Joint statement on death certification during the COVID-19 pandemic

A joint statement from Care Quality Commission, General Medical Council and Healthcare Improvement Scotland on death certification during the COVID-19 pandemic

During the COVID-19 pandemic there has been a change in legislation concerning completion of the medical certificate cause of death (MCCD) by medical practitioners*. Deaths are still required by law to be registered within 5 days (in England, Wales and Northern Ireland) or 8 days (in Scotland) of their occurrence unless there is to be a coroner’s post-mortem or an inquest or, in Scotland, the death has been reported to the Procurator Fiscal.

We acknowledge and thank doctors for responding and adapting to the revised arrangements during this very difficult time. Prompt and accurate certification of death is essential and crucially important during this pandemic. Not only does a MCCD provide the family with an explanation of how and why their relative died, it enables the deceased’s family to register the death and begin to make further arrangements in challenging circumstances, and also provides a permanent legal record of the fact of death. 

We do know some questions have arisen about how doctors should complete the form when the diagnosis of COVID-19 has not been confirmed by laboratory swab testing. This joint statement makes clear our position on that point.

The doctor issuing the MCCD has to state what they believe to be the most likely cause of death based on their knowledge of the patient, the events surrounding the death, and the medical history and any investigations available. With a lack of comprehensive COVID-19 swab testing of individuals in the community, the clinical accuracy of the cause of death based on clinical opinion is of key importance in the public health management of the pandemic. It determines the accuracy of data collected by the Office for National Statistics, National Records of Scotland and Northern Ireland Statistics and Research Authority. There may also be significant implications for other household members, or for the residential settings in which a person may have lived, when a diagnosis of COVID-19 is recorded on a MCCD. 

In the circumstances of there being no positive swab diagnosis, it is satisfactory to apply clinical judgement. Doctors are expected to state the cause of death to the best of their knowledge and belief, it is not required that the cause must be proven. 

Doctors are under a duty to complete the MCCD as accurately as possible. The inclusion of COVID-19 in any part of the MCCD is a matter for the doctor completing the form and there should be no expectation or pressure placed upon them to include or exclude it during the pandemic period.

*The Coronavirus Act 2020 put in place the mechanisms for changes relating to the registration of deaths in all four countries of the UK. Subsequent changes have been made to regulations and procedure. More detail is available for each nation: England; Northern Ireland; Scotland; and Wales.