Healthcare screening, assessment and monitoring
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Healthcare screening and assessment runs throughout policy and process documents for immigration detention. This is because medical appointments gathering clinical information for detained people have a dual purpose. Firstly, to ensure people can access medical care whilst detained. But secondly as such information is central to Home Office’s decisions about the risk of harm caused by the detention environment and so considering if that person should be detained at all.
Since healthcare assessments and communication between clinicians and the Home Office is key to understanding safeguarding in detention it would be useful to read this section with the information on the Home Office’s Adults at Risk Policy (AAR).
Healthcare professionals in detention also have a role in monitoring people identified as at risk. This includes situations involving risk of self-harm or suicide, segregation and food or fluid refusal. The policies relating to these areas are set out in the individual sections of the handbook addressing these issues.
The most important processes to understand that apply to all people in immigration detention centres are set out below. Please note that they do not apply to people held in prisons under immigration powers.
Rule 30 STHF Rules/ Rule 34 Detention Centre Rules 2001 sets out the process for offering a healthcare appointment by a clinician within 24 hours of arrival into each place of immigration detention.
Rule 32 STHF Rules/ Rule 35 Detention Centre Rules 2001 sets out the process that requires medical safeguarding reports to be completed by a clinician and sent to the Home Office to trigger a review of the person’s detention.
As set out in the Detention Service Order (DSO) on Management of Adults at Risk (December 2024), all people identified as having vulnerabilities that “may impact on the safety and wellbeing” of that individual should have a vulnerable adult care plan (VACP) completed to document this and any “reasonable adjustments” made in response to their situation if they are held in an IRC.
This sets out the process for making a care plan and subsequent decisions such as the level of monitoring the person will be subject to and any closure of the plan. The policy includes requirements for healthcare staff to be involved in key aspects of the care planning process. It is worth noting that a copy of the care plan should be offered to the detained person. In addition, where a care plan is opened limited information about the person’s situation is shared with the Home Office via an internal form called IS91RA Part C. This is a process for information sharing with the Home Office but does not require any review of whether the individual should be detained.
Both IRCs and STHFs have a broadly similar approach whereby an initial medical appointment should be offered shortly after arrival at that detention site. This appointment should offer the possibility that the clinician will raise safeguarding concerns in a Rule 32/35 report which can trigger a review of detention by the Home Office. The basis under which healthcare staff should draft these reports is the same regardless of whether the detention site is an IRC or a STHF.
The main legal and policy framework for the role of healthcare in identifying safeguarding information is set out in the (DCR 2001) which apply to IRCs and the (STHF Rules 2018) that concern STHFs. These two documents are underpinned by dated March 2019 (the guidance) which gives further detail about how the two sets of Rules should be applied.
Rule 34 DCR 2001 (i.e. the process that applies to IRCs) states:
“Medical examination upon admission and thereafter
34.
(1) Every detained person shall be given a physical and mental examination by the medical practitioner (or another registered medical practitioner in accordance with rules 33(7) or (10)) within 24 hours of his admission to the detention centre.
(2) Nothing in paragraph (1) shall allow an examination to be given in any case where the detained person does not consent to it.
(3) If a detained person does not consent to an examination under paragraph (1), he shall be entitled to the examination at any subsequent time upon request.”
This means detained people at an IRC must be offered an appointment with a GP (this is the definition of a ‘registered medical practitioner’ as set out in Rule 33(1) of the DCR 2001) within 24 hours of their arrival to the detention centre. It also explains that if a detained person refuses this initial offer, they can change their mind at a later date and request an appointment. People in detention are also entitled to be examined by a GP of the same sex, under Rule 33(10) DCR 2001.
Rule 30 of the STHF Rules 2018 (i.e. the process for short-term holding facilities) states:
“Medical screening
30.
(1) Subject to paragraphs (2) and (4), a detained person must be screened by a healthcare professional within two hours of admission to a short-term holding facility.
(2) A detained person's consent must be obtained before screening.
(3) Subject to paragraph (4), a detained person is entitled, if they so request, to be screened only by a health care professional of the same sex and the manager must ensure that a detained person is aware of that entitlement prior to any screening.
(4) In the event that a healthcare professional of the same sex is not available within the two hour time period, the manager must ensure that the screening is conducted as soon as practicable.”
There is guidance on the approach to reception and induction that applies to both IRCs and STHF. For safeguarding purposes, the guidance is clear that a detained person should be seen within two hours of arrival for an initial healthcare screening. The guidance requires the clinician completing this exercise to:
identify any medical needs
consider if reasonable adjustments[1] are needed
note if mobility aids are required
consider if a single occupancy room is medically indicated
assess whether an immediate appointment with a doctor is needed (this is in addition to the offer of a Rule 34 appointment with a GP in IRCs)
ensure a Rule 34 appointment been offered which has been explained as “a physical and mental examination to which each detained individual is entitled, regardless of whether they have any immediate physical or mental health concerns” and document the acceptance or refusal in the person’s medical records
check if the detained person has arrived with the necessary supply of medication, and to make arrangements and provide an explanation for access to this in future
complete an assessment of vulnerability via the healthcare screening questionnaire
check if there are any pre-existing external medical appointments scheduled
[1] This is widely defined in the Vulnerable Adult Care Plan policy as identifying any “reasonable adjustments that can be made to mitigate any identified risks or vulnerabilities. Extra support provided to the individual can include assistance with mobility, assistance with medication or attending medical appointments, regular observations or any other adjustment that will help the individual overcome the impact that such vulnerabilities may have on his or her experience of detention.” The itself gives examples of conditions and disabilities such as reduced mobility, learning disabilities, speech or hearing impairment, dyslexia and severe disfigurement.