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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Nutritional and Hydration Support Policy

1. Purpose

The purpose of this Nutritional and Hydration Support Policy is to provide clear, lawful and professional guidance to temporary workers supplied by {{org_field_name}} on how to support safe, respectful and person-centred nutrition and hydration when working on assignment within health and social care environments.

{{org_field_name}} operates as an employment business supplying temporary workers to client organisations. It does not directly provide regulated care activities and is not required to register with the Care Quality Commission unless it begins carrying on regulated activities itself. The client organisation remains responsible for assessing service users’ needs, preparing and reviewing care plans, meeting CQC-regulated provider obligations where applicable, and supervising the delivery of care within its service.

{{org_field_name}} is responsible for ensuring, so far as is reasonably practicable, that temporary workers supplied to client organisations are appropriately recruited, checked, trained, informed and instructed for the assignments they undertake. Temporary workers must follow the client organisation’s care plans, risk assessments, food safety procedures, safeguarding procedures and escalation arrangements at all times.

This policy supports compliance with employment agency legislation, agency worker rights, safeguarding requirements, data protection duties, health and safety obligations and relevant good practice guidance on nutrition and hydration, including NICE Quality Standard QS24 where applicable to the care setting.

2. Scope

This policy applies to:

• All temporary workers, agency workers, workers, employees, contractors and candidates supplied or engaged by {{org_field_name}}, including registered nurses, healthcare assistants, support workers and other staff engaged on temporary, casual, zero-hours, low-hours or assignment-based arrangements.
• This policy must be read alongside each worker’s written terms, key information document, assignment details and any client-specific instructions issued before or during an assignment.
• All client organisations receiving staffing services from {{org_field_name}}, including residential care homes, nursing homes, supported living services, hospitals, hospices and other health or social care settings, whether or not the client organisation is CQC registered.
• All circumstances in which temporary workers are involved in supporting, assisting, or monitoring service users’ nutrition and hydration as part of their duties

This policy applies to both planned care and the management of unforeseen circumstances affecting nutrition and hydration, such as deterioration, illness, or changes in a service user’s condition.

This policy does not authorise temporary workers to undertake tasks outside their competence, training, professional registration, assignment instructions or the client organisation’s care plan. Temporary workers must not independently assess, prescribe, amend diets, alter fluid restrictions, commence artificial nutrition, change texture-modified diets, or make clinical decisions unless this is within their professional scope of practice and authorised by the client organisation.

3. Related Policies

• Safeguarding Adults and Children Policy
• Infection Prevention and Control Policy
• Health and Safety Policy
• Incident Reporting and Management Policy
• Record Keeping and Confidentiality Policy
• Code of Conduct for Temporary Workers
• Equality, Diversity, and Inclusion Policy

• Recruitment, Selection and Vetting Policy
• Right to Work Policy
• DBS and Barring Checks Policy
• Agency Worker Terms and Key Information Document Procedure
• Working Time and Rest Breaks Policy
• Manual Handling Policy
• Food Safety and Hygiene Policy
• Medication Management Policy, where applicable
• Mental Capacity and Consent Policy
• Whistleblowing Policy
• Complaints Policy
• Data Protection, Records Retention and Confidentiality Policy

4. Legal and Regulatory Framework

This policy is underpinned by the following legislation, regulations and guidance, as applicable to {{org_field_name}} as an employment business supplying temporary workers in England:

• Employment Agencies Act 1973 – regulating employment agencies and employment businesses, including restrictions on charging fees to work-seekers and enforcement powers.
• Conduct of Employment Agencies and Employment Businesses Regulations 2003, as amended – including requirements relating to terms with work-seekers and hirers, provision of key information documents, suitability, work-seeker information, hirer information, restrictions on detrimental conduct, records and transfer fees.
• Agency Workers Regulations 2010 – including day-one rights to access collective facilities and vacancy information and equal treatment in basic working and employment conditions after the qualifying period.
• Employment Rights Act 1996 and Employment Rights Act 2025 – including worker protections, wage deductions, statutory rights and new rights affecting zero-hours, low-hours and agency workers as those provisions come into force.
• Working Time Regulations 1998 – including working time limits, rest breaks and paid annual leave.
• National Minimum Wage Act 1998 and National Minimum Wage Regulations 2015 – requiring payment of at least the applicable minimum wage for working time.
• Equality Act 2010 – including non-discrimination in recruitment, supply of workers and the provision of services, and respect for dietary needs linked to religion, belief, disability or other protected characteristics.
• Immigration, Asylum and Nationality Act 2006 and current Home Office right-to-work guidance – requiring compliant right-to-work checks before work starts and follow-up checks where required.
• Safeguarding Vulnerable Groups Act 2006, Police Act 1997 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 – relevant to DBS checks, barred list checks and regulated activity.
• UK GDPR and Data Protection Act 2018 – covering candidate, worker and client information, including health data, safeguarding information and DBS information.
• Health and Safety at Work etc. Act 1974 and related health and safety regulations – requiring co-operation between {{org_field_name}}, temporary workers and client organisations to protect health and safety.
• Food Safety Act 1990 and Food Safety and Hygiene (England) Regulations 2013 – relevant where temporary workers handle, prepare, serve, reheat or support access to food and drink.
• Mental Capacity Act 2005 – where a service user may lack capacity to make decisions about eating, drinking, diet, consent or refusal.
• Care Act 2014 – including safeguarding duties and the promotion of wellbeing by local authorities and relevant partners.
• Human Rights Act 1998 – including respect for dignity, autonomy, private life, family life and freedom of thought, conscience and religion.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulation 14 on meeting nutritional and hydration needs, where temporary workers are assigned into a CQC-regulated service. These duties apply directly to the registered provider, but temporary workers supplied by {{org_field_name}} must support the client organisation by following its care plans, policies, risk assessments and lawful instructions.
• NICE Quality Standard QS24: Nutrition support in adults, where relevant to the setting and service user group.

5. Principles

Temporary workers are expected to:

• Support and promote service users’ nutritional and hydration needs in line with the client organisation’s care plan, risk assessments, food safety procedures and lawful instructions.
• Support access to sufficient food and drink during the assignment, unless restricted by the service user’s care plan, clinical instructions, swallowing assessment, allergy requirements, fasting arrangements or other documented restriction.
• Recognise the role of nutrition and hydration in promoting health, preventing deterioration, and maintaining dignity
• Follow person-centred care principles by respecting the preferences, cultural needs, dietary requirements, and choices of service users
• Act promptly if a service user is identified as at risk of malnutrition, dehydration, or choking
• Work in partnership with client organisations to ensure safe and appropriate care is provided

• Work only within their competence, training, professional registration and assignment instructions.
• Respect the service user’s consent, capacity, preferences, dignity, privacy, independence, culture, religion and protected characteristics.
• Follow the client organisation’s escalation process immediately where nutrition, hydration, choking, swallowing, allergy, neglect or food safety concerns arise.
• Never alter a care plan, diet, fluid restriction, thickened-fluid requirement, texture-modified diet or clinical instruction unless authorised to do so by the client organisation and, where relevant, this falls within the worker’s professional scope of practice.

6. Temporary Workers’ Responsibilities

Temporary workers must:

• Follow the client’s care plan relating to nutrition and hydration at all times

• Read and follow the assignment details, client induction information and client-specific nutrition, hydration, food safety, infection control, safeguarding and emergency procedures.
• Confirm with the person in charge at the client organisation where they are unsure about any service user’s diet, allergies, fluid restrictions, swallowing requirements, fasting arrangements, food texture, positioning or level of assistance required.
• Check whether the service user has any documented allergies, intolerances, choking risks, modified-texture diet, thickened-fluid requirement, nil-by-mouth instruction, diabetes-related dietary requirements, renal/fluid restriction, end-of-life care plan or other relevant instruction before providing support.
• Wear any required personal protective equipment and follow infection prevention and food hygiene procedures when handling, serving or assisting with food and drink.
• Report concerns promptly to the client organisation’s nurse, senior carer, manager or other nominated person and to {{org_field_name}} where the concern relates to worker safety, competence, safeguarding, poor practice, an incident, a complaint or a refusal of essential care.

• Support service users in accordance with their individual preferences and capacity
• Observe, monitor, and report any signs of poor nutritional intake, weight loss, dehydration, or swallowing difficulties
• Promote a positive and enjoyable dining experience
• Maintain accurate records of food and fluid intake when required by the client’s procedures
• Refer any concerns about a client’s nutritional or hydration status promptly to the appropriate person within the client organisation and to {{org_field_name}}

6.1 {{org_field_name}}’s Responsibilities as an Employment Business

{{org_field_name}} will:

• Obtain sufficient information from the client organisation about the assignment, duties, working environment, required experience, training, qualifications, professional registration and known health and safety risks before supplying a temporary worker.
• Take reasonable steps to ensure that temporary workers supplied are suitable for the assignment, including appropriate recruitment checks, identity checks, right-to-work checks, employment history, references, professional registration checks where applicable, DBS checks where legally eligible and required, and training verification.
• Provide temporary workers with written terms and a key information document where required before agreeing terms with them.
• Provide assignment information to temporary workers, including the client organisation, location, start time, expected duties, pay arrangements, required checks, required training and any known health and safety information.
• Confirm that client organisations remain responsible for service user assessment, care planning, clinical decision-making, supervision and compliance with CQC provider duties where the client is a regulated provider.
• Maintain appropriate records in accordance with the Conduct Regulations, data protection requirements and {{org_field_name}}’s records retention procedures.
• Monitor incidents, complaints, safeguarding concerns and client feedback relating to nutrition and hydration support and take appropriate action, including removing a worker from an assignment where necessary.

6.2 Client Organisation Responsibilities

Client organisations are responsible for:

• Assessing each service user’s nutrition and hydration needs.
• Preparing, reviewing and updating care plans, risk assessments, nutrition plans, hydration plans, swallowing guidance, allergy information and food safety arrangements.
• Providing local induction, supervision and access to relevant records, policies and procedures.
• Informing {{org_field_name}} of the skills, experience, qualifications, training and checks required for each assignment.
• Providing safe systems of work, safe premises, suitable equipment, appropriate PPE and instructions for the duties to be undertaken.
• Ensuring that temporary workers are not asked to work outside their competence, role, professional registration or assignment terms.
• Meeting CQC-regulated provider duties where the client organisation is registered with CQC.

7. Assessment and Care Planning

Temporary workers must:

• Familiarise themselves with each client’s individual care plan on arrival at the client’s premises
• Follow and support the implementation of care plans prepared by the client organisation, including plans informed by nutritional screening tools such as MUST or equivalent, where used by the client organisation.
• Recognise and report signs of malnutrition (e.g., significant weight loss, reduced appetite) and dehydration (e.g., dry mouth, confusion, reduced urine output)
• Record findings clearly and promptly using the documentation system in place at the client organisation
• Respect dietary restrictions due to allergies, intolerances, religious or cultural beliefs, or medical conditions

Temporary workers must not conduct formal nutritional assessments, create care plans, amend care plans, prescribe nutrition support, alter prescribed diets or make clinical decisions unless this is expressly within their professional role, competence, registration and the client organisation’s instructions. Their usual role is to observe, support, record and promptly report concerns to the appropriate person within the client organisation.

8. Supporting Safe Eating and Drinking

Temporary workers must:

• Promote independence, encouraging clients to eat and drink for themselves whenever possible
• Provide support sensitively to clients who require assistance with eating and drinking, ensuring dignity and comfort
• Follow any speech and language therapist (SALT) recommendations or other specialist advice provided in the care plan regarding swallowing difficulties

• Check and follow any International Dysphagia Diet Standardisation Initiative (IDDSI), texture-modified diet, thickened-fluid, positioning, pacing, supervision or choking-risk instructions used by the client organisation.
• Do not give food or fluids that conflict with documented allergy information, swallowing guidance, dietary restrictions, nil-by-mouth instructions, fasting requirements or clinical instructions.
• Ensure the service user is alert, appropriately positioned and supported before assistance is provided, in line with the care plan and client procedures.
• Stop assisting immediately and seek urgent help if the service user shows signs of choking, aspiration, coughing during swallowing, wet or gurgly voice, sudden breathlessness, distress, reduced consciousness or any other concerning change.

• Follow safe positioning and feeding practices to reduce the risk of aspiration and choking
• Never force a service user to eat or drink. Refusals must be respected, recorded and reported in line with the client organisation’s procedures. Where refusal may create immediate or serious risk, the temporary worker must escalate without delay to the person in charge.

8.1 Food Hygiene, Allergens and Safe Handling

Where temporary workers handle, prepare, serve, reheat or assist with food and drink, they must:

• Follow the client organisation’s food safety, food hygiene, allergen management and infection prevention procedures.
• Wash hands and use PPE where required before handling food, drinks, utensils or feeding equipment.
• Check allergy, intolerance and dietary information before offering or serving food or drink.
• Avoid cross-contamination, including allergen cross-contamination, by using the correct utensils, crockery, preparation areas and storage arrangements.
• Follow the client organisation’s instructions for storage, temperature control, reheating, chilled items, expiry dates, labelling and disposal of food.
• Report unsafe food practices, suspected food poisoning, contaminated food, incorrect meals, missing allergen information or concerns about food hygiene immediately to the person in charge.
• Not prepare or serve food where they have symptoms that may present an infection risk, including vomiting, diarrhoea or other symptoms specified by the client organisation’s infection control policy.

9. Cultural, Religious, and Personal Preferences

Temporary workers must:

• Ensure clients’ cultural, religious, or personal food preferences are respected at all times
• Liaise with client staff when unfamiliar with particular dietary needs to ensure appropriate foods and drinks are offered
• Take into account fasting practices and religious observances when supporting individuals
• Respect the client’s choices even when they differ from the worker’s personal beliefs

• Recognise that dietary requirements may relate to protected characteristics under the Equality Act 2010, including religion or belief, disability, race or pregnancy and maternity.
• Support reasonable adjustments and person-centred arrangements identified in the care plan, including accessible mealtime support, adapted utensils, communication aids, assistance for visual impairment or support for service users with dementia or learning disabilities.
• Escalate any conflict between a service user’s preference and a documented clinical, allergy, choking or safeguarding risk to the person in charge rather than making an independent decision.

10. Fluid Intake and Hydration Support

Temporary workers must:

• Support service users to access fluids during the assignment, unless restricted by the care plan, clinical instruction, swallowing guidance or other documented requirement.
• Encourage regular fluid intake, especially for older people or those at risk of dehydration
• Monitor for signs of dehydration, including dry skin, confusion, constipation, or reduced urine output
• Record fluid intake accurately where care plans or risk assessments require monitoring
• Report concerns about hydration to the client’s responsible person and {{org_field_name}}

• Check whether the service user has a fluid restriction, thickened-fluid requirement, nil-by-mouth instruction, diabetes-related care plan, renal care plan, end-of-life care plan or other clinical instruction before encouraging or providing fluids.
• Follow the client organisation’s fluid balance chart or hydration monitoring process where one is in place.
• Report repeated refusal of fluids, signs of dehydration, difficulty swallowing, vomiting, diarrhoea, fever, confusion, reduced urine output or any sudden change in presentation without delay.

11. Responding to Nutritional and Hydration Concerns

Temporary workers must:

• Act immediately if a client shows signs of distress while eating or drinking (e.g., choking, difficulty swallowing)
• Notify senior staff at the client organisation without delay and follow emergency procedures if required
• Document all incidents, refusals, or concerns clearly in the client’s records and notify {{org_field_name}} if appropriate
• Share factual observations with the client organisation’s team so that the client organisation can review, develop or adjust the care plan where required.
• Engage in debriefs or reflective supervision following incidents to improve practice

• Call emergency assistance or follow the client organisation’s emergency procedure immediately where there is choking, suspected aspiration, collapse, severe allergic reaction, loss of consciousness or any other emergency.
• Report any incident, near miss, refusal, choking episode, suspected aspiration, suspected dehydration, suspected malnutrition, incorrect diet, incorrect fluid consistency, allergen exposure or safeguarding concern to the person in charge and to {{org_field_name}} in accordance with reporting procedures.
• Preserve factual records and do not alter client records after the event except through the client organisation’s approved correction process.

12. Record Keeping and Documentation

Temporary workers must:

• Keep accurate, legible, and timely records of food and fluid intake where required by the client organisation
• Document any refusals, concerns, or interventions related to nutrition or hydration
• Complete client-specific documentation systems, whether paper-based or electronic
• Ensure all records are treated as confidential and handled in accordance with {{org_field_name}}’s Data Protection, Records Retention and Confidentiality Policy, the client organisation’s records procedures, the UK GDPR and the Data Protection Act 2018.

• Record only factual, relevant, accurate and timely information.
• Do not remove, copy, photograph or share service user records unless authorised by the client organisation and permitted by law.
• Do not share service user information through personal email, personal messaging apps, social media or unauthorised devices.
• Report any suspected data breach immediately to the client organisation and {{org_field_name}}.

13. Safeguarding and Nutritional Neglect

Poor nutrition or hydration may indicate neglect, organisational abuse, self-neglect, acts of omission, discriminatory abuse or unsafe care, depending on the circumstances. Temporary workers must:

• Treat inadequate provision of food or fluids, missed meals, or forced feeding as safeguarding concerns
• Report any suspicions or evidence of neglect immediately to the client’s responsible person and {{org_field_name}} in line with the Safeguarding Adults and Children Policy
• Record safeguarding concerns factually and accurately
• Cooperate fully with any safeguarding enquiry, investigation, client review, local authority enquiry, police enquiry, professional regulator process or CQC inspection of the client organisation, where lawful and appropriate.

• Escalate immediately where a service user is repeatedly left without food or fluids, receives food or fluids that are unsafe for them, is denied support to eat or drink, is forced to eat or drink, is given food contrary to known allergies or swallowing guidance, or is placed at risk through poor staffing, poor supervision or poor practice.
• Follow {{org_field_name}}’s whistleblowing procedure where concerns are not acted upon by the client organisation or where the worker believes a person remains at risk.
• Recognise that a temporary worker may be personally accountable for failing to report serious concerns witnessed during an assignment.

14. Training

{{org_field_name}} will:

• Ensure that all temporary workers receive training on supporting nutrition and hydration as part of their induction
• Provide refresher training when required, especially following incidents, complaints, or changes in legislation
• Ensure workers understand that, where they are assigned into a CQC-regulated service, they must follow the client organisation’s policies and care plans that support the client’s compliance with applicable CQC Fundamental Standards, including Regulation 14 on nutrition and hydration.
• Include topics such as recognising malnutrition and dehydration, supporting safe feeding, and respecting cultural dietary needs

• Verify role-appropriate training before placement, which may include nutrition and hydration, food hygiene, infection prevention and control, safeguarding, mental capacity, moving and handling, basic life support, choking response, allergies and dysphagia awareness, depending on the assignment.
• Check professional registration, qualifications and role-specific competencies where required for the assignment.
• Record training, expiry dates and refresher requirements.
• Ensure workers are not supplied to assignments requiring specialist skills unless those skills have been verified.

Temporary workers must:

• Complete mandatory training before undertaking assignments
• Participate in ongoing learning and supervision related to nutrition and hydration
• Seek guidance when unsure about client needs or safe practices

• Not undertake any nutrition, hydration, feeding, dysphagia-related, clinical or specialist task unless trained, competent and authorised to do so.
• Tell {{org_field_name}} and the client organisation immediately if they feel unable or insufficiently trained to carry out a requested task safely.

15. Director’s or Senior Responsible Officer’s Responsibilities

As {{org_field_name}} is not a CQC-registered provider and does not have a CQC registered manager, the director or nominated senior responsible officer will:

• Take full responsibility for the implementation, monitoring, and review of this policy
• Oversee training delivery to ensure all workers are competent in nutritional and hydration support
• Review all incidents, complaints, or concerns related to nutrition and hydration
• Liaise with client organisations, employment law enforcement bodies, safeguarding bodies, professional regulators and other relevant authorities where appropriate, recognising that CQC-regulated provider duties remain with the client organisation unless {{org_field_name}} begins carrying on regulated activities itself.
• Support temporary workers with reflective supervision and debriefs following incidents involving nutrition and hydration

16. Working with Clients

{{org_field_name}} will:

• Ensure that temporary workers are made aware of client-specific policies and procedures relating to nutrition and hydration upon placement
• Supply appropriately checked, trained and suitable temporary workers and co-operate with client organisations to support safe assignment delivery. Where the client organisation is CQC registered, the client remains responsible for meeting CQC Fundamental Standards, including Regulation 14, and {{org_field_name}} will require temporary workers to follow the client’s lawful instructions, care plans and procedures.
• Cooperate fully with clients when responding to incidents, complaints, or concerns
• Share learning from incidents and audits with clients to improve practice and outcomes

• Obtain sufficient assignment information from the client before supply, including duties, risks, required training, required checks, supervision arrangements and any nutrition or hydration responsibilities expected of the worker.
• Request clarification before supplying a worker where the assignment appears to involve duties outside the worker’s role, competence, training or professional registration.
• Agree escalation routes for incidents, complaints, safeguarding concerns, food safety concerns and worker competence concerns.

17. Right to Work, DBS and Suitability Checks

Before supplying a temporary worker, {{org_field_name}} will complete appropriate pre-assignment checks, which may include:

• Identity checks.
• Right-to-work checks completed before work starts and repeated where required.
• Employment history and references.
• Qualification and training checks.
• Professional registration checks, including NMC or other relevant registers where applicable.
• DBS checks at the legally permitted level for the role, including barred list checks only where the role is eligible and involves regulated activity.
• Checks against any relevant restriction, suspension, warning or fitness-to-practise information where applicable and lawful.

{{org_field_name}} will not request a DBS check at a higher level than permitted by law. Where a role involves regulated activity with adults or children, {{org_field_name}} will follow applicable safeguarding and barred list requirements. Workers must immediately inform {{org_field_name}} of any change that may affect their suitability, right to work, professional registration, criminal record status, health, competence or ability to perform assignments safely.

18. Agency Worker Rights and Working Conditions

{{org_field_name}} will comply with applicable agency worker and employment business requirements, including:

• Providing written terms and a key information document where required.
• Providing assignment information before the assignment starts.
• Ensuring workers are paid lawfully and receive at least the applicable National Minimum Wage for working time.
• Managing holiday entitlement and working time in accordance with applicable law.
• Supporting compliance with Agency Workers Regulations 2010 rights, including day-one access to relevant collective facilities and vacancy information at the hirer, and equal treatment in basic working and employment conditions after the qualifying period.
• Monitoring implementation of relevant Employment Rights Act 2025 changes affecting zero-hours, low-hours and agency workers as they come into force.
• Keeping appropriate records in accordance with the Conduct Regulations and related employment law requirements.

19. Continuous Improvement

The director will:

• Review this policy annually or sooner if required by legislation or changes in best practice
• Use incident data, worker feedback, client feedback, and audit findings to improve policy and training
• Promote a culture of continuous learning and quality improvement across all areas of nutrition and hydration support

• Review updates from GOV.UK, the Employment Agency Standards Inspectorate or successor enforcement body, ACAS, HSE, ICO, DBS, CQC, NICE and the Food Standards Agency where relevant.
• Update this policy promptly where changes to employment agency law, agency worker rights, right-to-work checks, safeguarding, food safety, data protection, health and safety or care-sector guidance affect the business.
• Audit a sample of assignment records, training records, complaints, incidents and safeguarding concerns to identify learning.

20. Policy Review

This policy will be reviewed at least annually by the director or nominated senior responsible officer, or sooner where required due to legislative, regulatory, contractual, safeguarding, operational or best-practice changes.

The review will include consideration of changes affecting employment businesses, agency worker rights, right-to-work checks, DBS and safeguarding requirements, data protection, health and safety, food safety, CQC-regulated client environments and NICE or other relevant guidance.

Any material updates will be communicated to relevant temporary workers, internal staff and client organisations where appropriate.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.