The COVID-19 vaccines and undocumented migrants in the UK

As part of our efforts to monitor access to the COVID-19 vaccines for undocumented migrants in Europe, we’re speaking with national-level advocates about the situation in their countries. This interview was conducted in April 2021 with Anna Miller of Doctors of the World UK to discuss the situation in the UK. It is not meant to offer an exhaustive picture of the legal and practical context in the UK. Please get in touch at info@picum.org if you have information you’d like to share, and follow our Twitter page @PICUM_post to get more recent updates.

What does the UK vaccination strategy say about undocumented people?

The government says that the COVID-19 vaccines are accessible to everyone, including undocumented migrants, for free and without immigration checks. This is reflected in official guidance too.

So, all good?

Not really. There are still a number of challenges for undocumented people to actually get vaccinated against COVID-19. Starting with getting registered with a GP.

How do you register with a GP?

To get a vaccine, you need to book an appointment. You can do this either online or by calling your GP. The problem with the online registration is that you need an NHS (National Health Service) number, which lots of undocumented migrants don’t have.

How do you get one?

There are different ways. In some cases, you can get one automatically, for instance if you’re born in the UK, irrespective of your migration status. Or if you come to the UK on a visa for 6 months, you’ll have to pay a contribution to the NHS (the “immigration health charge”) and you’ll get an NHS number.

But most undocumented migrants don’t fall under these groups, and the only way they can get the number is through a GP.

What does that involve?

When you first go to the GP, and you don’t have an NHS number, the GP will request one for you, which you should be able to get in 14 days. But GPs routinely ask for proof of address or identity or immigration status, which can be hard if not impossible for undocumented migrants to produce. Government guidelines do say that the lack of those documents can’t be a ground for refusal, but in practice some GPs refuse to register people without those proofs. This is a huge issue.

What does this mean for access to the COVID-19 vaccines?

It means that if the GP refuses to register you, you won’t get your NHS number and you won’t be able to book an appointment for your COVID-19 vaccine.

How can this be solved?

We’ve been asking the government and the healthcare service to raise awareness among GPs about the paper requirements for registration, but most communications campaigns instead focuses on the patients. In England, for instance, NHS England has produced a card with the NHS logo for GP registration, which says that no document is required. Basically, it’s a self-advocacy tool. But it has limited impact, as the process for registering with a GP mostly happens online these days. And the online registration system still requires you to provide proof of address or identity.

Several Filipino care workers, who would be eligible for the COVID-19 vaccines because of the work they do, told us they tried to register with a GP online but didn’t manage to because of those requirements.

There are good practices, though, among doctors and clinics. Some local primary care networks are proactively doing outreach to people who haven’t come forward for vaccination and are eligible. Sometimes it’s outreach in asylum accommodation centres, or hotels used for confinement during lockdown for homeless people. But all of this work is driven locally, rather than coming from the government, so there is variation from region to region.

Let’s say an undocumented person was lucky enough to encounter an enlightened GP and get an NHS number, and an appointment for the vaccine. Will they need to show anything else at the vaccination centre?

Your booking reference number should be enough. But we’ve heard of cases where the vaccination centres asked for some proof of identity. The feeling is that this is due to sheer lack of awareness from the administration, we haven’t heard of cases where people were refused vaccination at the centre because they didn’t have those documents.

Since 2012, the UK government introduced a set of policies, known as “hostile environment”, that aim to make life unbearably difficult in the UK for those who cannot show the right paperwork.  How does this play into access to the vaccines?

This is a key point. The policy on access to the vaccines may be quite progressive on paper, but it’s implemented against the backdrop of years of policies that have eroded the trust of migrant communities in public authorities including the healthcare system. This includes the practice of sharing patient’s personal information with the Home Office, which is then used to carry out immigration enforcement activities.

Do health care providers share patients’ information with immigration authorities?

Patient data collected by primary care services used to be shared with the Home Office, because of a mechanism that existed between 2017 and 2018. The policy stopped but the fear around that is still very much there.

Secondary care services routinely share information about migrants with insecure immigration status with the Home Office. This results in people from migrant communities not trusting any type of healthcare services, including primary care ones.

We’ve long been asking the government to make all health care services safe and confidential for migrants and to communicate clearly about the prohibition of data sharing with immigration enforcement. So far, our calls have largely been ignored.

Cover: Ugur Akdemir – Unsplash