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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Occupational Health Screening and Medical Reports Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} has safe, fair, lawful and proportionate arrangements for assessing and supporting the health and fitness of staff, workers, volunteers and applicants who work in or may work in the domiciliary support service. The policy supports compliance with the Regulation and Inspection of Social Care (Wales) Act 2016, The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, and the Welsh Government statutory guidance for domiciliary support services. In particular, it supports the provider’s duty to ensure that persons working at the service are fit to do so and are able, by reason of their health and after any reasonable adjustments have been made, to properly perform the tasks intrinsic to the role.

This policy also ensures that occupational health information is collected only where necessary, proportionate and justified; is handled confidentially as special category data; and is used to support safe care, staff wellbeing, reasonable adjustments and lawful employment decision-making.

This policy aims to:

• Assess and monitor the health of employees to ensure they are fit for their roles.
• Prevent and manage work-related illnesses and health conditions.
• Support employees with medical conditions or disabilities through reasonable adjustments.
• Ensure compliance with statutory health checks required for specific job roles.
• Protect service users by ensuring staff are physically and mentally fit to provide care.

2. Scope

This policy applies to:

• All employees, including care workers, managers, and administrative staff.
• Job applicants undergoing pre-employment health screening.
• The Registered Manager and Responsible Individual, ensuring compliance.
• External occupational health providers, where applicable.

For the purposes of this policy, “staff” includes employees, workers, persons engaged under a contract for services, agency workers, volunteers where applicable, managers, administrative staff whose role may affect service delivery, and any other person whose duties may bring them into contact with individuals receiving care and support. Agency workers and externally supplied staff must be subject to equivalent fitness, health and suitability assurances before they work in the service.

This policy applies at recruitment, during employment or engagement, following sickness absence, where a health condition or disability may affect the person’s role, following a workplace accident or exposure incident, where a risk assessment identifies a need for health surveillance, and where there is a concern that a person may no longer be fit to work safely.

3. Legal and Regulatory Framework

This policy is underpinned by the following legislation, statutory guidance and regulatory expectations:

• Wales social care regulation
• The Regulation and Inspection of Social Care (Wales) Act 2016.
• The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, including Regulation 35, Fitness of Staff; Regulation 36, Supporting and Developing Staff; and Regulation 21, Standards of Care and Support.
• Welsh Government statutory guidance for service providers and responsible individuals on meeting service standard regulations for domiciliary support services, Version 3, March 2024.
• CIW Code of Practice for Inspection of Regulated Services and CIW inspection framework for care home and domiciliary support services, including inspection themes of Well-being, Care and Support, Leadership and Management and, where applicable, Environment.
• Social Care Wales Codes of Professional Practice and Code of Practice for Employers of Social Care Workers.
• Employment, equality and occupational health
• Health and Safety at Work etc. Act 1974.
• Management of Health and Safety at Work Regulations 1999.
• Manual Handling Operations Regulations 1992.
• Control of Substances Hazardous to Health Regulations 2002, where staff may be exposed to substances hazardous to health, including biological agents.
• Equality Act 2010, including the duty to make reasonable adjustments and restrictions on pre-employment health questions except where legally permitted.
• Employment Rights Act 1996.
• Working Time Regulations 1998, where health concerns relate to working time, fatigue, rest breaks or night work.
• Access to Medical Reports Act 1988, where {{org_field_name}} requests a medical report from a medical practitioner who is, or has been, responsible for the worker’s clinical care.
• Data protection and confidentiality
• UK General Data Protection Regulation and Data Protection Act 2018, including requirements for special category health data.
• The common law duty of confidentiality and relevant professional confidentiality obligations.
• Public health and infection prevention
• Public Health Wales and NHS Wales infection prevention and immunisation guidance relevant to social care settings.
• Any current local health board, public health or commissioning guidance applicable to infectious disease risks in domiciliary support services.

4. Occupational Health Screening Process

4.1 Pre-Employment Health Screening

Health information will not be requested from applicants before an offer of employment or engagement is made, except where this is legally permitted, necessary and proportionate, for example to establish whether reasonable adjustments are needed for the recruitment process, to assess whether an applicant can carry out a function that is intrinsic to the role, or where there is a specific legal or health and safety requirement.

Following a conditional offer of employment or engagement, applicants for care-related roles may be asked to complete a health declaration or occupational health questionnaire that is limited to information necessary to assess fitness for the role, identify reasonable adjustments, and protect the health, safety and wellbeing of the applicant, staff and individuals receiving care and support.

Any occupational health questionnaire must be role-specific, proportionate and limited to the requirements of the post. It must not be used to discriminate unlawfully or to withdraw an offer without proper consideration of reasonable adjustments and occupational health advice where appropriate.

How we manage this efficiently:

• A structured health questionnaire is used for consistency.
• Occupational health assessments are conducted only where necessary to avoid discrimination.
• Medical reports are kept confidential and compliant with GDPR.

A person will be considered fit to work in the service only where {{org_field_name}} is satisfied that the person:

• has the health, after any reasonable adjustments have been considered and made where required, to properly perform the tasks intrinsic to the role;
• can work safely without placing individuals receiving care and support, colleagues or themselves at avoidable risk;
• has any required occupational health clearance or risk assessment for duties involving specific health risks; and
• has provided sufficient information to allow {{org_field_name}} to make a safe and lawful decision.

Where health information indicates that adjustments may be required, {{org_field_name}} will consider reasonable adjustments before any decision is made that the person is not fit for the role. Decisions will be documented and will be based on the requirements of the role, the assessed risks, occupational health advice where appropriate, and the provider’s duty to deliver safe care and support.

4.2 Periodic Health Assessments for Employees

For roles with specific health risks (e.g., manual handling, exposure to infectious diseases), periodic health checks will be conducted, including:

• Vision and hearing tests (where relevant).
• Vaccination status checks (e.g., Hepatitis B for staff handling clinical waste).
• Musculoskeletal assessments for staff engaged in manual handling.
• Mental health and well-being assessments.

How we manage this efficiently:

• Health assessments and health surveillance will be carried out only where they are necessary, justified and proportionate, including where required by legislation, occupational health advice, risk assessment, the nature of the role, exposure to specific workplace hazards, or the need to assess fitness for work. Routine annual screening will not be applied automatically to all staff unless a documented risk assessment shows that it is required.
• A confidential employee health record system tracks periodic assessments.
• Staff are supported with adjustments if any concerns arise from medical reports.

Where health surveillance is required, the type and frequency of checks will be determined by the relevant risk assessment, occupational health advice, and applicable health and safety requirements. Staff will be informed of the purpose of the assessment, what information will be collected, who will receive the outcome, how the information will be used, and the possible consequences of the result.

Where staff undertake night work, extended shifts, significant travel, lone working or patterns of work that may create fatigue or health risks, {{org_field_name}} will consider whether a working time, fatigue or occupational health assessment is required. The assessment will consider whether the working pattern is safe for the member of staff and for individuals receiving care and support.

4.3 Referrals to Occupational Health

A referral to occupational health may be made where:

• a health condition, disability, injury or impairment may affect the member of staff’s ability to carry out the intrinsic duties of their role;
• a member of staff has had repeated, long-term or concerning sickness absence;
• there is a need to consider reasonable adjustments, modified duties, phased return, redeployment or other support;
• there has been a workplace accident, exposure incident or infection control concern;
• the member of staff requests support;
• there is concern about work-related stress, mental health, fatigue or wellbeing; or
• the Registered Manager, Responsible Individual or HR lead reasonably considers that occupational health advice is necessary to protect the member of staff, colleagues, individuals receiving care and support, or the safe operation of the service.

Before making a referral, {{org_field_name}} will explain to the member of staff why the referral is being made, what questions will be asked, what information may be shared with occupational health, what information may be returned to {{org_field_name}}, and how the information will be used.

Occupational health advice will normally be limited to fitness for work, likely work-related impact, adjustments, restrictions, rehabilitation, return-to-work planning and risk management. Managers should not normally receive detailed clinical information unless it is necessary, proportionate and lawful.

5. Managing Medical Reports and Confidentiality

5.1 Handling and Storing Medical Reports and Health Information

Health information, including occupational health reports, health questionnaires, vaccination records, sickness absence information, fitness to work assessments and medical correspondence, is special category personal data. It will be processed in accordance with UK GDPR, the Data Protection Act 2018, confidentiality requirements and this policy.

{{org_field_name}} will only collect health information where it is necessary, proportionate and justified for a clear employment, health and safety, regulatory, reasonable adjustment, infection prevention or safe care purpose.

Health information will be stored securely and separately from general personnel records where practicable. Access will be restricted to authorised persons who have a genuine need to know, such as the Registered Manager, HR lead, Responsible Individual or other authorised senior manager. Line managers will normally only receive information about fitness for work, work restrictions, adjustments, risk controls and return-to-work recommendations. Detailed clinical information will not normally be shared unless it is necessary, proportionate, lawful and the member of staff has been informed.

Records will be accurate, relevant, kept up to date and retained only for as long as necessary in accordance with {{org_field_name}}’s data retention schedule. Health information will not be used for a purpose that is incompatible with the reason it was collected.

Where an external occupational health provider is used, {{org_field_name}} will ensure that appropriate contractual, confidentiality and data sharing arrangements are in place. Staff will be told who controls their health information, who they may contact about their data protection rights, and how information will be shared between {{org_field_name}} and the occupational health provider.

5.2 Employee Rights Regarding Medical Reports

Where {{org_field_name}} requests a medical report from a GP, consultant or other medical practitioner who is, or has been, responsible for the employee’s clinical care, the Access to Medical Reports Act 1988 will apply. Before any such request is made, the employee will be informed of their rights and asked to provide written consent.

The employee has the right to:

• withhold consent to the report being requested;
• ask to see the report before it is supplied to {{org_field_name}};
• ask the medical practitioner to amend any part of the report that the employee considers inaccurate or misleading;
• attach a written statement of disagreement where the medical practitioner does not agree to amend the report; and
• withdraw consent for the report to be supplied, subject to the consequences this may have for {{org_field_name}}’s ability to make a decision based on available information.

Where the report is prepared by an occupational health provider who is not responsible for the employee’s clinical care, the Access to Medical Reports Act 1988 may not apply, but the employee will still be informed about how their health information will be used, who it may be shared with, and their data protection rights, including the right of access under data protection law.

If an employee disagrees with occupational health advice, {{org_field_name}} will consider any further evidence provided by the employee. A second opinion may be requested where it is reasonable and necessary, but this will not automatically delay management action where {{org_field_name}} must act to protect staff, individuals receiving care and support, or the safe operation of the service.

6. Reasonable Adjustments and Health Support

6.1 Workplace Adjustments for Health Conditions

Employees with long-term illnesses or disabilities will receive support, including:

• Flexible working hours or adjusted shift patterns.
• Ergonomic equipment (e.g., adjustable chairs, specialised keyboards).
• Modified duties if required.
• Access to mental health support services.

Reasonable adjustments will be considered on an individual basis and may include changes to duties, equipment, working patterns, travel arrangements, allocation of calls, supervision arrangements, communication methods, training, phased return, temporary restrictions, redeployment or other support. Adjustments will be discussed with the member of staff and, where appropriate, informed by occupational health advice, risk assessment and the needs of the service.

Any agreed adjustments will be recorded, implemented, reviewed and communicated only to those who need to know in order to support the member of staff and ensure safe care delivery. Where an adjustment cannot reasonably be made, the reasons will be documented.

6.2 Managing Long-Term Sickness Absence

• If an employee is absent due to health reasons, a return-to-work assessment will be conducted.
• A phased return to work may be arranged with reduced hours or modified duties.
• Regular well-being check-ins ensure employees feel supported.

How we manage this efficiently:

• An occupational health referral process is in place for long-term sickness cases.
• Return-to-work plans are developed in collaboration with the employee.

Where sickness absence may affect the continuity, safety or quality of care, {{org_field_name}} will ensure that staffing and rota arrangements are reviewed so that individuals continue to receive safe and reliable care and support. This reflects the provider’s duty to deploy sufficient suitably qualified, trained, skilled, competent and experienced staff at all times.

A return-to-work plan may include a phased return, temporary adjustments, amended duties, reduced hours, increased supervision, refresher training, manual handling reassessment, infection prevention precautions or review of travel and lone working arrangements. The plan will include review dates and will be updated if the employee’s health, role or service needs change.

7. Immunisation and Infection Control Screening

7.1 Vaccination Requirements for Care Staff

Staff working with individuals who may be vulnerable to infection will be encouraged and supported to follow current NHS Wales, Public Health Wales, local health board and occupational health advice on relevant immunisations. Vaccination requirements or recommendations will be based on role, exposure risk, individual risk assessment, public health guidance and the needs of individuals receiving care and support.

Vaccination and immunisation records are health information and will be processed as special category data. Records will be limited to what is necessary for infection prevention, occupational health, risk assessment, statutory or contractual requirements, and safe care delivery. Where a member of staff is not vaccinated, {{org_field_name}} will consider risk controls, adjustments or alternative measures where required and appropriate.

Annual flu vaccinations are recommended for frontline care workers.

Vaccination records must be maintained for compliance.

7.2 Infection Control Screening

• New staff may be required to undergo TB or Hepatitis B screening based on risk assessments.
• Staff must report any infectious illnesses that could pose a risk to service users.

Staff must not attend work where they have symptoms of an infectious illness that could place individuals receiving care and support, colleagues or others at risk, unless they have been advised it is safe to do so by an appropriate manager, occupational health, NHS 111 Wales, Public Health Wales, the local health board or another appropriate health professional.

Where there is a suspected or confirmed infectious disease exposure, outbreak or public health concern linked to the service, {{org_field_name}} will follow current public health advice, infection prevention procedures, reporting requirements and any relevant commissioner or local authority requirements. Occupational health advice will be sought where staff fitness, testing, exclusion from work or return to work requires clinical input.

How we manage this efficiently:

• A vaccination tracking system ensures compliance.
• Clear reporting procedures for infectious diseases protect service users and staff.

7.3 Exposure Incidents

Staff must immediately report any occupational exposure incident, including needlestick injury, contact with blood or bodily fluids, suspected exposure to infectious disease, sharps injury, bite injury, or any incident that may create a health risk to the staff member or others.

The Registered Manager or nominated senior person will ensure that immediate first aid, urgent medical advice and occupational health referral are arranged where required. The incident will be recorded, investigated and reviewed to identify any further action required, including infection prevention measures, risk assessment review, staff support, training, RIDDOR consideration where applicable, and notification to relevant external bodies where required.

8. Stress and Mental Health Support

8.1 Work-Related Stress and Mental Health

{{org_field_name}} recognises that work-related stress and mental health concerns can affect staff wellbeing, attendance, performance and the safe delivery of care. Managers will take reasonable steps to identify, prevent and manage work-related stress, including through supervision, return-to-work discussions, staff feedback, incident review, workload review, lone working review, rota review and risk assessment.

Staff are encouraged to raise concerns about stress, mental health, fatigue, bullying, harassment, workload, travel pressures, traumatic incidents or any other matter affecting their wellbeing or fitness to work. Concerns will be treated sensitively and confidentially, subject to safeguarding, health and safety or legal obligations.

8.2 Support and Adjustments

Support may include supervision, wellbeing check-ins, signposting to counselling or an Employee Assistance Programme where available, occupational health referral, temporary or permanent reasonable adjustments, amended duties, phased return, rota changes, additional training, mentoring or referral to external support services.

Where a mental health concern may affect safe working, {{org_field_name}} will carry out an individual risk assessment and seek occupational health advice where appropriate. Any action taken will balance the employee’s rights and wellbeing with the provider’s duty to protect individuals receiving care and support and maintain safe service delivery.

9. Fitness to Work and Capability Procedures

9.1 Determining Fitness to Work

Fitness to work will be determined by considering whether the member of staff is able, by reason of their health and after any reasonable adjustments have been considered and made where required, to properly perform the tasks intrinsic to their role. This assessment will take account of the job description, the person’s duties, the needs of individuals receiving care and support, lone working, manual handling, medication-related duties, infection prevention requirements, travel requirements, communication needs, working hours and any other relevant risks.

A fitness to work assessment may be required where:

• there is a health condition, injury, disability or impairment that may affect safe working;
• the member of staff is returning from long-term or repeated sickness absence;
• there are concerns about fatigue, stress, mental health, mobility, manual handling, infection risk or cognitive functioning;
• the member of staff has been involved in a serious accident, exposure incident or safeguarding-related matter where health is relevant; or
• the role changes or new duties introduce additional health risks.

The assessment may include a discussion with the member of staff, review of the role and duties, risk assessment, occupational health referral, consideration of medical evidence supplied by the employee, and consideration of reasonable adjustments.

A member of staff will not be judged unfit for work solely because they have a health condition or disability. Decisions will be based on evidence, the requirements of the role, reasonable adjustments, risk controls, occupational health advice where appropriate, and the need to provide safe care and support.

9.2 Managing Capability Due to Health Concerns

Where health affects attendance, performance or the ability to work safely, {{org_field_name}} will manage the matter fairly, sensitively and in accordance with employment law, equality law, this policy and the relevant sickness absence or capability procedure.

Before any formal decision is made, {{org_field_name}} will normally:

• meet with the employee to discuss the concern and obtain their views;
• consider medical or occupational health advice where appropriate;
• consider whether the employee may have a disability under the Equality Act 2010;
• identify and consider reasonable adjustments;
• consider temporary restrictions, amended duties, phased return or redeployment where appropriate;
• assess any risk to individuals receiving care and support, colleagues and the employee; and
• document the decision-making process.

Where there is an immediate risk to safety, {{org_field_name}} may temporarily restrict duties, remove the employee from specific tasks, adjust the rota, place the employee on alternative duties or take other proportionate action while advice is obtained. Any such action will be kept under review.

Dismissal on health capability grounds will only be considered where the employee remains unable to fulfil the role safely and effectively after reasonable adjustments, alternative options and relevant medical or occupational health evidence have been considered. Any dismissal decision will be taken under the appropriate formal procedure and will include the right of appeal where applicable.

9.3 Staff Who No Longer Meet Fitness Requirements

Where {{org_field_name}} becomes aware that a person working at the service may no longer meet the required fitness criteria, including health-related fitness, the Registered Manager will take necessary and proportionate action to ensure individuals receiving care and support are not placed at risk.

Action may include risk assessment, supervision, temporary restriction of duties, occupational health referral, training, reasonable adjustments, redeployment, use of sickness absence or capability procedures, disciplinary action where appropriate, or referral to a professional body, Social Care Wales, the Disclosure and Barring Service, CIW, the local authority safeguarding team or other relevant body where the concern requires it.

Any action will be recorded and monitored by the Registered Manager, with oversight by the Responsible Individual where appropriate.

10. Staff Training and Awareness

10.1 Mandatory Training for Staff

All staff will receive information, induction and training appropriate to their role on occupational health, fitness to work, sickness reporting, infection prevention, exposure incidents, manual handling, lone working, work-related stress, reasonable adjustments, confidentiality and the reporting of health concerns that may affect safe care delivery.

Managers will receive training or guidance on recognising when occupational health advice may be required, making lawful and proportionate referrals, handling health information confidentially, considering reasonable adjustments, supporting return to work, managing health-related capability concerns, and maintaining safe staffing arrangements.

10.2 Compliance Audits and Reviews

The Registered Manager will ensure that occupational health and fitness-to-work arrangements are audited at least annually and more frequently where risks, incidents, inspection findings, safeguarding concerns, sickness trends or service changes require it.

Audits may include review of:

• pre-employment health clearance processes;
• evidence that staff are fit for their role under Regulation 35;
• occupational health referrals and outcomes;
• reasonable adjustments and return-to-work plans;
• health surveillance records where applicable;
• vaccination and infection prevention risk controls;
• sickness absence trends;
• stress and wellbeing concerns;
• manual handling or exposure incidents;
• confidentiality and data protection compliance; and
• actions taken where staff may no longer meet fitness requirements.

Findings will be reported through the service’s governance arrangements and used to improve staff support, risk management, safe staffing and service quality. The Responsible Individual will maintain oversight of significant themes and ensure that required improvements are implemented and reviewed.

10.3 Records to Evidence Compliance

{{org_field_name}} will maintain records sufficient to evidence that staff are fit, supported and safely deployed. Records may include health declarations, occupational health advice, risk assessments, reasonable adjustment plans, return-to-work forms, health surveillance records where applicable, training records, supervision records, sickness absence records, exposure incident records and management decisions.

Records will be kept securely and made available for inspection by CIW where lawfully required, while maintaining confidentiality and data protection requirements. Where information is provided to CIW, commissioners, safeguarding bodies or other external bodies, only information that is necessary and lawful will be shared.

11. Related Policies

This policy aligns with:

• Health and Safety at Work Policy (DCW18)​.
• Supporting Employees with Disabilities Policy (DCW40)​.
• Mental Health and Well-being Policy (DCW33)​.
• Infection Control and Vaccination Policy (DCW22)​.
• Recruitment and Selection Policy.
• Safe Recruitment and DBS Policy.
• Staff Supervision and Appraisal Policy.
• Sickness Absence Management Policy.
• Capability Policy.
• Disciplinary Policy.
• Data Protection and Confidentiality Policy.
• Records Management and Retention Policy.
• Lone Working Policy.
• Manual Handling Policy.
• Risk Assessment Policy.
• Accident and Incident Reporting Policy.
• Whistleblowing Policy.
• Safeguarding Adults and Children Policy.
• Duty of Candour Policy.
• Equality, Diversity and Human Rights Policy.
• Business Continuity and Safe Staffing Policy.

12. Policy Review

This policy will be reviewed at least annually, or sooner where there are changes to legislation, Welsh Government statutory guidance, CIW requirements, Social Care Wales requirements, public health guidance, employment law, data protection law, service risks, inspection findings, safeguarding findings, occupational health trends or business needs.

The Registered Manager is responsible for day-to-day implementation of this policy. The Responsible Individual is responsible for maintaining oversight and ensuring that the service has effective governance arrangements to monitor occupational health, staff fitness, safe staffing and compliance with regulatory requirements.

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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}}
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