Introduction - success of the programme

1. The closing oral statement of the British Medical Association is as follows. The BMA’s position remains as stated at the outset of these hearings, that the Covid-19 vaccination programme was one of the biggest successes of the pandemic, as clearly demonstrated by the estimate of the UKHSA that as at September 2021, vaccination in the UK had prevented more than 24.3 million infections and over 123,000 deaths. 

2. The BMA also recognises and commends the speedy development and authorisation of the vaccine, which took place without compromising safety.  

3. However, the BMA’s interests in the issues under consideration in this Module primarily relate to vaccination roll out and deployment, and in particular to the following issues: 

• the role of general practice in delivering the vaccination programme;
• barriers to vaccine uptake; 
• workforce planning and capacity; 
• data collection, handling and record keeping; and 
• vaccination as a condition of deployment.

The role of general practice in vaccine delivery 

4. In respect of the role played by general practice, the BMA considers that GPs and their practice teams, made a major contribution to the success of the vaccination programme.  

5. The BMA proactively made the case in England that the COVID-19 vaccination programme should be delivered by general practice, and the Inquiry heard from Dame Emily Lawson that in England, GPs were the right model, particularly for the most at risk priority groups (including care home residents and the elderly). This use of existing infrastructure, and delivery of vaccinations at a local level was highly effective, and by the end of October 2021, 71% of vaccines in England had been administered by GPs and their teams and community pharmacies.  

6. The Inquiry was told that many people felt more comfortable and had greater levels of trust in receiving their vaccination from their local GP rather than at a vaccination centre. GPs have substantial experience of delivering vaccinations and have existing knowledge of and relationships with their patients (particularly elderly patients). This, coupled with the proximity of GPs to their local populations, helped overcome barriers to access. In addition, GPs have the expertise to address questions or concerns about the vaccine and to encourage uptake in their local communities. And as confirmed by the UKHSA, being able to receive a vaccine in a familiar environment can support public confidence. 

Vaccine uptake – barriers and hesitancy 

7. Turning to barriers to uptake, the Inquiry has heard a substantial volume of evidence on disparities in vaccination uptake amongst different population groups, including ethnic minority communities, migrants, Gypsy, Roma and Traveller communities, disabled people and those living in deprivation.   

8. These disparities highlighted long standing problems of inclusion within UK healthcare systems, and it was well known before the pandemic that there was historic mistrust of the healthcare system and vaccines within certain communities.   

9. A 2016 report of Public Health England on flu vaccination showed lower uptake by people from ethnic minority backgrounds than for people with White British or White Irish backgrounds. And this trend was also seen in the lower rates of Covid-19 vaccine uptake amongst ethnic minorities, again with vaccine uptake highest among those from a White ethnic background.  

10. The Inquiry has also heard that deprivation was a factor in lower uptake in all ethnic minority groups, with vaccine uptake higher in areas of greater affluence, something the BMA highlighted in its fifth Covid-19 Review Report.  

11. People from ethnic minority and deprived communities had worse health outcomes before the pandemic and had a higher likelihood of becoming infected with and experiencing severe symptoms from Covid, not least because of wider health inequalities. Disabled people were also at significantly greater risks from Covid and from dying as a result of infection. With this in mind, the BMA submits that there should have been greater consideration of these groups when planning the vaccine rollout. 

12. Professor Van Tam’s witness statement reflects this position, and sets out that [quote]: “It is well known that vaccine uptake tends to be lower in marginalised, deprived and minority ethnic communities. It was therefore foreseeable that a similar pattern would be observed when it came to delivery of the COVID-19 vaccines, as indeed it was. It is therefore arguable that more should have been done in the planning phase to consider this”. 

13. The mechanisms of the programme also on occasion caused barriers to vaccination. For example, although disabled people were a focus of prioritisation, the less than full identification of people living with a learning disability, and a lack of clarity on the level at which a learning disability provided priority eligibility, created a barrier in accessing vaccination for this vulnerable group. This must be addressed in advance of any future pandemic to ensure that the main means of offering vaccination in a mass vaccination programme does not rely on self-identification. 

14. The Inquiry has also heard of physical barriers preventing vaccine uptake such as the distance to a vaccination site, the cost of transport, and difficulties or concerns for the clinically vulnerable, disabled, elderly, or housebound from attending a vaccination centre. The lack of an NHS number also presented issues for people in the homeless population, the Gypsy, Roma and Traveller communities and vulnerable migrants.    

15. The BMA recognises that efforts were made to address vaccine hesitancy and to overcome barriers to accessing vaccines, but more needs to be done to instil confidence. Evidence before the Inquiry supports ongoing engagement with marginalised and underserved communities, which has been lacking.   

16. As already mentioned, the disparities in access and uptake laid bare the disparities in access to healthcare more broadly and highlight an important area for governments across the UK to prioritise for urgent improvement. The Inquiry’s experts in vaccine delivery and disparities warned that, “we cannot be complacent. We have to be continuously promoting uptake of vaccinations. And it needs to be resourced…”.   

Mis-/Disinformation  

17. Misinformation and disinformation also contributed to vaccine hesitancy and the Inquiry has heard about these issues from a number of witnesses in these hearings, including the Director General with overall responsibility for the Counter Disinformation Unit, who told the Inquiry that, “disinformation is defined as the deliberate creation and dissemination of false information which is intended to deceive and mislead. And misinformation is the same but without the deliberate intent”. 

18. During the pandemic the BMA ran its own social media campaign to address vaccine hesitancy and called on the UK Government to take more action to tackle misinformation online.  

19. It goes without saying, then, that the BMA entirely rejects the assertion made by the former Minister for Equalities, Kemi Badenoch, in her oral evidence that the BMA was itself responsible for misinformation.  

20. The background circumstances to this issue are that the BMA raised legitimate concerns in June 2020, within a number of letters to Ms Badenoch and the Secretary of State for Health and Social Care, following publication of the Public Health England Review into inequalities and disparities - and, my Lady, you heard evidence on this issue in Module 2.  

21. The BMA had anticipated that the review would address why there were such disproportionate deaths and serious illnesses in healthcare workers from ethnic minority backgrounds. However, when the review report was published it failed to address the (staggeringly) higher proportion of deaths amongst healthcare workers from ethnic minority backgrounds and the report failed to include recommendations to address this alarming disparity.  

22. In response to Ms Badenoch’s criticisms, Professor Banfield, the BMA’s Chair of UK Council issued an immediate public response on Monday of this week which concluded: 

“To suggest the BMA was spreading misinformation at the time is highly disingenuous. All we were doing was asking the Government to be transparent about how and when it was planning to take action to save lives and address racial inequalities.”  

Workforce planning and capacity  

23. In respect of workforce planning and capacity, the BMA’s view is that General Practice was the right delivery vehicle for Covid vaccination. However, the BMA remains concerned that insufficient consideration was given to workforce planning in connection with the vaccination programme, and that delivery of the programme further reduced the already limited workforce capacity in general practice, with GPs and other healthcare workers required to work additional hours to administer vaccinations while still continuing to deliver Covid and non-Covid care. 

24. During the pandemic the BMA engaged with NHS England and the Department for Health and Social Care to address the increasing demands on general practice, the rising workloads, and workforce shortages, and made clear that general practice was at breaking point and there were “simply too few GPs”. 

25. Against this background, the comments made in the published witness statement of the former Secretary of State for Health, Sir Sajid Javid, that the BMA sought to take commercial advantage of the vaccination scheme are shameful and offensive, and expose complete ignorance of the reality for GPs on the ground – including the overwhelming demand, the lack of capacity, and the abuse faced by GPs and their staff, while they did their best to manage unmanageable workloads. 

26. The vaccination programme was substantial additional work that general practice delivered in the national interest, requiring existing or additional staff to take on increased hours, often at weekends. It did not result in GPs being ‘paid twice’ as alleged, and the efficiency with which GPs delivered vaccines was more cost effective that the cost per dose at mass vaccination centres. 

Data collection, handling and record keeping 

27. On the question of data sharing, access to GP data is subject to a number of checks and balances. These are put in place to preserve the integrity of the doctor-patient trust relationship and to ensure that GPs uphold their obligations as data controllers under GDPR. The BMA was broadly supportive of measures put in place to support the UKs pandemic response which lowered the threshold on access to GP data.  

28. The Inquiry heard evidence that such measures should be brought back to enable better sharing of health data. The BMA agrees that improved data sharing is essential to providing safe, high-quality healthcare and to enable health services to respond to emergencies such as a future pandemic. However, great care must be taken to safeguard patient confidentiality. 

Vaccination as a condition of deployment 

29. Finally, on the issue of vaccination as a condition of deployment (or VCOD), the Inquiry has heard differing views on the merits of this policy.  

30. The BMA’s position is that it strongly urges doctors and frontline healthcare workers to be vaccinated and uptake amongst doctors of the Covid-19 vaccine was high. But the BMA considers that mandating vaccination is not the right approach and would worsen the existing recruitment and retention crisis within health and social care, as seen when the policy was implemented for a short period of time within social care in England, which caused significant reductions in the workforce.     

31. Covid-19 vaccines have been very successful at controlling serious disease and death, but they do not prevent transmission of Covid-19. And Professor Sir Chris Whitty, while acknowledging that VCOD was a political decision, expressed his scepticism that it was a good idea and told the Inquiry that, “mandation has not got a very happy history”. He also highlighted that doctors have a clear professional responsibility to protect patients by having vaccinations but said that “there is a big difference between responsibility and mandating it so that you lose your job”. 

32. A similar view was held by Dame Jenny Harries, who advised in February 2021 that there was no evidence that the policy would have more benefit than harm.   

Conclusion 

33. In conclusion, while there is no doubt the COVID-19 vaccination programme was a success, there are lessons to be learned from this experience – and from vaccination programmes before it – that can lead to increased uptake and reduced disparities, which will in turn further reduce the risk of infection and save more lives.