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Regulation & inspection

Oliver McGowan training: what CQC inspectors will look for

By Dr. Stewart Wilson ·

Learning disability and autism training is a legal duty for CQC-registered providers. Tier 1 vs Tier 2, and the evidence inspectors expect.

By the numbers

LeDeR 2024 report (published July 2026)People with a learning disabilityGeneral population
Median age at death62.8 years81.8 years
Deaths classed as avoidable39%21.1%
Avoidable deaths in 202146.3%

Pneumonia, ischaemic heart disease and epilepsy together caused 32.8% of avoidable deaths in 2024. "Avoidable" here means a death before 75 from a cause that is preventable or treatable.

Oliver McGowan was 18 when he died in 2016, after being given antipsychotic medication that he and his family had said he should not have. His mother, Paula McGowan, campaigned for every health and care worker to be trained to understand autistic people and people with a learning disability. That campaign is now law: CQC-registered providers must make sure staff receive learning disability and autism training appropriate to their role, and inspectors are checking it.

Many providers are still unsure what "appropriate" means in practice. This is a plain guide.

Median age at death
People with a learning disability
62.8 years
General population
81.8 years

Source: LeDeR 2024 report (King's College London)

Deaths classed as avoidable
People with a learning disability
39%
General population
21.1%

Source: LeDeR 2024 report (King's College London)

The legal position

The requirement comes from section 181 of the Health and Care Act 2022, which amended the Health and Social Care Act 2008. The Act does not name a course. Instead, a statutory Code of Practice sets out the standards training must meet and describes three tiers. Tiers 1 and 2 are the ones that apply to most staff; Tier 3 is for specialists.

CQC must take the Code into account when judging whether training is appropriate. If you depart from it, you need good, documented reasons and must show you meet the requirement another way.

Tier 1 or Tier 2?

TierWho it is forIn brief
Tier 1Staff who need a general awareness and may support people with a learning disability or autistic people occasionallyAwareness of needs and reasonable adjustments
Tier 2Staff who provide care or support and would seek help from others for complex management or decision-makingDeeper knowledge and skills, including the ability to adapt care

In adult social care, most care staff and managers will need Tier 2. If someone provides, or could be asked to provide, care to a person with a learning disability or an autistic person, plan for Tier 2.

Branded package or equivalent?

The Oliver McGowan Mandatory Training is the government's preferred and recommended package. However, CQC has said it will assess providers against Regulation 18 and the Code's standards rather than require a specific brand. In June 2026, Care England wrote to CQC's Chief Inspector of Adult Social Care asking it to confirm this approach and make inspections consistent.

Whichever route you choose, you must be able to show your training meets the Code's standards. On cost: funding for the branded training continues in 2026–27 through the Learning and Development Support Scheme, but it covers only the branded package, not equivalents.

What inspectors are likely to ask for

  1. A role map showing which staff need Tier 1 and which need Tier 2.
  2. A training matrix with completion dates for the eLearning and the live or face-to-face parts.
  3. An implementation plan with milestones for anyone not yet trained.
  4. Evidence of equivalence if you use training other than the branded package.
  5. Evidence in practice: care plans with reasonable adjustments, communication passports, and staff who can explain how they adapt care.

That last point matters most. A certificate shows a course was completed; an inspector will want to see that care has changed as a result. Our article on evidencing training in practice has more on this.

Why this matters beyond compliance

People with a learning disability die at a median age of 62.8, nineteen years younger than the general population, and 39% of their deaths are classed as avoidable, nearly twice the rate in the general population. Training is how we close that gap: noticing pain in someone who cannot say they are in pain, making a reasonable adjustment, listening to the family who know the person best.

Sources

About the author

Dr. Stewart Wilson

Stewart is Complete Care Training's CEO. A Doctor of Chiropractic and the owner of four care companies, he writes about what the latest policy and evidence mean on the care floor.