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Background

It is clear that we are facing an unprecedented global public health emergency caused by the continuing spread of COVID-19.  All statutory services have a part to play in supporting the wider humanitarian response and local authorities and support providers have a key role to play.

Purpose

This guidance is for local authorities and support providers involved in delivering supported and temporary accommodation and support to people who are sleeping rough. It sets out the need to put practical measures in place to deal with situations where:

  • People are unwilling or unable to follow self isolation and lockdown instructions in supported accommodation, hostels and temporary accommodation.
  • People who are sleeping rough who are unwilling or unable to follow self isolation and lockdown instructions.

Approach for people in supported accommodation, hostels or temporary accommodation

Existing Residents

All existing service users at the accommodation should receive a letter about the COVID-19 regulations and measures in place to follow at the accommodation. The accommodation provider should use letter template 1 at Annex A for this purpose. Where people have difficulty understanding written information, support providers should take steps to ensure that people understand the contents of the letter. This could include people with literacy issues, learning difficulties, disabilities or whose first language is not English or Welsh.

New residents

All new service users to the accommodation should receive a letter about the COVID-19 regulations and measures in place to follow at the accommodation. Please use letter template 1. Where people have difficulty understanding written information, support providers should take steps to ensure that people understand the contents of the letter. This could include people with literacy issues, learning difficulties, disabilities or whose first language is not English or Welsh.

When taking in a new service user, the support worker/housing worker/ accommodation provider should undertake an initial risk assessment by ascertaining if the new person coming into the accommodation has any symptoms suggestive of COVID-19.  If they do, they need to follow the current national guidance in requesting that person to self-isolate for 10 days because they are symptomatic.  If they do not have any symptoms, they should follow the social distancing guidance and maintain hygiene and cleaning practices in line with the guidance for local authorities and providers in supported accommodation settings

If for some reason they come into the scheme from another home where they have been self-isolating for 14 days (because they were a household contact of a symptomatic person) then they need not ‘rewind the clock’, but should continue with their original timescale until their 14 days have finished.

Service users who will not adhere to the social distancing rules but are not symptomatic

If an individual will not adhere to the social distancing rules, the support worker/housing worker/accommodation provider should take a trauma informed approach and consider whether they can address any of the reasons why people may not be able or willing to comply.

If the individual continues not to adhere to the social distancing rules as set out in letter 1, and is causing potential harm or risk to others, but is not symptomatic, then the support worker/housing worker/ accommodation provider should contact the police in the first instance. The police will aim to negotiate with the individual to co-operate. The police also have the powers under Regulation 8(5) of Health Protection (Coronavirus Restrictions) (Wales) Regulations 2020 to issue a fixed penalty notice resulting in a fine for an individual who does not adhere to social distancing rules.

Symptomatic Individuals

Any individuals displaying symptoms should isolate for 10 days in line with PHW guidance.  Where symptoms are of significant concern to support workers additional advice should be sought via NHS Helpline 111. If the individual is seriously ill or injured or their life is at risk call 999 as an emergency.

Individuals should be reminded of the written advice provided (letter template 1) which sets out why they need to self-isolate and guidance to follow. Where people have difficulty understanding written information, support providers should take steps to ensure that people understand the contents of the letter. This could include people with literacy issues, learning difficulties, disabilities or whose first language is not English or Welsh.

A risk assessment should be undertaken by support worker/housing worker/ accommodation provider on whether their current accommodation is suitable for the individual circumstances to self- isolate for 10 or 14 days. This should include:

  • Whether the person is likely to be able or willing to comply with self-isolation instructions.  Unwillingness or inability to comply could be due to a person’s experience of trauma, mental health problems and/or substance use problems.
  • Whether the accommodation has communal kitchen and bathroom spaces. If so, whether this can be managed safely or not.
  • Whether the individual has any mental health needs that need to be assessed (e.g. risk of suicide or self-harm)?  And if so, how they can continue to access psychological or psychiatric support.  
  • Whether the individual has any substance use problems, and if so, how these can be met during self-isolation. This may include consideration of prescribing options or harm reduction approaches such as sharps disposal boxes.

The support worker/housing worker/ accommodation provider should contact Public Health Wales (PHW) on 0300 003 0032 (between 8am to 10pm) to log the case and they will advise on whether testing needs to take place and any other advice that can be given.  

Where it is not possible for someone to self-isolate in their current accommodation

Where it is not possible for someone to self-isolate in their current accommodation due to the physical environment, or due to difficulties in understanding or complying with instructions, providers should look to identify and access alternative accommodation. This should be self-contained accommodation with private bathrooms and support should continue to be provided. This should be done in partnership with the local authority and the centralised coordination cells within local authorities, which have been tasked with coordinating accommodation and support services during this pandemic. Where people have mental health and substance misuse problems, this should also be done in partnership with mental health and substance misuse services.

Where an individual is not willing to self-isolate

Step 1

If an individual refuses to self- isolate, in the first instance the support worker/housing worker/ accommodation provider should take a trauma informed approach and consider whether they can address any of the reasons why people may not be able or willing to comply. For example:

  • Have the reasons for self-isolation been communicated effectively? Could you communicate this in a different format or through peer support?
  • Is there a reason connected to their experience of trauma that makes them reluctant or worried about self-isolation?
  • Have you given them assurance that their basic needs will be met?  i.e., providing a kettle and a microwave for them to be able to make their own food/drinks, giving them assurances that someone will pick up food and supplies on their behalf.  
  • Have you provided them with assurances that their support will continue while they're in self isolation? Have you provided them with the technology to enable phone or video support?
  • Have you provided assurances that they can still get their prescriptions?
  • Do they have mental health or substance use problems and have you given them assurances that these support needs will continue to be met?
  • Will they have the ability to communicate with their friends and family during self-isolation? Can you give them internet access, or a smart phone?
  • Are they worried about not having anything to do? Are you able to provide them with some activities, or seek donations of a television or a games console?

Step 2

If a trauma informed approach has been undertaken and the individual still refuses to self-isolate, then the support worker/housing worker/ accommodation provider should contact PHW on 0300 00 300 32 to discuss options available and receive advice.  PHW will liaise with the relevant local authority Environmental Health Officer (EHO) to consider the appropriateness of legal action using their powers under The Health Protection (Local Authority Powers) (Wales) Regulations 2010, Health Protection (Part 2a Orders) (Wales) Regulations 2010 and Schedule 21 Coronavirus Act 2020 (Part 4) and alternative informal action. Procedures and templates for these legal processes are already in place and the action taken will be based on risk and timeliness.

Step 3

Incidents of refusal will be managed between the provider, PHW, local authority EHO with regular liaison, the legal process if implemented will be led by PHW or EHO.  Where the individual can no longer be managed within the accommodation, then consideration should been given again with the local authority and the centralised coordination cell whether alternative accommodation is available and whether the individual would be willing to self- isolate at the alternative accommodation.

Local Authorities will use the ‘All Wales Protocol for the Application of existing health protection legislation for the control of COVID-19 transmission in urgent situations’. PHW may decide to use their powers under Schedule 21 of the Coronavirus which would be considered more timely use of the Part 2A Order. Decisions will be based on a case by case basis.

Approach for people who are sleeping rough

Every effort should be made on a continuing basis to accommodate everyone and avoid the need for anyone to sleep rough. A general information leaflet is available which can be issued to people sleeping rough, which provides general information on COVID-19 and social distancing advice.

Symptomatic Individuals

Should an individual who is sleeping rough present with symptoms then contact should be made with outreach services in the first instance to arrange suitable temporary accommodation in line with the COVID-19 Guidance for local authority support for rough sleepers.

When seeking accommodation the outreach service and local authority should conduct a risk assessment to identify what type of accommodation would be suitable for the person. This should include:

  • Whether the person is likely to be able or willing to comply with self-isolation instructions. This could be due to their experience of trauma, mental health problems and/or substance use problems.
  • Whether the accommodation has communal kitchen and bathroom spaces. If so, whether this can be managed safely or not.
  • Whether the individual has any mental health needs that need to be assessed (e.g. risk of suicide or self-harm)?  And if so, how they can continue to access psychological or psychiatric support.
  • Whether the individual has any substance use problems, and if so, how these can be met during self-isolation. This may include consideration of prescribing options or harm reduction approaches such as sharps disposal boxes.

If it is suitable and the individual is co-operating then they should be moved to the temporary accommodation to self-isolate and the support worker/housing worker/ accommodation provider should contact PHW to log the case and receive any advice on testing.  

Where an individual is not willing to self-isolate

Outreach staff should follow the principles of assertive outreach, recognising that it takes time to build relationships and trust with people who have been sleeping rough. This includes being purposeful, persistent, and person-centred, giving people multiple opportunities to engage. While the current pandemic places more urgency on securing accommodation, it is important that outreach staff maintain a trauma informed approach to encouraging people to access accommodation.

If an individual is not willing to co-operate and move to temporary accommodation to self –isolate, in the first instance the outreach team should take a trauma informed approach and consider whether they can address any of the reasons why people may not be able or willing to comply. For example:

  • Have the reasons for self-isolation been communicated effectively? Could you communicate this in a different format or through peer support?
  • Is there a reason connected to their experience of trauma that makes them reluctant or worried about self-isolation?
  • Have you given them assurance that their basic needs will be met?  i.e., providing a kettle and a microwave for them to be able to make their own food/drinks, giving them assurances that someone will pick up food and supplies on their behalf. 
  • Have you provided them with assurances that they will receive support while they're in self isolation? Have you provided them with the technology to enable phone or video support?
  • Have you provided assurances that they can still get their prescriptions?
  • Do they have mental health or substance use problems and have you given them assurances that these support needs will continue to be met?
  • Will they have the ability to communicate with their friends and family during self-isolation? Can you give them internet, or a smart phone?
  • Are they worried about not having anything to do? Are you able to provide them with some activities, or seek donations of a television or a games console?

If the individual is still unwilling to cooperate then the outreach team should contact PHW on 0300 003 0032 (between 8am to 10pm) to log the case and they will advise on whether testing needs to take place and any other advice that can be given. PHW will liaise with the relevant local authority EHO to consider the appropriateness of legal action using their powers under The Health Protection (Local Authority Powers) (Wales) Regulations 2010, Health Protection (Part 2a Orders) (Wales) Regulations 2010 and Schedule 21 Coronavirus Act 2020 (Part 4) and alternative informal action. Procedures and templates for these legal processes are already in place and the action taken will be based on risk and timeliness.

Incidents of refusal will be managed between the provider, PHW and local authority EHO with regular liaison, the legal process if implemented will be led by PHW or local authority EHO. Consideration should been given again with the local authority and the centralised coordination cell whether alternative accommodation is available and whether the individual would be willing to self- isolate at the alternative accommodation.

Local Authorities will use the ‘All Wales Protocol for the Application of existing health protection legislation for the control of COVID-19 transmission in urgent situations’. PHW may decide to use their powers under Schedule 21 of the Coronavirus which would be considered more timely use of the Part 2A Order. Decisions will be based on a case by case basis.

People sleeping rough who will not adhere to social distances rules but are not symptomatic

If an individual will not adhere to the social distancing rules, the outreach team should take a trauma informed approach and consider whether they can address any of the reasons why people may not be able or willing to comply.

If the individual continues not to adhere to the social distancing rules, and is causing potential harm or risk to others, but is not symptomatic, then the outreach team should contact the police in the first instance. The police also have the powers under Regulation 8(5) of Health Protection (Coronavirus Restrictions) (Wales) Regulations 2050 to issue a fixed penalty notice resulting in a fine for an individual who does not adhere to social distancing rules.

Mental Capacity Act 2005 and Deprivation of Liberty Safeguards

The UK Government has issued Guidance on the Mental Capacity Act (2005) (MCA) and Deprivation of Liberty Safeguards (DoLS) during the Coronavirus (COVID-19) Pandemic

This emergency guidance is for health and social care staff in England and Wales who are caring for, and/or treating, a person who lacks the relevant mental capacity to consent to that care and/or treatment during the coronavirus outbreak.

The guidance ensures that decision makers are clear about the steps they need to take during this period. It focuses on new scenarios and potential ‘deprivations of liberty’ created by the outbreak.

During the outbreak, the principles of the Mental Capacity Act 2005 (MCA) and the safeguards provided by the Deprivation of Liberty Safeguards (DoLS) still apply.

The Mental Capacity Act 2005 provides protections for people who lack or may lack the relevant mental capacity to make decisions about different aspects of their life.

The Deprivation of Liberty Safeguards are an important part of this Act and provide further safeguards for those who need to be deprived of their liberty in order to receive care or treatment in a care home or hospital, but do not have the capacity to consent to those arrangements. This guidance also applies to other settings, including supported housing.  This is set out in paragraphs 23 and 24 of the guidance:

Any other setting:

23. The same framework for determining best interest decisions and depriving a person of their liberty set out in the guidance above should be applied when considering the arrangements for care or treatment for a person who lacks the relevant capacity in other settings such as supported living.

24. If the arrangements do amount to a deprivation of liberty, then a referral should in most cases be made to the Court of Protection. The Court has issued their own guidance for this emergency period and will continue to update it as needed.

Other guidance

The Welsh Government along with other devolved nations is part of the UK Action Plan for tackling COVID-19.

Advice on COVID-19 is updated regularly and available on:

These sites are both updated on a regular basis with a range of guidance.

Please also note the advice from the information commissioner on data sharing

This guidance should be read in conjunction with other relevant guidance which has been published:

COVID-19: Guidance for local authorities and providers in supported accommodation settings

COVID 19: Guidance for providers of accommodation for survivors of violence against women, domestic abuse and sexual violence: coronavirus

COVID 19:  Guidance for local authorities support rough sleepers

COVID 19:  Guidance for substance misuse and homelessness services

Personal protective equipment (PPE)

For guidance on PPE in housing, health and social care supporting settings – see the latest advice from Public Health Wales.

Welsh Government written statement 25 March 2020

Welsh Government written statement 30 March 2020

Annex A – Letter template 1

Letter Template 1: for existing and new residents in supported accommodation, hostels and temporary accommodation setting out measures which they must follow in preventing the spread of coronavirus

Dear Resident 

Limiting the spread of Coronavirus – Information Notice

Your co-operation to limit the spread of Coronavirus is really important. Coronavirus is highly infectious and poses a significant risk to the health of you and other people.

Measures have been put in place and every person in the UK must comply with them to limit the spread of Coronavirus. The relevant authorities, including the police, have been given the powers to enforce them – including through fines and dispersing gatherings.

This letter explains in detail the things which you can and cannot do to make sure that coronavirus illness does not spread. 

You MUST:

1.   Comply with all requests from the Local Authority, Public Health Wales and your accommodation provider to ensure that infection is prevented.

2.   Stay at your accommodation and only leave for the following reasons:

  • to get food or medicines but only when you really need to.
  • to do one form of exercise a day – for example a run, walk or cycle.  You can go alone or with the person(s) you share your room with.
  • to get any medical need, or to provide care or to help a vulnerable person. 
  • If you are required to work and you are classed as a keyworker;
  • If you are required to attend an essential appointment and you are unable to do this over the telephone.

3.  Remember to stay 2 metres (6 feet) apart from anyone you aren’t living with.

Symptoms for Coronavirus

The most common symptoms are:

  • a new continuous cough – this means you’ve started coughing repeatedly
  • a high temperature – you feel hot to touch on your chest and back.

What should you do if you get symptoms?

You must let your accommodation provider/support worker know. Stay in your room by yourself for 10 days in order to avoid contact with any other person. Your support worker/ provider will make the necessary arrangements to ensure that you continue to receive food supplies and any medication required.

If you share your room with another person you may be asked to move to a separate room to self-isolate for 10 days.

If there isn’t a single room available, you must stay in the same room with the person you have been sharing with and you both must stay in the room for 14 days

Things you can do to reduce getting coronavirus

Follow these simple steps to reduce the risk of you and anyone you share your accommodation with getting ill with coronavirus:

  • Wash your hands with soap and water often – do this for at least 20 seconds.
  • Use hand sanitiser gel if soap and water are not available.
  • Wash your hands as soon as you get back to your home.
  • Cover your mouth and nose with a tissue or your sleeve (not your hands) when you cough or sneeze.
  • Put used tissues in the bin immediately and wash your hands afterwards.
  • Limit the time spent in shared areas within your dwelling and keep 2 metres (6 feet) apart from others.

It is essential that you adhere to the measures outlined in the notice, if you do not comply further restrictions may be placed on you by the court.

If you have any queries regarding the contents of this letter, or if you are having difficulty complying with the requirements, then do not hesitate to contact your case or support worker directly. 

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