Appendix 1: Correspondence: Test to Release Scheme
Letter from Robert Courts MP, Parliamentary Under Secretary of State at the Department for Transport, to Lord Hodgson of Astley Abbotts, Chair of the Secondary Legislation Scrutiny Committee
Thank you to you and other Noble Lords for joining the briefing session on 14 December and for your considered questions raised in relation to the Government’s Test to Release scheme.
Thank you too for the Committee’s 37th Report of Session 2019-21, published on 9 December. I committed to responding in writing to the Committee’s queries outlined therein.
You asked for further explanation and evidence in support of the policy change behind the scheme. The Test to Release regime marks an important evolution of our approach to health measures at the border. It provides passengers with the confidence that they can book travel and know that they have the opportunity to shorten their self-isolation by up to 5 days, should they choose to opt in to Test to Release and receive a negative test result. It will provide a much-needed boost to international travel, helping to stimulate our economy and show that the UK is open for business, while protecting public health.
Data has shown that even the most accurate tests are only accurate when the viral load is high enough to be detected. This point is generally not reached until 1 day before symptoms are displayed. Symptoms do not typically develop until 5-6 days following infection. Many cases are also asymptomatic. Therefore, a test after 5 days of self-isolation provides a strong level of protection against transmission of COVID-19 acquired abroad into the UK population, while allowing much more freedom for people seeking to travel.
We have considered existing scientific evidence carefully throughout this process and in advance of implementation. We have monitored other countries’ proposals and systems closely to learn from any successes and setbacks. The approach we are taking on travel testing mirrors that of close partners, including Iceland and Germany.
On the matter of enforcement, you asked whether there could be greater co-ordination between the different systems involved to ensure effectiveness. The NHS Track and Trace app is designed from the ground up to protect user privacy. Linking this app to the Passenger Locator Form (PLF), which requires travel history, home address and address of stay in the UK, would not be compatible with this purpose. Therefore, the role of contact tracing is best fulfilled by the PLF for journeys to the UK. However, PHE is able to link into the PLF system, for example through flight manifests, to identify other travellers an infected individual may have been in contact with during their journey. We appreciate that the number of fines issued for non- compliance with the requirement to complete the PLF at the border is low; however, Border Force has now moved to an Enhanced Enforcement Posture (EEP) which means that more people will be issued with fines if they have not completed the PLF. This is instead of being given the opportunity to complete the form before being issued a fine. This will help ensure more people complete the PLF before they reach Passport Control and help ensure the flow of passengers through airports is maintained.
Compliance checks, to ensure that international arrivals who are required to self-isolate are doing so, are carried out by Public Health England’s Isolation Assurance Service (IAS). IAS contacts randomly sampled international arrivals to ensure that they are self-isolating, including individuals who have opted in to Test to Release but have not yet received a negative test result. Compliance checks are also carried out by the police. If passengers test positive, they will be required to self-isolate for 10 days from the day of the test or when their symptoms started, if earlier, and will be subject to existing domestic support and enforcement measures.
You asked for further information about the Department’s evaluation of the effectiveness of the International Travel Regulations and about the evidential basis on which it was decided to introduce the Regulations to amend them. The Health Protection (Coronavirus, International Travel) (England) Regulations 2020 (“the Regulations”) are designed to reduce domestic transmission from imported cases of COVID-19. The Secretary of State must review the need for the requirements imposed by the Regulations at least every 28 days. This means determining whether each of the requirements remains necessary to achieving the public health aims of the Regulations. The statutory review includes consideration of both the requirement for international arrivals to complete a PLF and the requirement to self-isolate for 10 days, as well as consideration of the package of the measures as a whole. Each restriction is judged by reference to its continuing necessity as the pandemic develops; and based on the available information at each stage about the effectiveness and impact of the measures.
You asked for the evidence underpinning the assertion that “the protective effect of testing to release international arrivals after 5 days of self-isolation is only marginally less effective than 14 days of self- isolation”. As the Committee will be aware, the requirement for self-isolation has now been reduced to 10 days. PHE modelling, available at gov.uk, sets out the effectiveness of testing international arrivals after a period of 5 or 8 days’ self-isolation. The assumption made in the paper is that an individual would continue to self-isolate for 2 days, for example while tests are processed, meaning that they would be released from self-isolation on receipt of a negative result after 7 or 10 days. This results in an effectiveness of 85% when a test is taken after 5 days and 96% when a test is taken after 8 days. 98% effectiveness is reached when a test is taken after 10 days, with a further 4 days’ self-isolation (i.e. 14 days in total). Other modelling, conducted for example by the London School of Hygiene and Tropical Medicine, has reached results that are broadly consistent with PHE’s.
You also asked for further information about the Department’s level of confidence that travellers will comply with the new Regulations. There is no requirement to take a test – any person who is self-isolating because they have been in a country, territory or region not on the travel corridors list at any point in the 10 days before the date of their arrival in England may opt in to the Test to Release scheme on a voluntary basis.
For those who do opt-in, Test to Release will be enforced through a system of encouraging compliance in the first instance, followed by enforcement activity where needed. We will closely monitor the implementation of the scheme, including uptake and compliance, and will keep the scheme and amending regulations under constant review.
17 December 2020