected.

The transfer of personal data from the EU and other adequate countries to the UK may be restricted if the UK leaves the EU without a deal.

Check whether your organisation relies on transfers of personal data from the EU or other adequate countries to the UK. Focus on data that is critical to service delivery and data that would have a serious impact if it was disrupted.

If your data may be affected you will need to put in place alternative arrangements to ensure continued protection and exchange of personal data.

Check the advice from ICO, NHS England and the Ministry of Housing, Communities & Local Government on data protection and putting in place alternative arrangements should the UK leave the EU without a deal.

Help and contacts

Help with developing business continuity and contingency plans

If you need support in developing a business continuity plan or contingency plan, contact your local commissioner or contacts within your local authority.

Help with workforce queries

Raise concerns about capacity and resourcing in the usual way.

It is important to tell your local commissioner and the Care Quality Commission as soon as possible if there is any risk to service delivery.

You can also send Brexit-related workforce queries to workforceEUexit@dhsc.gov.uk.

Help with supply of medicines and vaccines

Continue to manage medicine and vaccine supply issues in the way you usually do.

Report concerns about supply issues, Brexit-related or not, through your regional pharmacist.

Help with supply of medical devices, clinical consumables and non-clinical goods and services

Start by following your usual processes. Check with your supplier or other relevant teams in your organisation.

Check with your clinical lead if you can use a different brand or product. If you can use an alternative but you are concerned about the initial shortage, report it through your usual escalation channels. This will ensure that supply can be restored as quickly as possible.

To report any issues or concerns around supply, contact:

  • your local commissioner – for primary care

  • your regional NHS EU Exit lead – for secondary care

  • your Local Resilience Forum – for adult social care

Tell your local commissioner and the Care Quality Commission as soon as possible if disruption to the supply of medical devices, clinical consumables and/or non-clinical goods and services poses a risk to service delivery.

National Supply Disruption Response (NSDR)

After Brexit, if you experience disruption to your supplies or you feel there is potential for disruption to healthcare services and usual procedures can’t resolve the matter, you will be able to report it to the NSDR.

NSDR has been set up to support the management of supply disruption.

NSDR contact details will be shared with suppliers and appropriate NHS and adult social care contacts before the UK leaves the EU. If you do not have the number then, follow your business as usual escalation processes or contact your supplier who will be able to access NSDR.

You can report the issue to NSDR whether or not the disruption is related to Brexit.

You should have the following information available when contacting the NSDR:

  • details of the disruption and causes
  • anticipated disruption and causes
  • products or services affected
  • how important these products or services are in providing healthcare
  • potential alternative products or service providers
  • the likely impact of the disruption
  • how many providers and/or people in care could be affected (by region or country as applicable)

Contacts for specific areas

Commissioners should send queries about:

Contact details for regional EU Exit leads

Escalate any immediate risks or concerns about continuity of NHS service provision by email to the relevant regional NHS EU Exit lead:

More information

You can see more guidance to help the healthcare sector plan for Brexit including about recovering costs from overseas visitors in a no-deal Brexit.

Published 20 September 2019