Patient vaccination – COVID-19
If your practice decides that patients are required to be vaccinated against COVID-19 to attend face-to-face consultations, that decision should be made in the context of your individual practice. Considerations include (but are not limited to):
- the health and vaccination status of clinicians (and self)
- the needs of the local population
- alternate points to access primary health care in the area
- stocks of PPE
- whether the patient is presenting with or without respiratory symptoms
- continuity of care needs for the patient
- the current outbreak setting in your location
- your practice’s capability to provide telehealth as an alternative.
In the absence of Public Health Orders mandating COVID-19 vaccination of patients before attending a health service, the RACGP urges GPs and practices to carefully consider practice concerns as well as patient needs. While determining vaccination policies for your practice, consider whether there are alternative ways of continuing to provide care to your patients. This may include improved infection prevention and control processes, adequate ventilation with an aim of 6 – 8 fresh air changes per hour, and the use of telehealth consultations.
Providing continuity of care to unvaccinated patients may facilitate ongoing opportunities to discuss the importance of vaccination with these patients. The RACGP believes that many patients who are hesitant may decide to have the vaccine following a discussion with their GP or the practice nurse who are a trusted source of information. Discussion about possible intranasal delivery of COVID-19 vaccines this year may also assist in building these patients’ confidence and willingness to become protected against COVID-19.
If you or your practice implement a requirement for vaccination as a mandatory pre-requisite for care, you must be mindful that you are subject to regulatory requirements, such as the Medical Board’s Code Of Conduct, and may be inadvertently unlawfully discriminating against some patients. This may make you subject to compliance investigations, professional conduct complaints or complaints to the Human Rights Commission or equivalent state bodies. This is particularly relevant where a person cannot be vaccinated because of a medical condition, their age (i.e., children under 5 are currently not eligible), or their religious beliefs.
As per the guidance from Australian Health Practitioner Regulation Agency (AHPRA) and the National Medical Board's Facilitating access to care in a COVID-19 environment, all health practitioners are expected to facilitate access to care, regardless of someone’s vaccination status.
This is an emerging field in law and in the first instance the RACGP recommends that if you or your practice are wishing to pursue a mandatory vaccination policy, that you have a conversation with your medical defence organisation to discuss your practice’s particular circumstances.
Co-administration with COVID-19 vaccines
Content: All COVID-19 vaccines can be co-administered (given on the same day) with a flu vaccine. COVID-19 vaccines can also be co-administered with other vaccines if required.
Although you are under no obligation to bulk bill patients receiving a flu vaccination, patients who receive a COVID-19 vaccination in the same appointment must be bulk billed for the MBS COVID-19 vaccine suitability assessment component.
If another attendance is provided on the same day as the vaccine suitability assessment service that is separate and/or unrelated to the vaccine service, the patient’s invoice/account or Medicare claim should be annotated (‘additional service [MBS item] is clinically relevant but not related to the vaccine suitability assessment service [MBS item]’) to help with the assessment of the claim.
Patients presenting for their COVID-19 booster or seasonal flu vaccination provides an opportunity to check whether the patient may be eligible or overdue for other vaccines.
For more information on the MBS COVID-19 vaccine suitability assessment items, visit MBS Online.