Page last updated 18 January 2021. Latest pdates appear in red text.
1. Check your insurance
2. Assess the risks of reopening
3. Prepare for social distancing
4. Appointment timings
5. Treatment time
6. Temperature checks
7. Deep clean and prepare for ongoing deep cleaning and hygiene
8. Handwashing facilities
9. Communications and signage
10. Removing risk items from common areas
11. Contactless payment facilities
12. Seeing clients in their own homes
13. Update policies and agreements
14. Face coverings, face masks and Personal Protective Equipment (PPE)
1. Check if clients are in COVID-19 high risk categories
2. Check if clients are in COVID-19 moderate risk categories
3. Screening for COVID-19 symptoms and when not to treat
4. When you should not treat clients
This advice applies to all CNHC Registrants, whether they are able to work with their clients while maintaining social distancing (face to face therapies) or practise ‘hands-on’ therapies (also known as close contact services). See Definitions below.
This advice will help you to follow government guidance on returning to work and working safely during the coronavirus pandemic.
You must follow guidance from the government of the country you practise in:
- England:: See Working safely during the coronavirus (COVID-19) and Staying alert and safe (social distancing).
- Northern Ireland: See Advice for businesses and workers and Coronavirus: Working safely in different business settings
- Scotland: See Coronavirus (COVID-19) Information for individuals and businesses in Scotland.
- Wales: See Coronavirus (COVID-19) Staying safe at work.
Additionally, for close contact services, you should check the guidance of the country you practise in:
- England and Northern Ireland: See Working safely during the coronavirus (COVID-19): Close contact services.
- Scotland: See Coronavirus (COVID-19): retail sector guidance including close contact services and Checklist for salons and close contact services.
- Wales: See Beauty, holistic and wellbeing services: coronavirus workplace guidance. It includes a restart risk assessment and a reopening checklist.
You are advised to check the relevant government guidance on a regular basis as it will be updated.
You should also refer to guidance issued by the professional organisation that verified your CNHC registration, as it may contain information specific to the discipline you practise.
Face to face therapies and close contact services have resumed in in England, Northern Ireland, Scotland and Wales subject to the following:
High/highest risk zones
Restrictions on treating the high/highest risk zone (ie the area in front of the face) vary for each UK country:
- England: From 15 August 2020 treatments to the highest risk zone (defined as "the area in front of the face where splashes and droplets from the nose and mouth may be present, which can pose a hazard") can recommence.
- Northern Ireland: Treatments to the highest risk zone cannot take place.
- Scotland: The ‘high risk zone’ is defined as ‘the area in front of the face where splashes and droplets from the nose and mouth may be present, which can pose a hazard’. If treatments in the high risk zone cannot be carried out without the ability to be provided from the side of the face or behind the head and therefore require prolonged periods in the highest risk zone then they should not be offered at this time.
- Wales: Guidance from the Welsh Government states that manual treatments and acupuncture in the ‘high risk zone’ (the area directly in front of the client’s eyes, nose and mouth) cannot be provided at this time. Indian Head Massage is permitted provided the practitioner wears a visor and avoids prolonged periods of activity in the high-risk zone.
Working in clients’ homes
In Scotland you cannot see clients for 'hands-on' (close contact) treatments in their homes. You can only treat them at your own premises.
Local restrictions on returning to work
Returning to work is subject to local lockdowns or restrictions put in place in areas where there are local COVID-19 outbreaks. You are advised to consult local restrictions guidance to see if any restrictions are in place in your area:
UPDATE: National lockdown approved by Parliament (updated 6, 11 & 18 January 2021)
On 4 January 2021 the Prime Minister, Boris Johnson, announced that England would go into a national lockdown with effect from midnight that night. The Government published relevant guidance on the lockdown requirements. Under the section ‘Businesses and venues which can remain open’ it states: “The full list of these businesses can be found in the guidance on closing certain businesses and venues in England.”
The businesses that can remain open include “dental services, opticians, audiology services, chiropody, chiropractors, osteopaths and other medical or health services, including services relating to mental health.” Under the legal advice we obtained during the November 2020 national lockdown in England, CNHC Registrants in England meet the definition of “other…health services, including services relating to mental health” contained in Section 17(o), Schedule 3A of The Health Protection (Coronavirus, Restrictions) (All Tiers) (England) Regulations 2020. The amended legislation on which Parliament voted today made no changes to that section of the Regulations.
This means, as a CNHC Registrant, you can continue to practise in England during the current restrictions if you meet the criteria set out below.
In order to stay within the remit of providing “other…health services, including services relating to mental health”:
- You must only provide the therapies you are registered for, on a one-to-one basis to clients, for an identified mental or physical health condition or injury that is causing them severe pain or having an adverse impact on their mobility or their quality of life. (updated 18 January 2021)
- You must engage in Evidence Based practice and In compliance with Section D1 of the CNHC Code of Conduct, Ethics and Performance “you must recognise and work within the limits of your own knowledge, skills and competence”. (updated: 11 January and 18 January 2021)
- You must be able to evidence that your therapeutic intervention is supporting your client with their condition. You cmust do this by recording their health condition and giving a clear rationale in your client’s care record for the treatment that you are providing, (updated 18 January 2021)
- You cannot provide treatment to a client in their own home unless you have received a direct referral from a statutory regulated health professional.
- If your practice is based in your own home you can continue to work from there as long as it is COVID-secure. You can find our advice on following government guidance on working safely here.
N.B. On the CNHC Register it is only hypnotherapists who are trained to support mental health conditions. (updated 18 January 2018)
We cannot stress enough the severity of the situation we are now in, with a surge in infection rates of the highly transmissible new variant of COVID-19 placing increasing pressure on the NHS. You must exercise the utmost caution and exercise your professional judgement in assessing the risks. You must carry out and record a risk assessment on whether the tangible benefits of seeing a client in person outweighs the risks. Practise remotely where you can and follow our advice on following government guidance on working safely which you can find here. (updated 18 January 2021)
UPDATE National lockdown announced (updated 5 January 2020)
The Prime Minister, Boris Johnson, announced last night (4 January) that England would go into a national lockdown with effect from midnight last night.
We have looked at all the information issued by the Government but have not seen the regulations that give legal effect to the lockdown, which go before Parliament tomorrow. We will provide our Registrants with an update once these regulations are published.
UPDATE: Formal tiering review (updated 30 December 2020)
The Government announced on 30 December that more areas will move to Tier 3 or Tier 4 on Thursday 31 December to limit the spread of coronavirus. Find out more here.
UPDATE: More areas to move into higher tiers (updated 24 December)
From 26 December more areas in England will move into higher tiers. You can find the full list of local restrictions by area here.
UPDATE: Advice on working in tier 4 (updated 22 December)
The regulations that give legal effect to tier 4 have now been published. Based on the legal advice we previously received, CNHC Registrants in England meet the definition of “other…health services, including services relating to mental health” contained in Section 17(o), Schedule 3A of The Health Protection (Coronavirus, Restrictions) (All Tiers) (England) Regulations 2020. This means you can continue to practise in England during Tier 4 restrictions if you meet the criteria set out below.
In order to stay within the the remit of providing “other…health services, including services relating to mental health:
- You must only provide the therapies you are registered for, on a one-to-one basis to clients, for an identified mental or physical health condition or injury that is causing them pain or having an adverse impact on their mobility or their quality of life.
- You must be able to evidence that your therapeutic intervention is supporting your client with their condition. You can do this by recording their health condition and giving a clear rationale in your client’s care record for the treatment that you are providing.
- You cannot provide treatment to a client in their own home unless you have received a direct referral from a statutory regulated health professional.
- If your practice is based in your own home you can continue to work from there as long as it is COVID-secure. You can find our advice on following government guidance on working safely here.
- You must exercise the utmost caution and exercise your professional judgement in assessing the risks. The new variant of COVID-19 is highly transmissible. You must carry out a risk assessment on whether the benefits of seeing a client in person outweighs the risks. Practise remotely where you can and follow our advice on following government guidance on working safely which you can find here.
If you are contacted by your local authority and asked why you are open during tier 4 restrictions, you can show or forward this email we have sent to all CNHC Registrants in England andor ask them to contact us at firstname.lastname@example.org
If you are in tier 4 you can continue to work remotely with clients who do not have identifiable health needs (as defined above) but you cannot see them in person.
If you are in tiers 1 to 3 you can continue to see clients iface to face and also provide close contact services 9i.e. 'hands-on therapies where social distancing is not possible). The full list of local restriction tiers by area can be found here.
We will be updating the information on our website on a regular basis and advise you to check it for the latest updates. We also suggest you monitor the news and the UK government website for further government announcements over the holiday period.
UPDATE: New Tier 4 local restriction tier introduced in London, the South East and East of England (updated 21 December)
On Saturday 19 December the Prime Minister announced that as a result of a new variant of COVID-19 which is more transmissible, infection rates have increased in London, the South East and the East of England. The Government have therefore introduced new restrictions in the most affected areas – specifically those parts of London, the South East and the East of England which are currently in tier 3.
These areas entered into a new tier 4 on Sunday 20 December, which will be broadly equivalent to the national restrictions which were in place in England in November.
CNHC are waiting for the regulations that give legal effect to tier 4 guidance to be published, to see whether complementary therapists on accredited registers can be considered to be exempt from the requirement to stop working. In the meantime all CNHC Registrants, unless they are working remotely, must cease practising. We will send you an update as soon as the legal regulations are published.
UPDATE: New local restriction tiers coming into effect on 2 December (updated 1 December 2020)
The national lockdown introduced on 5 November ends on 1 December. This is being replaced by a new tier system. Although less restrictive than the national lockdown the new three tier system will be stricter than the previous one. The new local restriction tiers are:
Tier 1: Medium alert
Tier 2: High alert
Tier 3: Very High alert.
In all three tiers “personal care”, the category in which complementary healthcare is deemed to fall under, can remain open. This includes mobile working. Guidance on the local restriction tiers can be found here.
The full list of local restriction tiers by area can be found here.
UPDATE: National restrictions for England from 5 November until 2 December (updated 9 & 26 November and 1 December)
CNHC sought legal advice on whether the complementary healthcare practitioners we register are included in the businesses permitted to remain open during the national restrictions in England introduced by the Government on 5 November.
The advice we received stated that CNHC Registrants in England meet the definition of “other…health services, including services relating to mental health” contained in Section 47, Part 3 of the Schedule to The Health Protection (Coronavirus, Restrictions) (England) (No. 4) Regulations 2020.
This legal advice has taken into account that in Sections 25D and 25E of the NHS Reform and Health Care Professions Act 2002 (as inserted by the Health and Social Care Act 2012) practitioners on Accredited Registers are defined as engaged in work that includes the provision of healthcare.
What does this mean for CNHC Registrants?
CNHC Registrants can continue to provide the therapies they are registered for, on a one-to-one basis, for an identified mental or physical health condition or injury that is causing them pain or having an adverse impact on their mobility or their quality of life. You must be able to evidence that your therapeutic intervention is supporting your client with their condition. You can do this by:
Identifying a health need: This is for you to establish using your professional judgement and expertise in the discipline you practise, based on information you should elicit from your client/potential client before agreeing to see them. You may decide to undertake further research, confer with colleagues at your practice or seek the advice of your professional association (while maintaining client confidentiality) before confirming a health need.
Evidencing a health need: Unless you have received a direct referral from a statutory regulated health professional, you must be able to evidence that your therapeutic intervention is supporting your client with their condition. You can do this by noting in your client records:
The symptoms your client has.
The adverse impact those symptoms are having on their daily life.
Their medical history, including any pre-existing conditions or diagnosis they have received from their GP, hospital consultant, or other regulated health professional.
A clear rationale for the care that you are providing.
You should already be keeping detailed, up to date and attributable client records. See CNHC’s Code of Conduct, Ethics and Performance, section B7 “Maintaining client records” (at page 17).
You cannot provide treatment to a client in their own home unless you have received a direct referral from a statutory regulated health professional.
If your practice is based in your home
If your practice is based in your own home you can continue to work from there as long as it is COVID-secure. You can find our advice on following government guidelines on working safely here.
UPDATE: National lockdown in Scotland (updated 8 January 2020)
The First Minister announced a national lockdown this week for all areas previously in Level 4. The restrictions will be in place for at least 4 weeks but will be kept under review and could be extended. You can find the guidance on the stay at home regulations here.
In areas subject to the stay at home regulations:
Our advice remains the same. All CNHC Registrants (and not just those providing close contact services), unless they are working remotely, must cease practising in mainland Scotland and the Isle of Skye until further notice.
In level 3 areas:
The following areas remain in level 3 :
- Na h-Eileanan Siar (Western Isles)
- The following islands within Argyll and Bute: Coll, Colonsay, Erraid, Gometra, Iona, Islay, Jura, Mull, Oronsay, Tiree, and UlvaAll islands in Highland (with the exception of the Isle of Skye).
CNHC Registrants can continue to work face to face and provide close contact services in level 3 areas. The exception is mobile close contact services, which will not be able to operate in Level 3.
UPDATE: New level 4 guidance announced for Scotland coming into effect from Boxing Day
The First Minister has announced that, as a result of the new variant of coronavirus being identified in Scotland, from 26 December 2020.
As of 0.01am on the 26th of December, all of mainland Scotland will enter level 4 restrictions for three weeks. Orkney, Shetland and the Western Isles, and the other island communities will be placed in Level 3 (except the Isle of Skye, which will move to level 4)..
What does this mean for CNHC Registrants in level 4: In the absence of a response to CNHC from the Scottish Government on the status of CNHC Registrants, and for the protection of public health, all CNHC Registrants (and not just those providing close contact services), unless they are working remotely, must cease practising for the next three weeks.
We will contact Registrants if we receive more information from the Scottish Government.
UPDATE: Changes to local protection levels announced (updated 9 December 2020)
On 8 December the First Minister announced some changes to local council restrictions, to come into effect at the end of this week.
The 11 council areas in level 4 will move into level 3
From 6pm on Friday 11 December, those 11 council areas currently in level 4 will move into level 3. The council areas are City of Glasgow, Renfrewshire, East Renfrewshire, East Dunbartonshire, West Dunbartonshire, North Lanarkshire, South Lanarkshire, East Ayrshire, South Ayrshire, Stirling and West Lothian.
Close contact retail services can reopen on the morning of 11 December
Retail can reopen from 6am on Friday 11 December instead of 6pm to manage business flow. As close contact complementary therapies (i.e. 'hands-on' therapies where social distancing is not possible) are deemed to fall into the category of close contact retail services for the purpose of COVID-19 restrictions in Scotland, it means that CNHC Registrants providing close contact services can resume work from Friday morning. This includes home treatment rooms. However, mobile working is not permitted in level 3.
Travel restrictions remain in place in level 3
Non-essential travel into or from another level 3 area is prohibited by law.
Non-essential travel into or from a level 3 area to a lower protection level area is prohibited by law.
Travel for work is considered essential. Therefore Registrants can travel into another council area for work purposes, except for mobile treatments. However,Registrants are urged tocarefully consider if a client travelling into a level 3 area from a lower tier or across a level 3 council border is essential.
Three council areas currently in level 3 will move into level 2 at 6pm on 11 December
The situation in theses areas in relation to close contct working remains the same. You can provide close contact services from your premises, including a home treatment room. However mobile working is not permitted.
Two council areas in level 2 will move into level 1 at 6pm on 11 December
- The Borders
- Dumfries and Galloway.
This means that mobile services can resume in these areas as they are now in level 1, provided that the therapist lives in a level 0 or level 1 area. Guidance on mobile working can be found here.
Find out more about the changes to local restriction levels
More information on the changes to the local protection levels can be found here.
New system of local protection levels introduced (information updated 1 November and 12 November 2020)
A new system of local protection levels has been introduced from 2 November 2020:
Levels 0 and 1: You can provide close contact services (i.e. 'hands-on' therapies where social distancing is not possible) including mobile services.
Levels 2 and 3: You can provide close contact services from your premises, including a home treatment room. However mobile working is not permitted.
Level 4: All CNHC Registrants providing close contact services must stop working. On 17 Noveember the First Minister, Nicola Sturgeon, has announced that 11 council areas will go into her highest tier of restrictions from 6pm on Friday 20 November 2020 for 3 weeks. The 11 council areas are: City of Glasgow, Renfrewshire, East Renfrewshire, East Dunbartonshire, West Dunbartonshire, North Lanarkshire, South Lanarkshire, East Ayrshire, South Ayrshire, Stirling, West Lothian.
Travel restrictions: Travel into and out of parts of Scotland that are in level 3 and level 4 areas will be against the law from Friday. The current guidance on non-essential travel has only been advisory but will become law from Friday.
- People in level 3 or level 4 areas will not be allowed to travel outside those areas unless it is essential.
- People from other parts of Scotland will not be able to travel into level 3 or 4 areas unless it is essential.
- People in Scotland will not be allowed to travel to other parts of the UK unless it is essential.
As close contact services must close in level 4, CNHC Registrant living in tiers 0-3 cannot travel to work in tier 4. However, REgistrants can travel from their home in tier 4 to work in a lower tier 3 area but please be mindful of the national effort to control the virus and carefully consider if your travel is essential and within the law. More information can be found here.
You can find additional guidance issued by the Scottish Government here, which includes specific guidance on mobile working.
N.B Services offered in the ‘high risk zone’: For levels 0 to 3 the Scottish Government's guidance states:
"The ‘high risk zone’ is defined as ‘the area in front of the face where splashes and droplets from the nose and mouth may be present, which can pose a hazard’. If treatments in the high risk zone cannot be carried out without the ability to be provided from the side of the face or behind the head and therefore require prolonged periods in the highest risk zone then they should not be offered."
N.B. Face coverings: Your clients must wear face coverings. No treatment should be performed that requires the face covering to be removed. See the additipnal guidance issued by the Scottish Government here. [updated 26 November 2020]
You can check the protection level for your area and find out what you can and cannot do under each level here. You can also use this postcode checker to find out which tier of protection applies to you.
UPDATE: New restrictions in Northern Ireland from Boxing Day (updated 23 December 2020)
Following an increase in coronavirus (COVID-19) cases, additional restrictions are being introduced in Northern Ireland. The restrictions will apply from 12.01 on 26 December 2020 and last for six weeks with a review after four weeks. You can find government guidance for the new restrictions here.
In the absence of a response to CNHC from the Northern Ireland Executive on the status of CNHC Registrants, and for the protection of public health, all CNHC Registrants (and not just those providing close contact services), unless they are working remotely, must cease practising for the next six weeks. The only exception to this at the moment, as set out in the guidance is: "sports massage and therapeutic services for elite athletes".
We will contact Registrants if we receive more information from the Northern Ireland Executive.
UPDATE: Close contact services by appointment can resume on Friday 11 December (updated 10 December)
The circuit-breaker measures introduced on 27 November come to an at midnight on 10 December. All CNHC Registrants providing close contact services (i.e. practising 'hands-on' where social distancing is not possible) can see clients by appointmemt only from Friday 11 DEcember. You can find the latest guidance on the nidirect website.
New circuit-breaker measures from 27 November to 10 December (updated 1 December 2020)
The restrictions will apply from 00:01 on 27 November 2020 until 23:59 on 10 December. All CNHC Registrants providing close contact services (i.e. 'hands-on therapies where social distancing is not possible) in Northern Ireland must stop working during this time.
Exceptions: You may continue to work:
- In a statutory regulated setting e.g. a hospital or hospice where the therapy you provide is part of a patient's care plan
- If your client has been referred to you by a statutory regulated health professional.
- If you are providing sports massage therapy to an elite athlete.
You can find more information and guidance on the nidrect website here.
Circircut breaker extended but close contact services can return to worki (Updated 13 November
The Northern Ireland Executive has taken the decision to extend the circuit-breaker measures that were introduced on 16 October. Close contact services can resume by appointment on Friday 20 November. For more information read the Statement on Executive decisions – 12 November 2020. (Updated 13 November 2020).
Circuit-breaker introduced (updated 19 October)
The First Minister outlined the Northern Ireland Executive's decisions to the Assembly on 14 October 2020. The restrictions, which will come into force on Friday 16 October for an initial period of 4 weeks, include: “Closure of close contact services apart from those meeting essential health needs which will be defined in the regulations to ensure continuation of essential health interventions and therapeutics. This will not include complementary treatments.”
All CNHC Registrants with practices in Northern must stop working from 6pm on 16 October for the next 4 weeks. Updated guidance can be found here.
UPDATE: Alert level four brought forward in Wales from midnight 19 December (updated 21 December)
On 19 December the First Minister announced that the new more easily transmissable strain of COVID-19 is present throughout Wales. The Welsh government decided to bring forward the alert level four restrictions for Wales, in line with the action being taken in London and the South East of England. On reviewing guidance issued by the Welsh Government, CNHC have concluded that all CNHC Registrants in Wales who are not practising online must stop working until further notice..
UPDATE: Wales to enter alert level four (very high risk) (updated 17 December)
The First Minister announced on 16 December that rapidly accelerating coronavirus rates mean that Wales has met the criteria in the new traffic light Coronavirus Control Plan to move to alert level 4 (very high risk). Close contact services must close at the end of trading on 24 December. All CNHC Registrants in Wales providing close contact services (i.e. practising 'hands-on' where social distancing is not possible) can not practise after this date until further notice. Find out more here.
New Coronavirus control plan published (updated 14 December 2020)
On Monday 14 December the Welsh Government published its updated Coronavirus control plan. The revised plan puts in place four alert levels. It also sets out how and when Wales will move between these alert levels. You can read the First Mininster's announcement here.
On Friday 11 December the First Minister said that if the strengthened national measures, together with the efforts everyone is making, do not succeed in reducing the rates of coronavirus, Wales will need to move to alert level four after the five-day Christmas period. Alert level four (very high risk) restrictions are equivalent to a lockdown and would mean close contact services would have to close. But this move is not a foregone conclusion. (as stated in a press release from the Welsh Government dated 11 December.
New national restrictions replace firebreak measures (updated 9 November2020)
The fire-break measures introduced on 23 October 2020 ended on Monday 9 November 2020. It has been replaced by new national restrictions. CNHC Registrants providing close-contact services (i.e. working 'hands-on' where social distancing is not possible) can return to work under these new restrictions.
1.1. Before any steps are made to return to face to face and close contact work, check with your insurance company that you will be covered under your professional indemnity insurance.
1.2. Most insurance companies have provided cover during remote working but may have quite different requirements for face to face and close contact work, due to the increased risks involved.
2.1. Before reopening it will be important to carry out a risk assessment of both the premises and treatment areas, as well as your way of working:
- England: The UK Government has prepared guidance on how to work safely during the coronavirus outbreak, Working safely during the coronavirus outbreak; a short guide. You can also find an online checklist Reopen your business safely during coronavirus (COVID-19).
- Wales: See Keep Wales Safe at Work guidance.
- Northern Ireland: See the section on “Working Safely” in Coronavirus updates: Support for your business
- Scotland: See Returning to work safely guidance
2.2. Key actions to take when assessing risks:
- Identify what work activity or situations might cause transmission of the virus.
- Think about who could be at risk.
- Decide how likely it is that someone could be exposed.
- Act to remove the activity or situation, or if this is not possible, control the risk.
2.3. See Health and Safety Executive (HSE) guidance on carrying out a risk assessment, Managing risks and risk assessment at work.
2.4. The HSE has identified the need to manage Legionella risks if the building to which you will be returning has been empty or unoccupied during the Covid-19 outbreak. See Legionella risks during the coronavirus outbreak.
3.1. The UK Government and the devolved nations have made clear that social distancing will continue for the foreseeable future.
3.2. When planning to reopen your clinic or premises, check how you can maintain the required social distancing between yourself or staff and clients, between clients and between staff.
3.3. Physical areas to consider are:
- the entrance to your premises
- waiting areas
- treatment rooms
- toilet facilities.
3.4. The UK Government suggests you consider how to:
- physically arrange work areas to keep people 2 metres apart (or where this is not possible having additional protective measures in place to manage the transmission risk)
- mark areas using floor paint or tape to help people keep a 2 metre distance
- provide signage to remind people to keep a 2 metre distance
- use screens to introduce a physical barrier, for example at reception desks or payment areas
- prepare to ensure your clinic or treatment area is well ventilated – do not use air conditioning systems or convector heaters that recirculate air.
4.1. Plan your treatment schedule to allow 30 minutes between clients, so that clients can leave without meeting other clients and to allow time for disinfecting and cleaning between sessions (see section D below). Do not allow appointments to over run if they will not allow for the 30 minute gap been appointments.
5.1. For close contact services treatment times should be kept to a minimum. They should not exceed an hour.
5.2. For face to face therapies and close contact services provided for clients who fall into high and medium risk categories, consider the shortest time that the treatment can be effectively delivered in.
6.1. You may wish to check each client’s temperature before treatment using a no-touch thermometer.
6.2. If so, ensure you have a supply of no-touch thermometers available.
7.1. Before re-opening you will need to check, if necessary, that the water supply does not carry any Legionella risks (see section A.2.4), then carry out a deep clean of your premises. This means a full clean including disinfecting all hard surfaces such as doorbells, door handles, bannisters, taps, reception desks, computer keyboard and mouse, telephones, toilet and hand washing facilities.
7.3. Ensure you have an adequate supply of cleaning products in stock.
7.4. Ensure you have an adequate supply of couch roll for use on non-wipeable chairs and couches in waiting and treatment areas for use for each client.
7.5. Towels, couch covers, blankets, pillowcases and any other soft item should only be used once per client. This may represent a change in practice if you have previously used couch roll on top of a soft cover. Ensure you have a sufficient supply of washable items for each client or use disposable couch roll and covers. At no time should a client be allowed to bring their own sheets, towels, blankets or pillows.
7.6. Ensure you have a covered laundry bin to collect any used washable items following each client's treatment. Ideally this should be a foot pedal bin.
7.7. Ensure you have disposable gloves to handle used items and waste at the end of each day.
7.8. Ensure you have laundry facilities to be able to wash any items at 60 degrees.
7.9. Check with the local authority in your area about waste disposal requirements of e.g. couch rolls, disinfectant wipes and other used items.
7.10. For close contact services where clients remove their clothing, ensure you have a lidded container where clients can place their clothing and belongings during treatment, where appropriate. Ideally use a foot pedal bin.
8.1. Ensure both yourself and clients have access to hand washing or hand sanitising facilities.
8.2. Ensure you have an adequate supply of hand washing or hand sanitising products in stock.
8.3. If you use hand sanitising gel or wipes, they should have an alcohol content of 70 per cent.
8.4. Hands should be washed for a minimum of 20 seconds. Guidance on the correct way to wash hands can be found on the NHS website.
9.1. Prepare signage for your clinic and treatment areas to remind clients to wash or to sanitise their hands and to keep a 2 metre distance from others.
10.1. To reduce the risk of transmission from touch, remove from waiting rooms and treatment areas all non-essential items such as:
- water dispensers (ask clients to bring their own water)
- any other items which clients may touch.
11.1. Put facilities in place to ensure clients can pay by contactless or online payment.
11.2. Card machines should be sanitised between clients.
11.3. If clients can only pay by cash, have single-use envelopes available where clients can place their cash following treatment. Use one envelope per client. Do not touch these until the end of the day. Wash hands thoroughly after handling the envelopes and cash. Dispose of the envelopes safely.
12.1. If you see clients in their own homes, check that your insurance will cover you for this.
12.2. Think carefully about how you will manage hygiene and social distancing in an environment that is not your own, particularly if other people live with the client. You may wish to use additional PPE (see section A.14).
12.3. Communicate to the client before the appointment the steps that will have to be taken to manage hygiene and maintain social distancing.
12.4. Consider who else lives with the client, and if they fall into the high or moderate risk categories.
12.5. Check in advance of the appointment and before you enter the client’s home if anyone in their household or bubble has symptoms of coronavirus or are self-isolating.
13.1. Check your cancellation policies and update if necessary, to allow for greater flexibility and sensitivity if you or your clients have to cancel an appointment at short notice due to COVID-19 infection. A cancellation charge for a client cancelling because they, or a member of their household, have COVID-19 symptoms would be inappropriate.
13.2. Seek advice from your insurance company about any disclaimers you may need to use for yourself and your clients regarding risks of COVID-19 infection.
14.1. Personal Protective Equipment (PPE) includes items such as disposable gloves, disposable masks and items of clothing such as disposable gowns and aprons.
14.2. If you work face to face, then Government advice is that social distancing and hygiene are the ways to manage the risk of infection from COVID-19.
14.3. If you work face to face and are not providing a close contact service, you may choose to take the additional precautionary measure of wearing a face mask or face covering and asking your client to wear a face covering as well, particularly if the client's is in a high or medium risk category or if the treatment is being delivered in the Registrant's or client's home. Face coverings are not classified as PPE - see Face coverings: when to wear one and how to make your own.
England: While facecoverings are not mandatory in this setting, Goverment guidance on wearing face coverings states:"You should also wear a face covering in indoor places not listed here where social distancing may be difficult and where you will come into contact with people you do not normally meet".
Northern Ireland: Guidance states that it is not mandatory to wear a face covering in a business that is able to maintain social distancing by using a system of ticketing or appointments.
Scotland:: It is not mandatory to wear a facemask where physical disctancing can be maintained at all times. However, guidance advises: "You are also advised to wear a face covering in other indoor places and where physical distancing is difficult and where there is a risk of being within 2 metres of people who are not members of your household."
Wales: While not mandtory to wear a facemask where physical disctancing can be maintained at all times, guidance states that they should be worn in "public areas within buildings that are otherwise closed to the public – for example a reception area of an office building".
[updated 26 Npvemenber 2020]
14.4. If you work face to face and are asking clients to wear a face covering, contact them before their appointment to ascertain if they are exempt from wearing a face covering. Exemptions may vary in each country in the UK so check the relvant government guidance for the country you live in. [Updated 26 November 2020]
14.5. If you work in a close contact service, you should refer to guidance for close contact services from the government of the country you practise in. Some recent updates and general guidance include the following:
England: From 24 September, it is mandatory in law for people providing a close contact service to wear a clear visor/goggles and Type II Face Mask. If wearing goggles these must be close-fitting with no visible gaps where droplets could enter the eye. Goggles and visors should be cleaned between clients according to manufacturer’s instructions. A Type II Face Mask is a medical-grade 3-ply face mask. Further details can be found here. [updated 26 Npvemenber 2020]
Northern Ireland: Guidance states that practitioners of close contact services must wear a clear visor or goggles, in addition to a Type II face mask. If wearing in place of a visor, goggles "must be close fitting with no obvious openings or vents that would otherwise allow droplets to enter the eyes".
Scotland: The Scottish Government’s checklist for close contact services states that ‘Staff should wear a visor in addition to a face covering. Visors are recommended but face masks are mandatory. Your clients must wear face coverings. No treatment should be performed that requires the face covering to be removed. See the additinal guidance issued by the Scottish Government here.
Wales: The Welsh Government’s guidance also requires practitioners of close contact services to wear a clear visor and Type II Face Mask. [Updated 26 November 2020]
14.6. You may wish to exercise your professional judgement to put additional precautionary measures in place to reduce the risk of virus transmission by wearing items of PPE such as disposable gloves, gowns, and aprons. If this is the case, CNHC suggest Registrants should refer to Public Health England’s advice on the use of PPE in primary care settings which includes the correct order for putting on (donning) and removing (doffing) PPE.
14.7. It is for each Registrant to decide what additional type of PPE is appropriate, in accordance Public Health England (PHE) guidance. This will depend on the discipline you are practising, the specific treatment being delivered, and where the treatment is carried out. Questions to consider are:
- Is the treatment being delivered in the Registrant’s or client’s home? Additional PPE might be advisable in these settings.
- Whether the PPE is for single or sessional use? Gloves and aprons should always be single use only.
14.8 Face coverings for clients: In England and Northern Ireland: It is mandatory for clients attending ‘premises providing personal care and beauty treatments’, which includes massage and similar close contact services, to wear a face covering. These face coverings should be worn before entry to the premises and ‘should not be removed unless essential for a particular treatment, for example for a treatment on the face area covered by the mask’. See the guidance here.
In Scotland The Scottish Government’s checklist for salons and close contact services states that ‘customers must wear a face covering’
The Welsh Government does not require clients to wear face coverings but ‘supports the right of the owners of nail, beauty and holistic and wellbeing salons, specialist or aesthetics salons or clinics and destination, hospitality, leisure or day spa businesses to decide whether they wish to ask their clients/guests to wear face coverings whilst on their premises. See the guidance here.
Some people are at higher risk of severe illness from COVID-19. They have been categorised as ‘clinically extremely vulnerable’. For more information, see guidance from the NHS Who’s at higher risk from Coronavirus.
Below we set out what you need to do before you see clients. This includes:
- Identifying any clients who are at increased risk of infection.
- Screening for COVID-19 symptoms.
- Clarifying when not to treat.
You may wish to use a checklist based on the areas outlined below.
1.1. Check if any clients are in the high risk (clinically extremely vulnerable) category which means they will have been contacted by the NHS and have been shielding. Clients in this category have been identified as being at extremely high clinical risk of infection and must avoid face to face contact with anyone outside their household for at least 12 weeks following any period of lockdown.
They include those who:
- have had an organ transplant
- are having chemotherapy or antibody treatment for cancer, including immunotherapy
- are having an intense course of radiotherapy (radical radiotherapy) for lung cancer
- are having targeted cancer treatments that can affect the immune system
- have blood or bone marrow cancer (such as leukaemia, lymphoma or myeloma)
- have had a bone marrow or stem cell transplant in the past six months or are still taking immunosuppressant medicine
- have been told by a doctor that they have a severe lung condition such as cystic fibrosis, severe asthma, or severe Chronic Obstructive Pulmonary Disease (COPD)
- have a condition that means they have a very high risk of getting infections such as Severe Combined Immunodeficiency (SCID) or sickle cell
- are taking medicine that makes them much more likely to get infections (such as high doses of steroids)
- have a serious heart condition and are pregnant.
1.2. Always seek advice from your professional indemnity insurance company about the risks associated with treating clients in the high risk category before proceeding.
1.3. You cannot see clients in the high risk category until the government in the country you practise in pauses shielding.
- England: Shielding has been paused from 1 August
- Northern Ireland: Shielding has been paused from 31 July
- Scotland: Shielding has been paused from 1 August
- Wales: Shielding paused from 16 August.
Where shielding has been paused it will be kept under close review by the relevant government and may change. Local outbreaks of COVID-19 may also lead to a change of measures so it is important to keep up to date with current guidance.
1.4. Even if shielding is paused, clients in this category will still be at risk of severe illness if they contract coronavirus. You must very carefully assess whether the potential benefits of treatment outweigh the risks, particularly if close contact services are being provided. As part of this assessment:
- Consider delivering the treatment remotely if that is possible.
- Clients should be encouraged to seek the advice of their GP, midwife or hospital consultant on whether they should proceed with the treatment. [UPDATED 24 August 2020}
- If the client tells you that their GP, midwife or hospital consultant has not identified any reason why they should not proceed with treatment, document this in the client’s notes and ask the client to sign and date this.[UPDATED 24 August 2020}
1.5. If you decide to proceed, take extra care with social distancing and hygiene measures.
1.6. Keep treatment times to a minimum. Consider the shortest possible time in which you can deliver the treatment effectively. Do not exceed an hour and do not book two appointments for different types of treatments back to back.
1.7. Remember that your safety and the safety of the client are paramount. Trust in your professional judgement and do not feel pressured to see a client if you feel this will put them or yourself at risk.
2.1. Check if any clients are in the ‘moderate risk’ groups which include those who are:
- 70 or older
- Pregnant. Pregnant women from 28 weeks are at higher risk of becoming seriously unwell if infected with COVID-19 and are advised to take particular care with social distancing. See RCOG guidance Coronavirus infection and pregnancy.
- have a lung condition that's not severe (such as asthma, COPD, emphysema or bronchitis)
- have heart disease (such as heart failure)
- have diabetes
- have chronic kidney disease
- have liver disease (such as hepatitis)
- have a condition affecting the brain or nerves (such as Parkinson's disease, motor neurone disease, multiple sclerosis or cerebral palsy)
- have a condition that means they have a high risk of getting infections
- are taking medicine that can affect the immune system (such as low doses of steroids)
- are very obese (a BMI of 40 or above).
2.2. People in the moderate risk group are advised to stay at home and social distance but they are not required to shield. For more information, see guidance from the NHS Who’s at higher risk from Coronavirus.
2.3. Always seek advice from your professional indemnity insurance company about the risks associated with treating clients in the moderate risk category before proceeding.
2.4. If a client is in the moderate risk group:
- For face to face therapies:
- As part of your risk assessment, use your professional judgement to decide if the potential benefits of treatment outweigh the risk. [UPDATED 24 August 2020]
- If you do proceed with treatment, take extra care with social distancing and hygiene measures.
- For close contact services:
- As part of your risk assessment, you must carefully assess whether the potential benefits of treatment outweigh the risks. [UPDATED 24 August 2020]
- Clients should be encouraged to seek the advice of their GP, midwife or hospital consultant on whether they should proceed with the treatment. [UPDATED 24 August 2020]
- If the client tells you that their GP, midwife or hospital consultant has not identified any reason why they should not proceed with treatment, document this in the client’s notes and ask the client to sign and date this.[UPDATED 24 August 2020]
- If you do proceed with treatment, take extra care with social distancing before and after the treatment and with hygiene measures..[UPDATED 24 August 2020]
2.6. Keep treatment times to a minimum. Do not exceed an hour and do not book two appointments for different types of treatments back to back for the same client.
3.1. At the time of writing the NHS guidance for symptoms to look out for are as follows:
- High temperature
- Persistent cough
- Loss or change to your sense of smell or taste.
This guidance may be updated so check the advice on symptoms on the NHS website on a regular basis.
3.2. You: Check daily if you are experiencing any COVID-19 symptoms. This could include taking your temperature each day.
If you become aware of any COVID-19 symptoms you should immediately cancel any booked appointments and follow government guidance about self-isolation.
3.3. Your household and support bubble: Check daily if anyone in your household or support bubble is experiencing any COVID-19 symptoms, which could include temperature checks.
If anyone in your household or support bubble experiences COVID-19 symptoms you must cancel all appointments and put yourself in quarantine for 14 days, as per government advice.
3.4. Your clients: Check with clients 24 hours in advance of any appointment if they or anyone in their household or support bubble is experiencing any COVID-19 symptoms.
If a client or anyone in their household or support bubble is experiencing symptoms they must not attend the session, They must follow government guidance and self-isolate for a minimum of 10 days if it is them, or 14 days if it is a member of their household.
3.5. Check NHS advice about COVID-19 symptoms and what to do.
4.1. To summarise, do not treat clients if:
- you or any member of your household or support bubble have any COVID-19 symptoms
- a client has COVID-19 symptoms
- a client is self-isolating or in quarantine
- a member of a client’s household or support bubble or anyone the client has been in contact with in the last 14 days has COVID-19 symptoms
- a client is in the high risk group and is shielding.
Think carefully and carry out a risk assessment for clients in the high and moderate risk groups. For close contact services ask them to obtain the advice of their GP, midwife or hospital consultant.
1.1. In advance of re-opening, communicate with clients to explain the new working arrangements.
1.2. Request that clients attend on their own to reduce the risk of additional contacts between people.
1.3. Ask clients to wait outside your premises until the appointment time.
1.4. Ask client to bring their own pen if relevant.
1.5. Ask client to bring their own water to drink. Do not provide plastic cups.
1.6. Request clients pay using a contactless card or via payment online. Only accept cash payment as a last resort.
2.1. Aim to carry out all pre-treatment consultations online or by telephone wherever possible to reduce the length of face to face contact.
1.1. Open the door yourself wherever possible.
1.2. DO NOT shake hands or hug the client.
1.3. Ask clients to wash or sanitise hands on entry to premises.
1.4. Maintain a minimum of 2 metres at all times (for face to face treatments).
1.5. Show the client the social distancing arrangements.
1.6. Ensure couch roll is placed on any non-wipeable seats and couches used by client.
1.7. Only use your own pen.
1.8. If a client needs to write, they must use their own pen or you can supply a pen which you should sanitise after use. [UPDATED: 10 September 2020]
1.9. Take client’s temperatures using a no touch thermometer. Record temperatures in client notes.
1.10. If a client shows signs of a fever or high temperature, do not treat the client. They must return home and may need to self-isolate. Suggest they call 111 for advice.
1.11. If a client has COVID-19, you may then need to self-isolate. Again, call 111 for advice.
1.12. If a client says they have had and recovered from COVID-19 it is advisable to gain a letter from their GP or hospital consultant to say it is ok for them to receive treatment. If the client says they have this permission, document it in your notes and request that the client signs and dates this.
2.1. Keep your premises well-ventilated, with windows open in your treatment room wherever possible, or use an extractor fan. Do not use air conditioning or a convector heater that recirculates air.
2.2. Remain a minimum of 2 metres from the client for face to face therapies.
2.3. Take additional precautions when seeing clients for close contact services. This may include the wearing of masks, visors and gloves to provide hands-on therapy. See section A. 14.5 for updates related to requirements to wear visors and or masks and check the guidance for close contact services from the government of the country you practise in. [Updated 26 November 2020]
2.4. For close contact services you may need to adapt client position if the client is wearing a mask. For example, clients may be more comfortable lying on their side rather than on their back.
2.5. Make sure you sanitise any reusable tools or implements after each appointment.
3.1. Amend your aftercare advice sheets to include information on what clients should do if they feel unwell with any COVID-19 symptoms and any hygiene protocols you have introduced into your practice. These should be to be emailed to your client.
1.1. Ask client to pay by contactless method using contactless cash machine or online payment.
1.2. If client can only pay by cash, show the client the envelope for cash payments. Use one envelope per client. Do not touch these until the end of the day. Dispose of the envelopes safely. Wash your hands thoroughly afterwards.
1.1. Wash hands thoroughly in hot water and soap for a minimum of 20 seconds. Guidance on the correct way to wash hands can be found on the NHS website - How to wash your hands.
1.2. For close contact services, hand hygiene should extend to include washing of exposed forearms.
1.2. Sterilise the container where clients have placed their clothing between clients, including any handles and any areas touched by the client.
1.3. Dispose safely in a bin with a lid all couch roll, disinfectant wipes and any other items used by or for the client. You may wish to use disposable gloves to do this. Wash your hands thoroughly for a minimum of 20 seconds afterwards.
1.4. Disinfect any surface(s) touched by a client – this might include couch, chairs, door handles, consultation table, toilet area, handwashing area.
1.5. Open doors and windows to ventilate the treatment and waiting areas.
1.6. Replace couch roll on chairs and treatment couches in readiness for the next client.
1.7. Keep doors to areas not used by client closed.
1.8. Change and dispose of Type II mask, disposable visor and PPE if being worn. Clean and disinfect reusable visor if being worn.
1.1. Place all waste in sealable plastic bags and follow local waste disposal advice.
1.2. If a uniform is worn, place in a sealable plastic bag for laundering before leaving. Dispose of the bag afterwards.
1.3. Wash all uniforms, towels, coverings on a 60°C washing machine cycle.
1.4. Open doors and windows to ventilate the areas used by clients.
You are advised to keep up to date with the government guidance on testing and contact tracing in the country you practise in.
1.1. See UK Government advice NHS Test and Trace: how it works and Maintaining records of staff, customers and visitors to support NHS Test and Trace.
1.2. You may be required to pass on client details to the NHS Test and Trace service.
1.3. Inform clients that you may need to pass on their details if required. You can either explain this to each client or have a notice up in your practice to say that you may be required to pass on contact details. Client consent is not required for their details to be used in this way
1.4. Although compliance with the NHS Test and Trace service is voluntary, please encourage customers and visitors to share their details in order to support NHS Test and Trace and advise them that this information will only be used where necessary to help stop the spread of COVID-19.
1.5. If a client informs you that they do not want their details shared for the purposes of NHS Test and Trace, they can choose to opt out, and if they do so you should not share their information used for booking purposes with NHS Test and Trace.
1.6. The NHS COVID-19 Test and Trace app launched on 24 September 2020. The app has a feature that allows users who have the app to ‘check in’ to your premises by scanning an NHS QR code if they wish to. CNHC Registrants in England who provide close contact treatments must register for an official NHS QR code and display the official NHS QR poster from 24 September. The QR code and poster can be generated here. If you need techical support with the QR code and poster or have specific queries about using it, call the NHS QR Code support line on 0800 540 4900.
This requirement DOES applies to mobile therapists: You need to provide your business address as the venue address when registering for the code. See NHS COVID-19 app FAQS here.
The Government in England also encourages those who provide services indoors which are not close contact services to display an official NHS QR code.
Once a client has scanned the QR code, it is no longer necessary to include them on a customer log. For clients who do not have the app you will need to continue to collect and retain contact details for 21 days from the date of the most recent visit.
You can find out more details on maintaining records here and also see Which venues in England should display the official NHS QR code poster? [UPDATED 30 September and 26 November 2020]
2.1. See NIDirect guidance - Coronavirus (COVID-19): testing and contact tracing.
Northern Ireland has developed a StopCOVID NI Proximity App. Users of the app will be notified anonymously via Bluetooth if they have been in close proximity to someone who has tested positive for coronavirus and told to self-isolate.The app does not yet directly link to the contact tracing system. If someone tests positive, manual contact tracing will take place by telephone. This app is designed to act in parallel to contact tracing to reach people who might not otherwise know they had been close to someone with the virus. You can see full details of this app here.: (UPDATED 26 November 2020]
3.1. See the Scottish Government's guidance Coronavirus (COVID-19): Test and Protect.
The Scottish Government has launched a Protect Scotland app. Users of the app will be notified anonymously via Bluetooth if they have been in close proximity to someone with coronavirus and told to self-isolate. If someone tests positive for coronavirus in Scotland manual contact tracing will take place by telephone. This app is designed to work in parallel to the manual test and trace system to reach people who might not otherwise have been contacted by manual contact tracing. You can see full details of this app here.
4.1. See the Welsh Government's guidance -Test Trace Protect.
4.2. The NHS COVID-19 Test and Trace app launched on 24 September 2020. The app has a feature that allows users who have the app to ‘check in’ to your premises by scanning an NHS QR code if they wish to. CNHC Registrants in Wales who provide close contact treatments are strongly encouraged to download the official NHS QR code and display the official NHS QR poster from 24 September. The QR code and poster can be generated here. A Welsh language version can be generated here. If you need techical support with the QR code and poster or have specific queries about using it, call the NHS QR Code support line on 0800 540 4900.
NOTE: The Government have now confirmed this requirement DOES applies to mobile therapists: [UPDATED: 28 September2020]
If you do not download and use the NHS QR app, you must continue to collect the contact details of your clients and retain them for 21 days from the date of each visit. For further details visit. See keeping-records-staff-customers-and-visitors-test-trace-protect
If you have any questions, please do not hesitate to contact us at:
Tel: 020 3668 0406