Why are GP practices suddenly pulling HCAs out of flu clinics — and do they actually need to?

Over recent weeks, something approaching panic has spread across general practice.

Messages are circulating suggesting that Healthcare Assistants (HCAs) and Healthcare Support Workers (HCSWs) can no longer give flu vaccinations. Some practices have reportedly responded by removing HCAs from vaccination clinics altogether.

Given how heavily primary care relies on HCAs to deliver seasonal vaccination programmes, that understandably raises some fairly significant operational questions.

But the headline is much simpler: HCAs have not been banned from administering flu vaccines.

What has become much clearer is the distinction between: clinical assessment and informed consent and the physical administration of the vaccine.

Understanding that distinction and the different legal mechanisms available is the key to designing a compliant flu clinic for 2026/27.

So what has actually changed?

Until 1 April 2026, influenza vaccination could be delivered using the National Protocol framework introduced during the pandemic.

The legislation allowing National Protocols expired on 1 April 2026.

From April 2026, the Human Medicines Regulations introduced a new mechanism called a Vaccine Group Direction (VGD).

Importantly, UKHSA says the VGD is not simply a direct replacement for the National Protocol. It is a separate and permanent legal framework capable of supporting NHS vaccination programmes more broadly.

For the 2026/27 influenza programme, UKHSA has published both a national PGD and VGD, with the influenza VGD valid from 1 September 2026 to 31 March 2027.

And this is where some of the confusion starts…..

Under a VGD, HCAs can still vaccinate

The VGD allows different stages of the vaccination pathway to be undertaken by different members of the team.

However, the important restriction is that the clinical assessment of the patient and obtaining informed consent must be undertaken by one of the registered healthcare professionals specified within the VGD.

Once that has happened, tasks including: vaccine preparation administration record keeping

can, where permitted by the VGD, be delegated to another appropriately trained and competent practitioner, including non-registered healthcare staff.

UKHSA specifically describes the VGD as allowing the remainder of the vaccination process, following patient consent, to be delegated to suitably trained individuals.

Where tasks are delegated under the VGD, they must also be appropriately supervised by the healthcare professional who undertook the consent process.

So: Registered HCP assesses + obtains informed consent → trained HCA administers is perfectly possible.

What is not permissible is: HCA independently assesses + obtains informed consent + administers.

But practices don’t have to use a VGD

This is probably the most important part of the discussion.

A practice can also administer vaccines using a Patient Specific Direction (PSD).

A PSD is a written or electronic instruction from a prescriber for a medicine to be administered to a named individual, following an individual clinical assessment.

And SPS specifically gives the example of a prescriber authorising a list of individually named patients attending a pre-booked seasonal influenza clinic, provided every patient on that list has been individually assessed.

Non-registered healthcare workers can administer prescription-only medicines, including vaccines, where an appropriate PSD is in place.

The BMA/GPC England guidance is also explicit that HCAs can administer vaccines under a PSD provided they are appropriately trained, competent and supervised.

The really important issue: consent

This is where much of the current anxiety appears to originate.

UKHSA’s national vaccination training standards make clear that it is outside the scope of an HCA/HCSW to undertake: clinical assessment for vaccination informed consent or work under a PGD.

The BMA says UKHSA has described this as a clarification rather than a change in policy, while acknowledging that this clarification may differ from how some practices historically interpreted HCA vaccination roles.

That distinction matters.

An HCA can seek the patient’s agreement to physically proceed with an injection.

They cannot independently undertake the preceding clinical process that constitutes informed consent to vaccination.

First flu vaccination versus repeat seasonal vaccination

There is another important distinction which has arguably received much less attention.

First-time flu vaccination

Where a patient becomes eligible for influenza vaccination for the first time and the vaccine is being prescribed under a PSD, the prescriber is responsible for the clinical assessment and informed-consent process.

But crucially, this does not necessarily have to happen in the vaccination room immediately before the injection.

BMA guidance states that the clinical assessment/consent stage and subsequent vaccine administration do not need to occur contemporaneously or in the same location, provided the consent has been appropriately obtained and documented before administration.

Londonwide LMCs goes further in its 2026/27 guidance and specifically says this process could be undertaken through mechanisms including:

direct discussion, Accurx, email or letter, provided appropriate information about the risks and benefits of vaccination is supplied.

That opens up some very practical possibilities for GP practices.

Repeat annual flu vaccinations

Perhaps even more significantly, UKHSA guidance recognises consent as an ongoing process.

For seasonal influenza vaccination under a PSD, where a patient has previously received a flu vaccine, the prescriber does not necessarily have to repeat the full informed-consent process every season.

This applies where:

• the vaccine is of the same formulation, other than the normal seasonal antigen changes;
• the risks and benefits for that individual remain unchanged; and
• there has been no relevant change in their circumstances.

The HCA can then check that the patient remains happy to proceed and that there have been no new clinical concerns.

Anything new; an allergy, illness, change in medical circumstances, questions about risks or benefits, or another concern – should be referred back to a registered healthcare professional.

That is very different from saying: “HCAs can no longer run flu clinics.”

Could digital pre-screening solve much of this?

Potentially, yes.

A practice could design a pathway along the following lines:

Patient invited → digital screening/consent information → prescriber reviews patient and authorises PSD → patient attends → HCA checks nothing has changed → HCA administers vaccine

For patients receiving their first flu vaccination, the digital pathway could support the registered clinician’s assessment and consent process before the clinic.

For established flu patients, the previous consent and current clinical circumstances can be reviewed as part of the PSD process, with the HCA confirming at attendance that the patient remains happy to proceed and that nothing material has changed.

The important point is that a questionnaire cannot itself clinically assess or prescribe.

There must still be an appropriate registered clinician making the relevant clinical decision, and patients must have a meaningful opportunity to receive information and raise questions.

But there is no requirement that every element of that process happens face-to-face immediately before the needle goes into the arm.

What should practices do?

The answer probably isn’t to immediately remove HCAs from flu vaccination.

Instead, practices should examine how their existing HCA vaccination pathway actually works.

If the process has historically been: “HCA calls patient in, assesses them, obtains informed consent and vaccinates” then it needs reviewing.

But if the practice has a properly governed PSD pathway or chooses to use the new VGD, HCAs can continue to play an important role in delivering influenza vaccination.

Practices should therefore ensure that:

• the legal mechanism for administration is clear — PSD, PGD or VGD;
• HCAs are not undertaking clinical assessment or obtaining informed consent;
• PSDs genuinely follow individual patient assessment;
• previous consent and any subsequent changes are appropriately checked;
• HCA training and competency are current and documented;
• there is a clear escalation route to a registered healthcare professional;
• consent, prescribing and administration are appropriately recorded.

The bottom line

HCAs can still administer flu vaccines in England in 2026/27.

What they cannot do is independently undertake the clinical assessment and informed-consent process.

For practices using HCAs, there are now two particularly relevant routes:

VGD: a registered healthcare professional assesses the patient and obtains informed consent, after which appropriate vaccination tasks can be delegated to trained staff.

PSD: an appropriate prescriber assesses and authorises vaccination for the named patient, after which a trained HCA can administer it.

And for repeat seasonal influenza vaccination, the national guidance recognises that full informed consent does not necessarily need to be repeated from scratch every year, provided the relevant circumstances remain unchanged.

So before cancelling HCA flu clinics, practices may want to examine the guidance carefully.

The solution may not be fewer HCA vaccinators.

It may simply be a better-designed vaccination pathway.

Sources

UK Health Security Agency – Flu vaccination programme 2026 to 2027: information for healthcare practitioners UK Health Security Agency – Influenza Vaccine Group Direction 2026/27 NHS Specialist Pharmacy Service – Patient Specific Directions (PSD) BMA/GPC England – Provision of vaccinations by non-registered healthcare workers Londonwide LMCs – Seasonal flu campaign 2026/27