{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

---

Pressure Area Care and Tissue Viability Policy

1. Purpose

The purpose of this policy is to provide a clear framework for temporary workers supplied by {{org_field_name}} to recognise, prevent, report and appropriately respond to pressure area risks and tissue viability concerns while working on assignment within client organisations.

{{org_field_name}} operates as a temporary staffing agency and does not provide, manage or regulate care packages in its own right. Responsibility for the assessment, planning, delivery and review of regulated care remains with the client organisation, including the care home, nursing home, hospital, hospice or other healthcare setting where the worker is assigned.

{{org_field_name}} is committed to supplying workers who are appropriately recruited, checked, trained and, where applicable, professionally registered and competent for the assignments they undertake. Agency workers must follow this policy, the client organisation’s local policies, care plans, risk assessments, escalation procedures and professional standards relevant to their role.

This policy supports safe practice in line with current legislation and guidance relevant to temporary healthcare staffing in England, including the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Health and Safety at Work etc. Act 1974, the Care Act 2014, the Mental Capacity Act 2005, the Equality Act 2010, UK GDPR and the Data Protection Act 2018, NICE Clinical Guideline CG179, NICE Quality Standard QS89, the GOV.UK safeguarding adults protocol for pressure ulcers, the NMC Code for registered nurses, and relevant local client procedures.

Preventing avoidable pressure damage is essential to protecting people’s dignity, comfort, safety and wellbeing. Agency workers must act promptly where they identify risk, deterioration, poor skin integrity, possible neglect, unsafe care, equipment concerns or gaps in documentation.

2. Scope

This policy applies to:

• all temporary registered nurses, healthcare assistants, support workers and other workers supplied by {{org_field_name}} to client organisations;
• directors, consultants, booking staff and office-based staff involved in recruiting, vetting, training, booking, supporting or monitoring temporary workers;
• assignments in care homes, nursing homes, hospitals, hospices, supported living services, community health settings and similar client environments where workers may encounter people at risk of pressure damage.

This policy does not make {{org_field_name}} the provider of regulated care. The client organisation remains responsible for care planning, clinical governance, equipment provision, risk assessments, tissue viability referrals, safeguarding referrals and regulatory notifications unless otherwise expressly agreed in writing and legally permitted.

Agency workers must work within their role, competence, assignment instructions and professional registration, and must escalate concerns immediately to the client’s nurse-in-charge, manager or other designated person.

3. Regulatory Status of {{org_field_name}}

{{org_field_name}} is a temporary staffing agency. It supplies workers to client organisations but does not itself provide, direct or manage regulated care activities and is not registered with the Care Quality Commission.

{{org_field_name}} must not:

• assess people for care packages on behalf of the agency;
• create or own service-user care plans;
• direct, supervise or manage the day-to-day delivery of regulated care as the care provider;
• provide personal care, nursing care or treatment directly to individuals in its own name;
• hold itself out as a CQC-registered provider unless it becomes registered for a regulated activity.

Where an agency worker is on assignment, they act within the client organisation’s governance arrangements and must follow the client’s policies, care plans, reporting procedures, safeguarding arrangements, equipment instructions and escalation pathways.

If any proposed service model would involve {{org_field_name}} assessing, arranging, managing, directing or delivering care in its own right, the directors must obtain legal and regulatory advice before the service begins, as CQC registration may be required.

4. Related Policies

This policy should be read alongside the following {{org_field_name}} policies and procedures:

• Safeguarding Adults Policy;
• Mental Capacity and Consent Policy;
• Incident Reporting and Escalation Policy;
• Whistleblowing Policy;
• Complaints Policy;
• Record Keeping and Documentation Policy;
• Infection Prevention and Control Policy;
• Health and Safety Policy;
• Moving and Handling Policy;
• Medication Policy, where applicable to the worker’s role;
• Equality, Diversity and Inclusion Policy;
• Recruitment, Vetting and Selection Policy;
• Training and Competency Policy;
• Data Protection and Confidentiality Policy;
• Lone Working Policy, where applicable;
• Client Assignment and Booking Procedure.

5. Definitions
For the purpose of this policy:

• Agency worker means a registered nurse, healthcare assistant, support worker or other temporary worker supplied by {{org_field_name}} to work under the direction of a client organisation.
• Client organisation means the care home, nursing home, hospital, hospice, supported living provider, community healthcare provider or other organisation receiving temporary staffing services from {{org_field_name}}.
• Pressure ulcer means localised damage to the skin and/or underlying tissue, usually over a bony prominence, as a result of pressure, or pressure in combination with shear.
• Pressure damage means any suspected or confirmed harm to skin integrity caused or contributed to by pressure, shear, friction or a medical device.
• Tissue viability means the prevention, assessment and management of wounds and skin integrity concerns, including pressure ulcers and other forms of tissue damage.
• At risk means a person who may be vulnerable to pressure damage due to factors such as reduced mobility, frailty, poor nutrition or hydration, incontinence, acute illness, chronic illness, sensory impairment, previous pressure damage, end-of-life care needs or use of medical devices.
• Medical-device-related pressure damage means pressure damage caused by equipment or devices such as oxygen masks, tubing, catheters, splints, collars, continence products or other equipment in contact with the skin.
• Safeguarding concern means a concern that pressure damage may be linked to neglect, acts of omission, poor care, organisational abuse, unsafe systems or failure to respond to known risk.

6. Responsibilities

6.1 Directors and Senior Management

The directors and senior management of {{org_field_name}} are responsible for:

• maintaining and reviewing this policy;
• ensuring workers are recruited, vetted and supplied in line with the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003;
• ensuring workers receive appropriate induction and training relevant to pressure area care, tissue viability, safeguarding, record keeping, escalation and health and safety;
• confirming, as far as reasonably practicable, that workers are suitable for the assignments they are supplied to undertake;
• ensuring registered nurses have current NMC registration where the assignment requires registration;
• ensuring workers are reminded to work within their competence and assignment instructions;
• maintaining records of training, competency evidence, incidents, concerns and client feedback;
• responding to concerns raised by workers, clients, people receiving care, families or representatives;
• removing a worker from assignment or restricting duties where there are reasonable concerns about competence, conduct, safety or fitness to practise;
• co-operating with client investigations, safeguarding enquiries, professional referrals or statutory requests where lawful and appropriate.

6.2 Office and Booking Staff

Office and booking staff are responsible for:

• ensuring that relevant assignment information is obtained from the client before placing a worker;
• matching workers to assignments according to role, experience, training and any specific client requirements;
• passing relevant client instructions to workers before or at the start of an assignment;
• recording concerns raised by workers or clients and escalating them to a director or policy lead without delay;
• not giving clinical instructions unless they are clinically qualified, competent and authorised to do so.

6.3 Registered Nurses Supplied by {{org_field_name}}

Registered nurses must:

• comply with the NMC Code and maintain professional registration;
• work within their competence and scope of practice;
• follow the client organisation’s care plans, risk assessments, policies and escalation procedures;
• carry out, update or contribute to pressure ulcer risk assessments and skin assessments where this is part of their assigned role and they are competent to do so;
• recognise and respond promptly to pressure damage, deterioration, pain, infection risk, equipment issues or gaps in care;
• delegate only where appropriate and ensure that delegation is safe, clear and within the other worker’s competence;
• keep accurate, clear, factual and contemporaneous records;
• escalate concerns to the client’s nurse-in-charge, manager, tissue viability service or other appropriate professional in line with local procedure;
• report concerns to {{org_field_name}} where the concern relates to agency working, worker competence, unsafe systems, safeguarding, incidents or complaints.

6.4 Healthcare Assistants and Support Workers

Healthcare assistants and support workers must:

• work only within their training, competence and assignment instructions;
• follow the client organisation’s care plans, repositioning charts, moving and handling plans and local procedures;
• observe skin condition during personal care or assigned duties, where appropriate;
• report redness, discolouration, pain, broken skin, moisture damage, device marks, deterioration or any other concern immediately to the nurse-in-charge or client manager;
• not assess, grade, diagnose or treat pressure ulcers unless this is within their role, training and competence and is permitted by the client organisation;
• record care delivered in the client’s documentation system and complete any required {{org_field_name}} incident or concern form;
• seek guidance if instructions are unclear, unsafe or outside their competence.

6.5 Client Organisation

The client organisation remains responsible for:

• assessing people’s pressure ulcer risk;
• preparing and reviewing care plans;
• providing suitable equipment, including pressure-relieving mattresses, cushions and moving and handling aids;
• providing local induction, site-specific instructions and access to records;
• arranging tissue viability, GP, district nursing or other clinical referrals;
• making safeguarding referrals where required;
• making statutory notifications where applicable;
• ensuring its own compliance with CQC requirements where it is a registered provider.

7. Legal and Best Practice Framework

This policy is informed by the following legislation and guidance, as applicable to a temporary staffing agency operating in England:

• Employment Agencies Act 1973;
• Conduct of Employment Agencies and Employment Businesses Regulations 2003;
• Agency Workers Regulations 2010;
• Employment Rights Act 1996;
• Working Time Regulations 1998;
• National Minimum Wage Act 1998 and National Minimum Wage Regulations 2015;
• Equality Act 2010;
• Health and Safety at Work etc. Act 1974;
• Care Act 2014, including adult safeguarding duties;
• Mental Capacity Act 2005;
• Safeguarding Vulnerable Groups Act 2006;
• Police Act 1997 and Disclosure and Barring Service arrangements;
• Rehabilitation of Offenders Act 1974 and the Exceptions Order 1975, where applicable;
• UK GDPR and Data Protection Act 2018;
• NICE Clinical Guideline CG179: Pressure ulcers: prevention and management;
• NICE Quality Standard QS89: Pressure ulcers;
• GOV.UK safeguarding adults protocol: pressure ulcers and raising a safeguarding concern;
• NMC Code, for registered nurses;
• client organisation policies, procedures and care plans.

References to CQC requirements in this policy are included only to recognise the regulatory duties that may apply to client organisations that are CQC-registered providers. They do not mean that {{org_field_name}} is CQC registered or that it provides regulated activities.

8. Prevention of Pressure Ulcers

Prevention is central to safe care. Agency workers must support pressure ulcer prevention in line with their role, competence, client care plans and local procedures.

Agency workers must:

• consider pressure ulcer risk at each relevant contact, especially where a person has reduced mobility, frailty, acute illness, incontinence, poor nutrition, dehydration, sensory impairment or existing skin damage;
• follow the client’s care plan, risk assessment and repositioning schedule;
• use recognised risk assessment tools, such as Waterlow, Braden or PURPOSE-T, only where this forms part of the client’s procedure and the worker is trained and competent to do so;
• support regular repositioning, mobilisation and pressure relief in line with the care plan;
• check that pressure-relieving equipment is in place and appears to be functioning correctly;
• promote hydration and nutrition in line with the care plan and the person’s preferences;
• avoid dragging, pulling or causing shear during moving and handling;
• protect skin from excessive moisture, incontinence-associated damage and friction, following the client’s care plan;
• report immediately where care plans are absent, unclear, unsafe, not being followed or no longer suitable.

Agency workers must not change care plans, alter specialist equipment settings or introduce new interventions unless this is within their role, competence and authority under the client organisation’s procedures.

9. Risk Factors for Pressure Ulcers

Agency workers must be able to recognise and report factors that increase the risk of pressure damage, including:

• immobility or reduced mobility;
• prolonged sitting or bed rest;
• poor nutrition or dehydration;
• incontinence or excessive moisture;
• existing or previous pressure damage;
• acute illness, infection or deterioration;
• chronic illness, including diabetes, vascular disease or neurological conditions;
• reduced sensation or communication difficulties;
• advanced age, frailty or end-of-life care needs;
• pain that limits movement;
• poor circulation;
• medical devices pressing on the skin;
• poorly fitting equipment, footwear, splints or continence products;
• unsafe moving and handling practice;
• inadequate staffing, missed repositioning or missed care.

Any new or increasing risk must be reported promptly to the client’s nurse-in-charge or manager and documented in line with client procedures.

10. Skin Observation and Assessment

Agency workers must observe for signs of pressure damage during care delivery, where this is appropriate to their role and the person’s consent, dignity and privacy.

Registered nurses may complete or update formal skin assessments where this is part of the assignment, they are competent to do so and the client organisation’s procedure permits it.

Healthcare assistants and support workers must report concerns but must not diagnose, categorise or grade pressure ulcers unless specifically trained, competent and authorised by the client organisation.

Signs to report include:

• persistent redness or discolouration;
• purple, blue, grey, darker or warmer areas of skin;
• skin that feels unusually hard, boggy, hot or cold;
• swelling, blistering, broken skin or open wounds;
• pain, tenderness, itching or altered sensation;
• moisture damage, excoriation or maceration;
• marks or damage caused by medical devices;
• deterioration of an existing wound or pressure ulcer;
• signs of infection, including heat, odour, pus, increased pain or spreading redness.

Agency workers must be aware that pressure damage may be harder to identify on darker skin tones and may present as changes in skin tone, temperature, texture, pain or firmness rather than visible redness.

Any concern must be reported immediately to the client’s nurse-in-charge, manager or designated clinician and recorded in the client’s documentation system.

11. Repositioning

Repositioning must be carried out in line with the person’s care plan, moving and handling plan, risk assessment, consent and preferences.

Agency workers must:

• follow the client organisation’s repositioning schedule and equipment guidance;
• encourage people to reposition independently where safe and appropriate;
• use safe moving and handling techniques to reduce friction and shear;
• ensure call bells, personal items, hydration and pressure-relieving equipment are correctly positioned after care;
• document repositioning clearly, accurately and contemporaneously in the client’s records;
• report missed repositioning, refusal of care, pain, distress, equipment failure or inability to reposition safely.

Where a person refuses repositioning or pressure area care, the worker must respect the person’s rights, encourage and explain the benefits of care, report the refusal to the nurse-in-charge or manager, and document the refusal and actions taken.

12. Equipment

The client organisation is responsible for providing suitable, clean, safe and correctly maintained pressure-relieving and moving and handling equipment.

Agency workers must:

• use equipment only where they have been trained and are competent to do so;
• follow the client’s instructions for mattresses, cushions, slide sheets, hoists, slings, heel protectors and other equipment;
• check, before use, whether equipment appears clean, safe, correctly positioned and functioning;
• report faults, missing equipment, incorrect settings, contamination, damaged covers or unsafe use immediately to the client’s nurse-in-charge or manager;
• record equipment concerns in line with client procedures and notify {{org_field_name}} where the issue creates a safety risk for the person or worker.

Agency workers must not alter specialist pressure-relieving equipment settings unless this is within their competence and permitted by the client organisation’s procedure.

13. Documentation and Record Keeping

Agency workers must keep clear, accurate, factual, legible and contemporaneous records in the client organisation’s documentation system.

Records must include, where relevant to the worker’s role:

• skin observations;
• repositioning provided;
• personal care and continence care delivered;
• nutrition and hydration support provided;
• pressure-relieving equipment used;
• concerns identified;
• refusals of care;
• advice sought or given;
• escalation to the nurse-in-charge, manager, tissue viability nurse, GP, district nurse or other clinician;
• incident forms or body maps completed under the client’s procedure.

Records must not include unsupported opinions, blame, assumptions or judgemental language.

Where {{org_field_name}} requires an internal incident or concern report, this must be completed in addition to, and not instead of, the client organisation’s records.

Any records shared with {{org_field_name}} must be handled in line with UK GDPR, the Data Protection Act 2018 and the agency’s Data Protection and Confidentiality Policy.

14. Reporting and Escalation

Any new, suspected or deteriorating pressure damage must be treated as a significant concern and escalated without delay.

Agency workers must:

• report concerns immediately to the client’s nurse-in-charge, manager or designated clinician;
• follow the client organisation’s local pressure ulcer, tissue viability, incident reporting and safeguarding procedures;
• complete the client’s documentation, body map, wound chart, incident form or electronic record where required and within their role;
• notify {{org_field_name}} as soon as practicable where the concern involves an agency worker, missed care, unsafe staffing, unsafe systems, safeguarding, equipment failure, client instructions that appear unsafe, or any incident that may lead to a complaint, investigation or claim;
• escalate again if no appropriate action is taken by the client organisation and the person remains at risk.

Where there is immediate risk of serious harm, the worker must seek urgent clinical or emergency assistance in line with the client organisation’s procedure.

If the worker believes that pressure damage may be linked to neglect, acts of omission, organisational abuse or failure to provide necessary care, this must be escalated as a safeguarding concern in line with the client organisation’s safeguarding procedure and {{org_field_name}}’s Safeguarding Adults Policy.

For CQC-registered client organisations, statutory Duty of Candour obligations rest with the registered provider and registered manager. {{org_field_name}} will co-operate with the client organisation where openness, investigation, information sharing or worker statements are required. Registered nurses must also follow the professional duty of candour and the NMC Code.

15. Safeguarding Interface for Pressure Ulcers

Pressure ulcers are not automatically a safeguarding concern. However, a safeguarding concern must be considered where pressure damage may have resulted from neglect, acts of omission, poor care, deliberate harm, organisational abuse, failure to follow care plans, failure to provide equipment, failure to escalate deterioration or repeated missed care.

Agency workers must follow the GOV.UK safeguarding adults protocol for pressure ulcers and the client organisation’s local safeguarding procedure.

Factors that may indicate a safeguarding concern include:

• unexplained pressure damage;
• significant deterioration without appropriate action;
• repeated missed repositioning or personal care;
• absence of a care plan or risk assessment where one is required;
• failure to obtain or use pressure-relieving equipment;
• poor hygiene, prolonged soiling or moisture damage;
• failure to seek clinical advice;
• falsified, missing or inaccurate records;
• concerns raised by the person, family, representative or staff;
• any indication of wilful neglect or organisational abuse.

The worker must report the concern to the client manager or nurse-in-charge and to {{org_field_name}}. If the worker believes the concern has not been acted upon and the person remains at risk, they must escalate under {{org_field_name}}’s Safeguarding Adults Policy and Whistleblowing Policy.

16. Training and Competency

{{org_field_name}} will ensure that workers receive training appropriate to their role and assignments. Training may include:

• pressure ulcer awareness and prevention;
• tissue viability awareness;
• identifying risk factors and early warning signs;
• skin observation and escalation;
• repositioning and safe moving and handling;
• use of pressure-relieving equipment, where relevant;
• documentation and record keeping;
• safeguarding adults and pressure ulcer safeguarding concerns;
• infection prevention and control;
• Mental Capacity Act and consent;
• equality, diversity and recognising pressure damage on different skin tones;
• incident reporting and whistleblowing.

Registered nurses must maintain professional competence in line with NMC requirements. Healthcare assistants and support workers must complete training appropriate to their role, which may include Care Certificate standards where relevant.

Workers must not undertake pressure ulcer assessment, grading, wound care, equipment adjustment or delegated clinical tasks unless they have the necessary training, competence and authority from the client organisation.

{{org_field_name}} will review training following incidents, complaints, safeguarding concerns, client feedback or changes in guidance.

17. Communication and Teamwork

Agency workers must communicate promptly, clearly and respectfully with client staff, people receiving care, families, representatives and other professionals, within confidentiality requirements.

Agency workers must:

• participate in handovers where required;
• share relevant pressure area concerns with the nurse-in-charge or manager;
• confirm unclear instructions before providing care;
• report changes in risk, skin condition, pain, mobility, continence, nutrition or hydration;
• document information given and received;
• respect the person’s dignity, choices, privacy and preferences;
• balance choice and risk in line with the Mental Capacity Act 2005 and client procedures.

Agency workers must not promise outcomes, provide unauthorised clinical opinions or communicate investigation findings unless authorised to do so by the client organisation and {{org_field_name}}.

18. Equality, Diversity and Inclusion

{{org_field_name}} is committed to equality, dignity and non-discriminatory care.

Agency workers must:

• treat every person with dignity, respect and compassion;
• recognise that pressure damage may be harder to identify on darker skin tones;
• consider pain, texture, temperature, firmness, swelling and the person’s own reports as well as visible colour change;
• take account of disability, communication needs, sensory impairment, cultural needs, religious needs and personal preferences;
• use appropriate communication support where required;
• avoid assumptions based on age, disability, race, sex, gender reassignment, religion or belief, sexual orientation, pregnancy or maternity, marriage or civil partnership.

Any concern that a person’s skin integrity needs are not being met because of discrimination, communication barriers or failure to make reasonable adjustments must be escalated to the client manager and {{org_field_name}}.

19. Supervision and Support

{{org_field_name}} will provide reasonable support to workers in relation to pressure area care and tissue viability concerns arising during assignments.

Support may include:

• guidance on agency reporting and escalation procedures;
• advice on how to raise concerns with the client organisation;
• support following incidents, complaints, safeguarding concerns or distressing events;
• review of training or competency needs;
• restriction of assignments where additional training or supervision is required;
• referral to professional, regulatory or safeguarding bodies where necessary and appropriate.

Clinical supervision and day-to-day direction during an assignment remain the responsibility of the client organisation unless otherwise agreed in writing and legally permitted.

20. Monitoring and Quality Assurance

{{org_field_name}} will monitor the effectiveness of this policy through:

• review of incidents and concerns involving pressure area care or tissue viability;
• client feedback;
• worker feedback;
• complaints and compliments;
• safeguarding concerns;
• training compliance records;
• competency concerns;
• patterns of cancelled shifts, refused assignments or unsafe placement feedback;
• lessons learned from investigations.

Where concerns are identified, {{org_field_name}} may take action including additional training, supervision, suspension from particular assignment types, removal from assignment, referral to the client organisation, referral to the NMC, referral to the DBS, safeguarding escalation or changes to agency procedures.

{{org_field_name}} will co-operate with client organisations in investigations where lawful and appropriate but will not assume the client provider’s regulatory responsibilities.

21. Policy Review

This policy will be reviewed at least annually by the directors of {{org_field_name}}, or earlier where:

• there are changes to legislation, national guidance, NICE guidance, safeguarding guidance or professional standards;
• there are changes to the services provided by {{org_field_name}};
• the agency considers undertaking any activity that may require CQC registration;
• incidents, complaints, safeguarding concerns, audits or client feedback indicate that improvements are required;
• best practice developments emerge in relation to pressure area care, tissue viability or temporary healthcare staffing.

References to CQC requirements will be reviewed to ensure the policy remains accurate for a non-CQC-registered temporary staffing agency.

---

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.