18th January 2021 | Coronavirus

Information last updated 18 January 2021. Latest updates shown in red text.

ENGLAND

UPDATE: National lockdown approved by Parliament (updated 6, 11 and 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 Hanuary 2021)
  • You must be able to evidence that your therapeutic intervention is supporting your client with their condition. You must 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 2021)

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. (pdated 18 Juauray 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 info@cnhc.org.uk 

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.

You can find out if you are in Tier 4 by using the postocode checker. Guidance for tier 4 can be found here

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 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. 

You can find out if you are in Tier 4 by using the postocode checker. Guidance for tier 4 can be found here

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 Wednesday 2 December (updated 26 November and 1 December 2020) 

The Prime Minister announced on 23 November a return to a 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 what you can and can't do in each local restriction tierscan 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 Decemner (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).

Mobile working
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.

Face to face therapies
From 4 July 2020 the following restrictions have been eased:

  • The 2-metre social distancing rule has been relaxed to "1 metre plus" where 2 metres is not possible – but people will be encouraged to have mitigation in place to reduce risk of virus transmission.
  • Hair salons and barbers can reopen, but visors must be worn.

Registrants who can maintain social distancing of 2 metres, and who have full infection control measures in place, may return to work if that would be covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

'Hands-on' therapies (also known as close contact services)
From 13 July 2020 Registrants can return to practising 'hands-on' provided that they:

  • Do not treat highest risk zones. This is defined in UK Government guidance 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”. 
  • Have full infection control measures in place.
  • Have confirmation that they are covered by their professional indemnity insurance.

The UK Government guidance for close contact services can be found here.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

UPDATE: Highest risk zones - on 13 August the UK Government announced that treatments to the face can resume on 15 August 2020.  (updated 12 August 2020)
UPDATEThe NHS COVID-19 Test and Trace app launched on 24 September 2020 for England and Wales. A NHS QR code and official NHS poster are available. CNHC Registrants in England providing close contact treatments (i.e. practising 'hands-on') including mobile therapists MUST register for a QR code and display the poster from 24 September. Find out more here.


NORTHERN IRELAND

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.
UPDATE: 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.

UPDATE: 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).
UPDATE: COVID-19 circuit-breaker measures announced (updated 16 October 2020)
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 at 6pm 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 Ireland must stop working from 6pm on 16 October for the next 4 weeks.

A summary of the new restrictions can be found here

Face to face therapies
From 6 July 2020 Registrants who have practices in Northern Ireland can return to work provided:

  • They can maintain social distancing of 2 metres.
  • Have full infection control measures in place.
  • Have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local lockdown restrictions you cannot return to work yet.

Guidance for working safely in Northern Ireland can be found here

'Hands-on' therapies (also known as close contact services)
From 6 July 2020 Registrants who have practices in Northern Ireland can return to work provided they have full infection control measures in place and have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

Guidance for working safely in Northern Ireland can be found here


SCOTLAND

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 

  • Orkney
  • Shetland
  • Na h-Eileanan Siar (Western Isles)
  • The following islands within Argyll and Bute: Coll, Colonsay, Erraid, Gometra, Iona, Islay, Jura, Mull, Oronsay, Tiree, and Ulva
  • All 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 to carefully 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
These are:

  • Inverclyde
  • Falkirk
  • Angus.

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
These are:

  • 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.

UPDATE: 5 tier system of local protection levels introduced (updated 18 November and 26 November 2020)
A new system of local protection levels has been introduced from 2 November 2020:
Levels 0 and 1You can provide close contact services (i.e. 'hands-on' therapies where social distancing is not possible) including mobile services.
Levels 2 and 3You 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 November the First Minister, Nicola Sturgeon, has announced that 11 council areas will go into the highest tiel 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 levels 0-3 cannot travel to work in tier 4. However, Registrants can travel from their home in tier 4 to work in a level 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.

Guidance
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. [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.

Face to face therapies
From 15 July 2020 Registrants who have practices in Scotland can return to work provided:

  • They can maintain social distancing of 2 metres.
  • Have full infection control measures in place.
  • Have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

'Hands-on' therapies (also known as close contact services)

From 22 July 2020 Registrants who have practices in Scotland can return to work provided they have full infection control measures in place and have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

The Scottish Government's guidance on close contact services can be found here.

This guidance diverges from UK Government guidance for close contact services are as follows:
- No mobile services: Treatments can only be carried out at your own premises. You cannot provide close contact treatments in client's homes in Phase 3 of of the Scottish Government's Route Map
- High risk zones: 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 in phase 3 of the Scottish Government’s Route Map


WALES

UPDATE: Level 4 restrictions brought forward - all cNHC Registrants to stop working until further notice (updated 21 December 2020)
On 19 December the First Minister
announced that the new more easily transmissable variant of COVID-19 is present throughout Wales. The Welsh government made the decision 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 reviwing the restrictions, CNHC have concluded that all CNHC Registrants in Wales who are not practising online must stop working until further notice.
UPDATE: Wales enters alert level four (very high risk) - close contact services to close after end of trading on Christmas Eve (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.
UPDATE: New Coronavirus control plan published (updated 14 December 2020)
On Monday 14 December the Welsh Government published its updated Coronavirus control planThe 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. 
UPDATE: Coronavirus fire-break in Wales has ended (updated 9 November 2020)
The fire-break imeasures introduced on 23 October 2020 ended on Monday 9 November 2020. They have 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. 

Face to face therapies
From 13 July 2020 Registrants who have practices in Wales can return to work provided:

  • They can maintain social distancing of 2 metres
  • Have full infection control measures in place,
  • Have confirmation that they are covered by their professional indemnity insurance.

Exception: If your practice is based in an area subject to local restrictions you may not be able to return to work yet.

The Welsh Government's guidance on working safely can be found here

'Hands-on' therapies (also known as close contact services)

From 27 July 2020 Registrants who have practices in Wales can return to work provided that they have full infection control measures in place and have confirmation that they are covered by their professional indemnity insurance. 

Exception: If your practice is based in an area subject to local restrictions you cannot return to work yet. 

The Welsh Government's workplace guidance for close contact holistic services can be found here. It includes a restart risk assessment and a reopening checklist.

This guidance diverges from UK Government guidance for close contact services in relation to high risk zones. It states:
"practitioners are currently strongly advised not to perform treatments that will bring them within the ‘highest risk zone’ of clients (defined as the area in front of the face where splashes and droplets from the nose and mouth, that may not be visible, can be present and pose a hazard from the client to the practitioner and vice versa)".


CNHC ADVICE

CNHC advice on preparing to return to work and working safely can be found here


CONTACT US

If you have any questions or queries, please don't hesitate to contact us at info@cnhc.org.uk