NRCPD writes to UK Clinical Commissioning Groups

29 January 2021

Dear CCG Chief Executive


My apologies for not addressing you personally - there are 135 or more Clinical Commissioning Groups in the UK and we are writing to you all in a short time regarding vaccination priorities for British Sign Language/English interpreters and translators as part of the integrated clinical frontline. If your CCG is already doing this I am most grateful - if not then my letter will make that case and offer some help to reach people.

The whole country is acutely aware of the difficult work of every corner of the NHS coping with the Covid-19 pandemic and at the same time triaging, treating, nursing and commissioning in all the business-as-usual areas too. A staggering effort the country is wholly dependent upon, but with wellbeing implications for clinical staff that worry everyone.

It is no surprise therefore that Health and Social Care workers are prioritised for Covid-19 vaccination as part of Level 2. I am writing to you because the frontline of health and social care delivery is made up of integrated teams of multiple professions, and where deaf people are the patient or the clinical practitioner, that will very often include British Sign Language/ English Interpreters, Translators, Lipspeakers and Interpreters for Deafblind People.

NRCPD is the national voluntary regulator of language service professionals and we are extremely concerned that the Covid-19 risk facing our registrants working shoulder to shoulder with frontline health staff is reducing the numbers available for work and depriving deaf and hearing people of the ability to communicate in clinical settings with evident patient safety implications. The NHS Accessible Information Standard and the public sector equality duty under the Equality Act 2010 very clearly set out the requirement to enable deaf people to be included effectively in their own care and treatment, for reasons both of patient choice and patient safety and wellbeing.

Without the confidence and safety that early vaccination brings, the number of available NRCPD registered professionals will not be able match the demand for effective language services in clinical settings involving deaf or deafblind people, which risks the chain of healthcare failing for them. I am certain this will lead to poor clinical outcomes for deaf people that could be avoided. Access to health services is already severely hampered by the constraints put in place for Covid-19 protection and sometimes exacerbated by a lack of awareness of the issues facing deaf people seeking support with their health.

I urge you therefore to include in your vaccination programs, the NRCPD registered language service professionals who work within your services and with your partner providers, and to consider doing so at Level 2, equivalent to the Health and Social Care professionals they work alongside. We have just over 1,600 professionals registered (not all of whom work in the NHS) - so spread across all 135 CCGs, we expect the numbers in your catchment area to be relatively small and manageable.

Your staff will be able to identify the individuals in question either through NRCPD or via the language service provider you have in place. Often that is a contract with an agency or an arrangement with a local council language service. Not all NHS bodies have such a formal arrangement and many interpreters are freelance so we could assist with a call out to professionals working in your catchment area, or, as some CCGs have done, NRCPD can receive and pass on invitations or booking links to our professionals in your area. At the point of vaccination, each can be identified by their NRCPD badge and we could help with verifying anyone's professional status also.

You will be applying the JCVI guidance and I recognise it is not straightforward prioritising different professional or population groups, but with such small numbers of NRCPD registered language service professionals across the country, their safety through vaccination is a vital part of ensuring the NHS can properly provide for and include deaf people in clinical delivery. I know of the following Clinical Commissioning Groups who have considered the many aspects of this and are doing so:

  • NHS Cannock Chase CCG
  • NHS Derby and Derbyshire CCG
  • NHS East Staffordshire CCG
  • NHS Herefordshire and Worcestershire CCG
  • NHS Kent and Medway CCG
  • NHS North Staffordshire CCG
  • NHS South-East Staffordshire and Seisdon Peninsula CCG
  • NHS Staffordshire and Surrounds CCG
  • NHS Stoke-on-Trent CCG

The Scottish Government and NHS has also recognised the need for interpreters to be considered.

Therefore, for all the above reasons I urge you to do the same and prioritise a vital part of your integrated clinical frontline by make this crucial provision in delivering the vaccine program.

I would be grateful for your response to this request, via

Yours sincerely

Marcus Hawthorn
NRCPD Executive Director and Registrar

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