{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}


End of Life and Palliative Care Policy

1. Purpose

The purpose of this policy is to establish clear, legally compliant and agency-specific guidance for all temporary workers supplied by {{org_field_name}} who may be placed in settings where people are receiving palliative or end-of-life care. {{org_field_name}} is an employment business/temporary staffing agency and does not itself provide, manage, direct or control regulated care. Responsibility for care planning, clinical governance, regulated activity, treatment decisions and the management of service users remains with the client provider, placement setting and relevant healthcare professionals.

Temporary workers supplied by {{org_field_name}}, including registered nurses, healthcare assistants and other care staff, may encounter people approaching the end of life or receiving palliative care. They must act compassionately, protect dignity, follow the client’s policies and care plans, work within their role and competence, and escalate concerns promptly to the client’s senior staff or relevant clinician.

This policy supports compliance with applicable legislation and guidance, including the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Agency Workers Regulations 2010, the Employment Rights Act 1996, the Employment Rights Act 2025 where in force, the Working Time Regulations 1998, the National Minimum Wage Act 1998, the Equality Act 2010, the Human Rights Act 1998, the Mental Capacity Act 2005, the Safeguarding Vulnerable Groups Act 2006, the Police Act 1997, the Rehabilitation of Offenders Act 1974 and Exceptions Order, UK GDPR and the Data Protection Act 2018, the Immigration, Asylum and Nationality Act 2006, the Health and Safety at Work etc. Act 1974, and relevant NICE guidance on end-of-life care.

The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and CQC guidance apply to the client provider where the client is carrying on regulated activities. {{org_field_name}} will support clients by supplying suitable workers but will not hold itself out as the regulated care provider unless its business model changes and CQC registration is obtained where required.

2. Scope

This policy applies to:

This policy does not make {{org_field_name}} the provider of regulated care, the controller of clinical treatment, or the organisation responsible for making end-of-life, DNACPR, mental capacity, best-interests, medication or treatment decisions. Those responsibilities remain with the client provider, relevant clinician, registered professional, attorney, deputy or other legally authorised decision-maker, as applicable.

3. Related Policies

4. Definition of Palliative and End of Life Care

Palliative care is holistic care and support for people with life-limiting or serious illness. It focuses on quality of life, comfort, symptom relief and emotional, psychological, social, cultural and spiritual support. Palliative care may be provided alongside active treatment and is not limited to the final days of life.

End-of-life care refers to care and support for people who are likely to be approaching the end of life, including those who may be in the last months, weeks, days or hours of life. Care in the last days of life must focus on dignity, comfort, sensitive communication, involvement of the person and those important to them, and appropriate recognition and management of symptoms.

5. Principles of End of Life and Palliative Care

All staff representing {{org_field_name}} must ensure that care is:

6. Responsibilities

Directors

As {{org_field_name}} does not have a registered manager, the directors will assume full accountability for:

Temporary and Agency Staff

All registered nurses, healthcare assistants, and temporary workers must:

6.1 Agency Status, Client Responsibility and CQC Boundary

{{org_field_name}} operates as a temporary staffing agency/employment business. It supplies workers to client providers but does not itself provide, manage, direct or control regulated care. The client provider remains responsible for assessing service users, developing and reviewing care plans, making treatment decisions, ensuring appropriate clinical governance, supervising the placement environment, and complying with CQC registration and regulated activity requirements.

Agency workers must follow the client’s policies, care plans and lawful instructions while working within their competence and professional responsibilities. If an agency worker believes that a client instruction is unsafe, unlawful, discriminatory, outside their competence, inconsistent with a care plan, or not in the person’s best interests, they must escalate this immediately to the client’s senior staff and notify {{org_field_name}} as soon as practicable.

{{org_field_name}} will review its CQC registration position if its business model changes, including if it begins to arrange, manage, direct, supervise or provide personal care, nursing care or another regulated activity in its own right.

7. Advance Care Planning

Staff must respect the right of individuals to be involved in decisions about their care, treatment, and preferences, particularly as they approach the end of life. Where appropriate, agency staff should:

7.1 Mental Capacity, Consent, Best Interests and Deprivation of Liberty

Agency workers must presume that a person has capacity to make a specific decision unless it is established otherwise in accordance with the Mental Capacity Act 2005. Workers must support people to make their own decisions wherever practicable and must not treat a person as unable to make a decision merely because the person makes a decision others consider unwise.

Where a person lacks capacity for a relevant decision, any act done or decision made on their behalf must be in their best interests, be the least restrictive option available, and be consistent with the client’s care plan, legal authority and local procedures. Agency workers must not make independent best-interests decisions about serious medical treatment, end-of-life treatment, DNACPR, deprivation of liberty or significant restrictions unless this is within their professional role and expressly authorised by the client’s procedures.

If a worker is concerned that a person is being restricted, restrained, prevented from leaving, deprived of liberty, or cared for in a way that may be unlawful or not properly authorised, they must report this immediately to the client’s senior staff and to {{org_field_name}}. In England, Deprivation of Liberty Safeguards remain relevant for hospitals and care homes unless and until replaced by a new statutory framework.

7.2 Assisted Dying, Requests to Die and Unlawful Assistance

Assisted dying, assisted suicide and euthanasia are not lawful care interventions for agency workers in England. Workers must not assist, encourage, advise on, arrange or participate in any act intended to end a person’s life.

If a person expresses a wish to die, requests help to die, talks about suicide, or appears to be at risk of self-harm, the worker must respond with compassion, remain with the person where safe to do so, and immediately report the concern to the client’s nurse in charge, manager or responsible clinician. The worker must also follow safeguarding, mental capacity, mental health, incident reporting and emergency procedures as appropriate.

Workers must distinguish between unlawful assistance to die and lawful, compassionate end-of-life care, including symptom relief, comfort care, clinically appropriate medication, refusal of treatment, valid Advance Decisions to Refuse Treatment, best-interests decisions and DNACPR decisions.

8. Communication

Effective communication is vital when delivering palliative and end-of-life care. Staff must:

9. Symptom Management and Comfort

Agency workers must work collaboratively with client staff and healthcare professionals to support comfort and symptom management within their role and competence. This includes:

10. Dignity and Respect

All staff must preserve the dignity and rights of individuals receiving end-of-life care by:

11. Supporting Families and Significant Others

Agency staff have a role in supporting family members and significant others by:

12. After Death Care

Staff must follow the client’s procedures, local policy and their own professional responsibilities when a death occurs. This includes:

13. Safeguarding and End of Life Care

Staff must remain vigilant to safeguarding concerns even when a person is receiving palliative or end-of-life care. Abuse, neglect, organisational abuse, discriminatory abuse, financial abuse, psychological abuse, domestic abuse, self-neglect, medication misuse, rough handling, inappropriate restraint, coercion, pressure around decisions, or failure to provide appropriate care must never be ignored.

Any safeguarding concern must be reported immediately in accordance with the client’s safeguarding procedure and {{org_field_name}}’s Safeguarding Adults Policy. Where there is immediate risk of harm, staff must seek urgent assistance from the client’s senior staff, emergency services or other appropriate authority. {{org_field_name}} will cooperate with safeguarding enquiries, local authority safeguarding processes, police investigations, professional regulator referrals and DBS referrals where legally required.

Workers must not investigate safeguarding concerns themselves unless specifically authorised. Their role is to recognise, preserve evidence where relevant, record objectively, report promptly and cooperate with the appropriate process.

13.1 Recruitment, Suitability and Placement Checks

Before supplying a worker to a placement involving health or social care, {{org_field_name}} will take reasonable steps to ensure that the worker is suitable for the role and that the client has been given relevant information needed to assess suitability for the assignment. Checks may include, as applicable:

{{org_field_name}} will not knowingly supply a worker to a role where the worker lacks the required right to work, registration, DBS/barred-list clearance, competence, training or suitability required for that assignment.

13.2 Agency Worker Rights, Pay and Working Time

{{org_field_name}} will comply with applicable employment and agency-worker legislation, including the Agency Workers Regulations 2010, Employment Rights Act 1996, Employment Rights Act 2025 where in force, Working Time Regulations 1998, National Minimum Wage Act 1998 and National Minimum Wage Regulations 2015.

Agency workers will receive relevant written information about their assignment, pay, holiday entitlement, expected hours, contract type, deductions and any intermediary or umbrella arrangements where applicable. {{org_field_name}} will take reasonable steps to ensure that workers receive at least the National Minimum Wage or National Living Wage applicable to them and that working time, rest breaks and annual leave are managed lawfully.

{{org_field_name}} will monitor agency workers’ rights under the Agency Workers Regulations 2010, including day-one rights to relevant collective facilities and information about client vacancies, and equal treatment in relevant basic working and employment conditions after the qualifying period. The agency will also monitor phased changes introduced by the Employment Rights Act 2025, including provisions relating to agency workers, shift notice, cancellation or curtailment of shifts, guaranteed-hours rights where applicable, umbrella company regulation and labour-market enforcement.

13.3 Right to Work and Immigration Compliance

{{org_field_name}} will complete right-to-work checks before a worker starts work and will conduct follow-up checks where required. Checks will be carried out using the method required or permitted by current Home Office guidance, which may include manual document checks, online right-to-work checks or checks using an Identity Service Provider where applicable.

Workers must not be supplied to clients unless {{org_field_name}} is satisfied that they have the right to work in the UK for the work in question. Where a worker has time-limited permission to work, {{org_field_name}} will monitor expiry dates and complete repeat checks in accordance with Home Office requirements. Records of right-to-work checks will be retained securely for the required period.

13.4 Data Protection, Confidentiality and Information Sharing

{{org_field_name}} will process candidate, worker, client and placement information in accordance with UK GDPR, the Data Protection Act 2018 and its Confidentiality and Data Protection Policy. Information relating to health, safeguarding, DBS checks, criminal records, professional registration, complaints or incidents will be handled securely and shared only where there is a lawful basis and legitimate need.

Workers must maintain confidentiality at all times and must not disclose service-user, family, client or colleague information except where required for care, safeguarding, legal, regulatory, professional or placement-management purposes. Workers must use the client’s records and systems as instructed and must not remove, photograph, copy or share records unless authorised.

Any actual or suspected data breach, confidentiality breach or inappropriate disclosure must be reported immediately to the client where relevant and to {{org_field_name}}.

14. Emotional Wellbeing of Staff

Providing end-of-life care can be emotionally challenging. {{org_field_name}} is committed to supporting staff by:

Where a worker experiences distress, moral injury, trauma, bereavement, conflict with family members, involvement in a safeguarding concern, or distress following a death or serious incident, {{org_field_name}} will offer appropriate support, debriefing and signposting. Workers are encouraged to report concerns early and will not be penalised for seeking support or stating that an assignment is outside their competence or causing significant distress.

15. Equality, Diversity, and Non-Discrimination

{{org_field_name}} will ensure that palliative and end-of-life care is delivered in line with the Equality Act 2010 by:

16. Training

All agency staff will receive appropriate training in:

Mandatory and refresher training will be provided or verified as required by the role, client requirements, legal obligations, professional standards and identified risks. {{org_field_name}} will keep training records and will not knowingly supply workers to assignments where required training or competence is absent or out of date.

17. Monitoring and Compliance

The directors of {{org_field_name}} are responsible for:

18. Policy Review

This policy will be reviewed at least annually or sooner if:

The directors of {{org_field_name}} will be responsible for the review, implementation, and communication of this policy.


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.

Leave a Reply

Your email address will not be published. Required fields are marked *