COVID-19: ASO Practice Toolkit

The ASO has prepared these resources with advice from the Practice Managers Advisory Group which may be of assistance to members during the COVID-19 Pandemic. Updates are made regularly.

Please Contact ASO with suggestions or questions.

MDA National

Deb Jackson, Medico Legal Advisory Counsel.

The Medical Board of Australia have released a position statement for health practitioners facilitating access to care to patients in the current COVID-19 environment. Read about it here

Can I decline to see unvaccinated patients? 

In respect of whether a doctor/practice can refuse to see unvaccinated patients, the answer is quite complex.

In general, doctors are not required to treat any patient unless it is an emergency. Good medical practice: a code of conduct for doctors in Australia states that good practice involves keeping health practitioners and their staff safe when caring for patients - but it is expected that health practitioners will facilitate access to care in the current COVID-19 environment.

Ahpra has recently released guidelines, Board Guidelines on treating unvaccinated patients, and there is some useful information here, regarding minimising the risk in a Primary Health Care setting, and the Australian Commission on Safety and Quality in Health Care has useful information COVID-19 infection prevention and control risk management

Practices have an obligation to provide a safe workplace and a risk based approach is required, taking into account risks at a practice level and the risks for an individual staff member.

Vaccinated people can also be infected with and transmit COVID-19.

A blanket ban on the unvaccinated could lead to a complaint to the Medical Board or be considered discriminatory.

  • Practice specific risks include patient cohort e.g., ophthalmology, oncology practice, and respiratory practice-   likely to be able to have more risk adverse policies; specialities requiring close contact with patients e.g. ophthalmology.
  • Staff risks – are all staff vaccinated against COVID-19? (some jurisdictions have public health orders requiring this) Some staff members have particular health issues placing them at increased risk.
  • Operational risks if there is a positive case and the practice has to close or operate with reduced staff levels.

Practices can consider:

  • Pre-consultation COVID-19 testing (if available)
  • Provide a dedicated examination room for unvaccinated patients who require a face-to-face consultation
  • Arrange a separate, dedicated time for appointments with unvaccinated patients
  • Provide referral to another medical practitioner who can offer face-to-face consultations, either at the same practice or elsewhere.
  • Consulting with the patients with full PPE, N95 or P2 masks- this is being adopted by high risk specialties- oncology, ophthalmology and respiratory.
  • Telehealth – triage

Can I restrict access to patients on the basis of a patient attribute?

Yes, in limited circumstances.

While in private practice there is generally no obligation to see / continue to see any individual patient (presuming the matter is not an emergency and care can be deferred), the reason must not be discriminatory.

Care needs to be taken in initiating policies for restricting care access to groups of patients where the reason is linked to one or more health attributes. We do see complaints to Ahpra (or equivalent) and anti-discrimination bodies over this issue.

A practice also has occupational health and safety obligations to its staff, and those attending a practice (patients, patient supports, 3rd parties such as trades-people). This does provide a basis for a practice to introduce policies to reduce transmission of infectious illnesses. Where a patient health attribute genuinely posed a OHS risk, steps can be taken to mitigate that risk.

Is excluding patients on the basis of Covid-19 vaccination status a good idea ?

No.

In NSW, the pattern of Covid-19 (Omicron) transmission has demonstrated that approximately 80% of those infected were fully vaccinated (see NSW data for week up to 25 Dec 2021).  While transmission into the partially and unvaccinated group (15%) was somewhat over-represented compared to the percentage of not fully vaccinated persons (6%), it is clear from this that vaccination status would be a very unreliable way of determining whether an individual patient posed a Covid-19 transmission risk to the practice. This conclusion is also reflected in the ATAGI advice on Omicron – “The rapid growth in case numbers relative to the Delta variant, as well as studies of contacts of cases demonstrating its higher secondary attack rate provide evidence that Omicron can spread rapidly even in populations where there has been widespread infection and/or COVID-19 vaccination.”

What risks are there for the practice if we do adopt such a policy?

You may get an Ahpra (or similar) complaint. The Medical Board position on refusing care to patients who are not vaccinated was released on 23 December “National Boards expect all health practitioners to facilitate access to care regardless of someone’s vaccination status. People cannot be denied care if steps can be taken to keep the person, health practitioners and their staff safe”.

You may get an anti-discrimination complaint.

There are medicolegal risks involved in introducing policies which limit care based on vaccination status, because of the above concerns, and because it is a poor predictor of risk to the practice. There may be specific individual exceptions to this general position.

Can we still enquire about a patient’s vaccination status?

Yes, presuming that this is clinically relevant information for this patient. It might be better collected at a consultation level, rather than a practice level.

Consider whether vaccination status information is reasonably necessary for your functions or activities. For some types of practice (e.g. ophthalmology, GP or oncology practice) the fact that a patient without Covid-19 immunity (unvaccinated, and previously uninfected with Covid-19) may be at greater risk of acquiring Covid-19 infection (including at the practice); and also at greater risk of complications from that infection, means that this information may be clinically relevant (even here, the focus on those who are not immune, not those who are not vaccinated). There may be other types of practice where discussion of Covid-19 risk for that patient was not something that the practice staff typically engaged in.

Privacy guidance suggests “you must have clear and justifiable reasons for collecting this information and be able to show that there are no reasonable alternatives to achieving your objectives without collecting this information. If you have no immediate and specific use for the information, or you are recording it on a ‘just in case’ basis, the collection would not be considered reasonably necessary”. Patients would not typically be required to divulge this information to a health practitioner.

So how can we manage Covid-19 transmission risk?

The practice policy needs to take into account risks to the staff / attendees to the practice. This will involve considering the type of practice (e.g. a practice requiring close and prolonged face to face consultations such as ophthalmology will have different needs to a psychiatry practice operating by telehealth); the type of patients (e.g. immunocompromised or elderly); the current state of Covid transmission and outcome risk; the availability of consultation alternatives; other monitoring tools (rapid antigen tests; PCR availability); transmission reduction equipment (filters; PPE; ability to conduct consultations away from the practice – telehealth; outdoor consultation in cars or outdoor rooms) and so on. You can then determine what options you will provide to your patients, depending on the risk the individual patient poses.

Practice policy: 

Example of a policy (which may need to be fine-tuned to your practice circumstances)

How we minimise the risk of Covid-19 transmission at this practice

There is an inherent risk in attending a health facility that provides in-person services in a shared office environment. It is not possible for us to eliminate a risk for potential exposure to infective illnesses, including Covid-19.

We are all responsible for taking relevant precautions to minimise exposure to Covid-19, and keep everyone safe. This includes staff, patients, carers and others attending the practice.

Covid-19 can infect vaccinated and unvaccinated persons, and may be asymptomatic. This means that transmission of Covid-19 can occur from and between staff, patients, patient carers and others vising the practice. Our staff are all vaccinated against Covid-19.

Our practice has legal occupational health and safety obligations to minimise the risk of transmission of Covid-19, so we may have to adopt certain ways of providing care to address this risk.

If our staff become unwell from catching an infectious illness (including Covid-19), this may result in them being unable to work at the practice while they are tested / recover. It may also result in the practice having to close temporarily if key staff are unable to work. It is important to us to minimise this operational risk to our practice, in addition to any other obligations we may have.

The way we manage the risk of Covid-19 transmission at this practice includes:

  • we will follow relevant government public health guidelines and requirements. This may include an obligation to notify government bodies / public health authorities regarding persons who have Covid-19 infections. If this is the case, we will only provide the minimum necessary information (e.g. QR code check in data) to the relevant authorities.
  • our administration staff may initially talk to you be phone to determine if there are any risks we need to address, before you are able to attend the practice in person. This discussion could include screening questions for patients at high risk of Covid transmission.
  • we may ask you to wait outside the practice until we are ready to see you, in which case we will call you in.
  • we will need to know, prior to appointments or at the time of your appointment being confirmed via SMS or telephone (usually a week prior), of any possible upper respiratory symptoms you have experienced; whether you are unwell; whether you are a close contact of someone with Covid-19; whether you have Covid-19; or whether you should be in isolation.
  • when the risk of Covid-19 transmission is very high, we may need to delay care; arrange care elsewhere (e.g. hospital; respiratory clinics) or ensure certain steps occur beforehand (e.g. Covid-19 testing such as PCR tests and rapid antigen tests).
  • we may need to enquire about your immunity to Covid-19 (vaccination status / past infection) to gauge the risk Covid-19 transmission poses to you. While you don’t have to disclose this information, this might interfere with our ability to minimise risk to you, to provide best care, or give you the best advice. In limited situations, it may even mean that we are not able to provide you with care in the manner you are seeking.
  • it may be necessary or appropriate for us to conduct a consultation by telehealth (phone or video). Not all telehealth consultations are able to be billed to Medicare, but we will clarify this with you beforehand (and let you know an estimate of any out of pocket costs). Not all consultations can be held by telehealth (e.g. if you need to be examined), and we may need to make other arrangements for your care in such situations.
  • all patients must sign into our practice using the relevant, CovidSafe app and QR code or manually sign in with the required details, when this is required by the authorities.
  • patients may be required to wear a mask (even if this is not the current public health mandate).
  • those at the practice should physically distance wherever possible.
  • we ask that patients attend their appointment alone if possible (or with only one other person if necessary).
  • consultations may be safer to hold outside in some circumstances (e.g. in your car; in a room outside).
  • we may arrange consultations at specific times (e.g. first of the day / last of the day) to reduce the risk to others who might be at the practice.
  • some consultations may require staff to be in full personal protective equipment.
  • as some of these steps may require additional time and resources on behalf of our staff, we reserve the right to not bulk bill these consultations if the cost burden to us is significant. We will inform you of any out of pocket cost that will be incurred, which we will obtain prior to the consultation being held.

Our approach to minimise the transmission of Covid-19 at the practice applies to all patients, and aligns with the Australian Commission on Safety and Quality in Health Care’s COVID-19 infection prevention and control risk management, and the Medical Board Code of Conduct.

If this arrangement is not acceptable to you, you will need to find a practice which is able to accommodate your needs.

If you have any queries about how we manage these risks, please do not hesitate to discuss these efforts with your doctor, or the practice staff.

We thank you for your cooperation.

Useful links for conducting a practice risk assessment:

Safe Work Australia - Key considerations for undertaking a risk assessment - COVID-19

ACSQHC - COVID-19: Infection prevention and control risk management

 

MDA National

Deb Jackson, Medico Legal Advisory Counsel.

Most states have already enacted legislation which compels health care workers and health support worker to undergo mandatory COVID-19 vaccination.

Residential aged care workers requirement for mandatory vaccination was covered under Commonwealth legislation in August 2021.

Below are links to the relevant legislation (any any explanatory notes) for each State and Territory:

Australian Capital Territory

  • A worker for a health care facility must not work at the premises of a health care facility after 29 October without receiving one dose, or after the 1 December 2021, worker receiving 2 doses.
  • The latest public health directions can be found here. Public Health (Health Care and Support Workers COVID-19 Vaccination) Emergency Direction 2021 found here. A worker for a health care facility must not work at the premises of a health care facility after 29 October without receiving one dose, or after the 1 December 2021, worker receiving 2 doses.

New South Wales

  • Public Health (COVID-19 Vaccination of Health Care Workers) Order (No 2) 2021 found here. Information that the vaccination order will be extended to primary care and private sector health service providers is here. Click here for further information about the Order. Click here for a copy of the medical contraindication form.
  • Changes to the latest NSW Public Health Orders can be found here

Northern Territory

  • Chief Health Officer directions can be found here. Consolidated version of COVID-19 Directions released on 10 November 2021 (No.55 2021: Directions for mandatory vaccination of workers found here.
  • Original directions for mandatory vaccination of workers to attend workplace released on 13 October 2021 found here.
  • Amendments can be found here.
  • First dose must be received by 13 November 2021 and second does by 25 December 2021. Directions apply to workers who face patients in healthcare and ancillary health services and health care workers in hospitals and emergency departments.

Queensland

  • A mandate is now in place via a Health Employment Directive. See FAQs “Is the vaccine mandatory if I want to keep my job” for further information and the latest Chief Health Office Pubic Health Directions can be found here.

South Australia

Tasmania

  • Mandatory vaccination for all health care workers via a Public Health Order. Click here for a copy of the medical contraindication form.

Victoria

  • Mandatory vaccination for all health care workers, allied health, administrative and ancillary workers via Directions from the Acting Chief Health Officer. Directions found here.

Western Australia

For further information on Coronavirus and Australian Workplaces Fair Work Ombudsman found here

The number of positive cases of Covid-19 are rising daily and the new variant of the virus, Omicron is now rapidly spreading across the country. Most State Governments have taken the step to implement restrictions and included a blanket ban on elective surgery.

 

The Australian Society of Ophthalmologists (ASO) can advise there will be a build-up in cases, making the public hospital waiting lists even longer. The blanket ban will generate a future back-log of wait times exceeding an 18-month period for public patients to receive elective surgery.

 

The following are the guidelines for each state.

 

NSW

 

From 10 January 2022, all non-urgent elective surgery will cease.

  • This does not prevent surgery proceeding for a patient identified as a Category 2, who require surgery within 90 days; if a patient’s clinical condition indicates that an emergency admission may eventuate if the condition is not treated in 30 days.
  • Does not apply in relation to patients who are admitted and discharged on the same day.

 

QLD

  • Queensland’s public hospitals are postponing all non-urgent elective surgeries until March 1.

 

SA

 

VIC

  • Elective surgery is restricted to Category 1 urgent surgery from January 6.

 

ACT

  • Category 2 and 3 elective surgeries at Calvary Public Hospital will cease for the next six to eight weeks from January 7.

 

WA

  • There is no new information at this time from State Government, however, ANF State Secretary Mark Olson has advised if a serious outbreak of the Omicron virus is to occur elective surgery in WA should be cancelled within 6 weeks.

 

NT

  • There is no new information currently.

 

TAS

  • There is no new information currently.

NSW resident, Associate Professor and ASO President, Ashish Agar says;

 

"This entirely predictable and avoidable resurgence in Covid cases is having a severe impact on people's vision and therefore their lives. Elective surgery is necessarily having to be restricted as our health system and workforce is decimated by the virus, especially in the public system but now increasingly in the private sector. This restriction will again delay sight-saving surgery and add further to the stress our patients are feeling. They relied on the government to look after the community and did all that was asked of them, but now feel understandably let down, confused and anxious. Health must once again be the priority in our response to the pandemic, for it is unacceptable that our most vulnerable are paying the price for this failure.

 

Victorian Ophthalmologist and ASO Board Member, Laurence Sullivan, says “Governments are unable to use nuanced measures to help maintain ICU and hospital capacity. The blanket ban on elective surgery certainly will endanger non-COVID-19 patients. These are the people who will not show up on the daily case reporting. 

 

The government should simply require each hospital or day surgery to constrain throughout to maintain optimum ICU and Ward staffing. Hospital administrators know how to allocate resources appropriately.

 

Otherwise, they may as well invoke another lockdown.

 

AMA (NSW) President Dr Danielle McMullen has said “health care workers have been insulted by assurances that the health system is strong and coping. Repeatedly saying that elective surgery is not an ‘unnecessary surgery’, it is serious medical care and delaying that care impacts on the quality of life of many Australians”.

ASO has also teamed with our alliance partners MDA National and Cutcher & Neale to deliver live webinars to our members:

Upcoming Webinars

TBA 

Past Webinar Recordings

MDA National 

  • 8 April, Pandemic practicalities. Medico-legal advice live online- Listen to the recording here.

Cutcher & Neale 

  • 22 October, Rethinking ophthalmology and your finances in the face of COVID-19Listen to the recording here.
  • 27th May, Stimulus Packages and Tax Planning Listen to the recording here
  • 23 April, An overview of the economic effects of coronavirus and the government’s stimulus packages - Listen to the recording here
  • 15 April, Finding value in turbulent times: A Cutcher & Neale Investment Services perspective - Listen to the recording here
  • 9 April, Coronavirus and workplace laws for medical practices - Listen to the recording here.

The Prime Minister has announced that eye surgery will recommence from Monday 27 April.

The AHPPC has prepared a statement on restoration of elective surgery including:

  • Principles around reintroduction of hospital activity
  • Patient Selection Principles for first tranche of elective surgery re-commencement.
  • Suggested approach for elective surgery. Read the full statement here.

RANZCO have provided guidance on return to elective surgery in Australia. Click here.

The Australian Commission for Quality and Safety in Healthcare has prepared the following resource: COVID-19 Elective surgery and Infection Prevention and Control Precautions. Click here to download

The Royal College of Ophthalmologists has prepared this interim guide on Reopening and redeveloping ophthalmology services during Covid recovery - Download here

Listen to an interview with ASO President Dr Peter Sumich supporting a return to elective surgery on Fran Kelly's RN Breakfast here -Monday 20 April.

  • Visual Field Analyser Cleaning*:
    • Zeiss Cleaning Guidelines for HFA -Click here
    • Zeiss Cleaning Quick Guide (how to clean VFA bowl)- Click here

*Because there could be aerosolization during disinfection, we recommend that staff wear a surgical mask and eye protection while cleaning visual field analyzers.

 

*ASO members save 12.5% on MDA National Professional Indemnity Insurance Premium and Membership
Subscription - find out more click here

  • The Australian Government has prepared this advice and FAQs about epidemiology for Clinicians during COVID-19 - click here

New MBS items

  • From Monday 30 March temporary MBS Telehealth items will be available for all Australians.
  • Specialists attendance items 104 (New Telehealth item equiv. 91822) and 105 (New Telehealth item equiv. 91823) can be used. 
  • Phone items are also available where a patient cannot access video means- 104 (91832) and 105 (91833).·
  • From 20 April Health providers may apply their usual billing practices to the telehealth items.
  • Providers are expected to obtain informed financial consent from patients prior to providing the service; providing details regarding their fees, including any out-of-pocket costs.
  • The following MBS factsheets will assist members in claiming and understanding these Telehealth items.

E-prescribing

Interim arrangements for prescriptions for supply of medicines: Supporting telehealth patients and healthcare professionals-click here.

  • MDA National* has useful FAQs about Telehealth on their COVID -19 Resource Hub - click here

*ASO members save 12.5% on MDA National Professional Indemnity Insurance Premium and Membership
Subscription - find out more click here

Recent topics of importance:

Job keeper package 

Home Office tax deductions

SMSFs and rental arrangements

*ASO members are entitled to a complimentary first consultation with Cutcher & Neale contact them here medical@cutcher.com.au or phone 1800 988 522

NSW.  QLD.   VIC.   SA

Recent topics:

When can employees be stood down without pay?

*ASO members are entitled to a complimentary first consultation with Cutcher & Neale contact them here medical@cutcher.com.au or phone 1800 988 522

*ASO members save 12.5% on MDA National Professional Indemnity Insurance Premium and Membership
Subscription - find out more click here

 

  • Award - Most practice staff will be covered by the Health Professionals and Support Services Award 2010 - please ensure you are complying with it - Click here to access

posture-picture-300x215

  • Contact your IT provider to ensure your systems are secure, backed up and can manage working from home arrangements.
 
  • Perform a BACKUP of all your electronic records.
  • Norton's how to protect against COVID-19 scams advisory page -click here 
  • Visit The Australian Government's Stay smart online website -click here

Dr Joann Lukins, Associate Professor (Adjunct) at James Cook University and Sports Psychology Consultant to the NRL North Queensland Cowboys, has been kind enough to provide us with some expert advice regarding resilience and mental health during the COVID-19 crisis via these two videos:

Building Resilience

Resilience is our ability, in the face of a challenge to bend and not break. In this video, Dr Lukins outlines the four key elements of resilience, why it is helpful to understand them and how you can build your personal resilience to manage challenges better.

How to stand up after you've been stood down. Navigating the emotions of job loss. from Jo Lukins on Vimeo.

How to Stand Up when you've been Stood Down

An unprecedented shift in restrictions in employment has meant that too many Australians have been stood down by their employers. This has been a heart-breaking and necessary decision in response to the health crisis, Covid-19. Few of us are immune to this experience, either because it has happened to us, or someone that we love. This video helps to understand the grief experience for people who have lost their employment, and what can be done to pick ourselves up and move forward.

Mental Reset from Jo Lukins on Vimeo.

This is a complex area, and there are different requirements and directions in each state and territory, and the situation is subject to change.


In general, your practice can make it a condition of entry that patients and other persons entering your practice wear a face mask or covering, and in some states, there is a public health directive requiring people entering their premises to wear a mask/face covering unless an exemption applies.


Practices have an obligation under the Medical Board of Australia Code of Conduct: Good Medical Practice and WHS legislation to provide a workplace that is safe for staff and other persons at the practice.


However, your practice must also comply with discrimination laws, which are different in each state and territory.


Practices have an obligation to ensure that patients who do not want to wear a mask or face covering or have an exemption are able to access medical services. Practically this could mean offering such patients a telehealth appointment, or treatment at the practice at a time when there are no other patients present, or referral to local clinic or hospital.


As a doctor, you are not under an obligation to provide medical services (even in an emergency) if there is a risk to health and safety.


According to the Medical Board’s Good medical practice: a code of conduct for doctors in Australia, treating patients in emergencies requires you to consider a range of issues in addition to the patient’s best care:
 

  • your own safety
  • your skills
  • availability of other options
  • impact on any other patients under your care

Below are links for each state. Please check your state and be aware that there are differences between states, and that the situation can change rapidly.
 

ACT:     Face mask requirements

NSW:   Face mask rules

NT:      Information about face masks

QLD:    Mandatory face masks

SA:       Face masks

TAS:     Face masks

VIC:      Face mask

WA:      Face masks


We suggest that Ophthalmologist’s make ‘reasonable arrangements’ to accommodate the class of persons who refuse to wear a mask. We recommend that Ophthalmologists incorporate in their practice policy ‘reasonable arrangements’ for the safety of practice staff/ other patients and to continue to provide a service to those patients as follows:
 

  1. All presenting patients to the practice must comply with the Public Health mandated requirements to wear a mask for entry to the practice and face to face consults.
  2. All patients with respiratory symptoms attending the practice must (either) be seen via telehealth, or if a face to face consultation is required, proof of a negative COVID test result within 36 hours of their appointment must be provided on entry to the practice. (or whatever timeframe is clinically appropriate given infectious period data on the Delta strain of the virus)
  3. Patients with a valid medical exemption from wearing a mask must (either) be seen via telehealth, or if a face to face consultation is required, proof of a negative COVID test result within 36 hours of their appointment must be provided on entry to the practice. (or whatever timeframe is clinically appropriate given infectious period data on the Delta strain of the virus)

Where a legal exemption from compliance with Public Health Orders applies, we accept it is your right to not wear a mask in accordance with the Public Health mandated requirements. Please help us maintain the health and safety of our staff and our vulnerable patients by ensuring you comply with our COVID testing requirements prior to your attendance at our Practice.


The above listed telehealth and COVID testing requirements are reasonable safety precautions in the current circumstances and ensure that class of (sometimes difficult) patients are unable to argue that they are not being provided a service based solely on their inability to wear a mask (whether their reason for non-compliance is valid or not).

Doctors are not obliged to treat patients unless it is an emergency, or a contractual requirement.

Doctors may consider a range of issues  when deciding who they treat,  and this circumstance has been contemplated by the Medical Board of Australia in Good medical practice: A code of conduct for doctors in Australia:
 

  • 2.4.5 One of the considerations relates to your ability to keep …yourself and your staff safe when caring for patients. If a patient poses a risk to your health and safety or that of your staff, take action to protect against that risk. Such a patient should not be denied care, if reasonable steps can be taken to keep you and your staff safe.
  • 2.5 Treating patients in emergencies requires doctors to consider a range of issues, in addition to the patient’s best care. Good medical practice involves offering assistance in an emergency that takes account of your own safety, your skills, the availability of other options and the impact on any other patients under your care.

If you feel you are not in a position to keep yourself, your staff, or your other patients safe in light of COVID-19, then you can decline to treat or suggest high risk patients postpone non-urgent appointments. This will be taken into account by Ahpra in the event of a complaint.

If a patient cannot be seen at the practice, they should be directed to an appropriate alternative to access care, taking into account local resources.

 

Many hospitals and child care require immunisation of staff, however we are unable to provide a response which takes into account every practice’s individual circumstances.  Mandatory vaccination of health practitioners is largely mandated by policy directive of individual state and territory health authorities. In Victoria  the Health Services Act 1988  (VIC) state that the Chief Health Officer can issue a public health  order requiring a person to receive prophylaxis which includes a vaccine. Below are some of the issues to consider:
 

Clinical considerations

Employment considerations

  • The laws allowing for certain workplace direction (e.g. a requirement to be immunised) vary between different jurisdictions, awards and contracts.
  • The requirement, if not appropriately implemented, may be discriminatory or a breach of workplace law. Consideration of State and Territory antidiscrimination laws.
  • Do you have an existing workplace policy employment requirement in relation to immunisation or are you bringing in a new policy or employment requirement It could be challenging to argue for compulsory COVID-19 vaccination if the requirement has not been in place for influenza
  • Assess role based level of staff risk. If staff have a medical exemption or contraindication to vaccination, consider whether role modification or re-deployment.
  • What steps will you take in the event of a breach, and are those actions lawful.

Further information

https://coronavirus.fairwork.gov.au/coronavirus-and-australian-workplace-laws/covid-19-vaccinations-and-the-workplace

https://www.mja.com.au/journal/2021/215/1/medico-legal-considerations-mandatory-covid-19-vaccination-high-risk-workers