Coronavirus (COVID-19) domestic vaccine certification: business and regulatory impact assessment

Summary and recommendations

The Scottish Government's Strategic Framework includes a package of measures which, taken together, are designed to suppress transmission of the virus. Although daily Covid case numbers are dropping in Scotland, case numbers remain too high, and we still have a large susceptible population which could lead to cases rising again. In addition, the number of people in hospital and ICU continues to increase.

This BRIA has set out the relative costs and benefits of Certification options with the intended effect of reducing the risk of transmission, reducing the risk of serious illness and death, allowing higher risk settings to stay open and increasing vaccine uptake. Our assessment of the options has been informed as much as possible by engagement with the sectors in scope.

A summary of costs and benefits associated with the options is presented below in Table 4:

Table 4: Summary table.

Measure:

Option 1: Do not introduce Certification – where baseline measures are in place, we continue with them including in higher risk settings

Benefits:

Businesses would continue to trade as under current circumstances, and would not be required to adhere to any further restrictions.

There would be little additional public health benefit, over and above that arising from continued use of baseline measures in higher risk settings.

Costs:

Businesses would not incur any additional infrastructure and staffing costs. Therefore this option is not likely to have immediate financial implications beyond those associated with continuation of baseline mitigation measures.

However if the state of the epidemic requires further more restrictive measures and even closures to be considered, the negative economic impact on these sectors is likely to be significant.

Measure:

Option 2: Introduce voluntary, non-regulatory, Certification in higher risk settings

Benefits:

No new or additional requirements of businesses regarding Certification, unless they chose to implement it.

Public health benefit would depend on scale of adoption in higher risk settings.

Costs:

Businesses choosing to introduce Certification would incur costs relating to additional staffing and infrastructure. It is likely that restrictive measures and even closure may be required.

Measure:

Option 3: Introduce mandatory Certification in higher risk settings and remove capacity limits from regulations

Benefits:

Sectors in scope are characterised by many of the high risk factors associated with transmission of the virus. Certification is an additional means through which we can continue to reduce the risk of transmission. As such, it will mitigate the risk of closure and more restrictive measures, and consequent negative economic impact.

This option would result in the most benefit to public health and would reduce the risk of infection and transmission of the virus and subsequent hospitalisations and pressure on the NHS.

Costs:

These include both direct costs of compliance with the regulations (staffing and infrastructure), potential losses of footfall and revenue arising e.g. from refunds to customers, cancellation of events. This could be offset by people choosing to go to settings where there is certification.

We conclude that Option 3 - a limited and targeted Certification scheme - is a necessary and proportionate response, alongside an effective baseline of public health measures, which will best meet our policy objectives. Monitoring and evaluation will inform implementation as well as regular review (at least once every 21 days) of the Regulations to determine whether any less intrusive alternative measures could be introduced to achieve the same combination of policy objectives in respect of the higher risk sectors concerned.