Oliver McGowan Mandatory Training: What CQC Now Expects
This has been a statutory requirement since 2022 — but a new Code of Practice from September 2025 turned it into something CQC can inspect against directly. Here’s what actually changed, and what it means for your staff training records.
The Oliver McGowan Mandatory Training on Learning Disability and Autism takes its name from Oliver McGowan, whose death exposed serious, avoidable gaps in how health and social care staff understand learning disability and autism. Since the Health and Care Act 2022 came into force on 1 July 2022, it’s been a statutory requirement for CQC-registered providers to ensure staff receive this training appropriate to their role — it isn’t optional, and it isn’t something a service can substitute with informal in-house awareness sessions and assume it’s equivalent.
The Two Tiers, and Why Getting Them Right Matters
The training is structured in two tiers, and which one applies depends on the level of contact a staff member has with people who have a learning disability or autism:
- Tier 1 — Awareness: for staff with indirect or occasional contact — administrative, reception, estates, and other support roles
- Tier 2 — In-depth: for staff who provide direct care or support, or who make decisions about service delivery — this includes managers, clinicians, and all frontline care staff
Assigning a frontline care worker to Tier 1 because it’s shorter, or assuming a registered manager doesn’t need Tier 2 because they’re “not hands-on,” are both common ways services end up with a training record that looks complete but isn’t actually compliant.
What Changed on 6 September 2025
The statutory duty itself dates back to 2022, but it was significantly strengthened when the Oliver McGowan Code of Practice came into force on 6 September 2025. This matters because the Code of Practice now forms the specific benchmark CQC uses when assessing compliance with Regulation 18 (Staffing). Before the Code, the training requirement existed but the standard CQC would measure a service against was less concrete. Now, inspectors have an explicit reference point to check training records against — which changes this from a background legal obligation into something that shows up directly in how Regulation 18 gets assessed.
Risky assumption
“We already do learning disability awareness training, so we’re covered” — without checking whether it actually matches the standard the Oliver McGowan Code of Practice sets.
Safer position
Staff mapped correctly to Tier 1 or Tier 2 based on their actual contact level, training delivered against the standardised Oliver McGowan programme specifically, and records that show completion dates by name and tier.
What CQC Can Reasonably Ask to See
With the Code of Practice now the benchmark for Regulation 18, inspectors can reasonably request training records showing exactly which staff completed which tier and when, and whether refresher training is scheduled where it’s due. A gap here isn’t treated as a separate, softer issue — it’s treated as a staffing compliance gap like any other under Regulation 18.
Don’t assume your existing training counts
Generic learning disability and autism awareness training your service already runs may not satisfy this requirement unless it genuinely matches the Oliver McGowan standard. If you haven’t specifically checked this against the Code of Practice since September 2025, it’s worth confirming directly rather than assuming.
Know exactly who’s covered, and who isn’t, at a glance
CQCLogic’s Staff Training Tracker maps every team member to the correct tier, flags who’s due a refresher, and keeps completion evidence ready to show an inspector — so Regulation 18 compliance for this specific requirement is never a guessing game. See the full feature or view a sample plan.
Summary: Oliver McGowan Training and CQC
- Statutory since 1 July 2022 under the Health and Care Act 2022 — not optional for CQC-registered providers
- Two tiers: Tier 1 (awareness, indirect contact roles) and Tier 2 (in-depth, direct care and decision-making roles)
- The Oliver McGowan Code of Practice came into force 6 September 2025, strengthening the requirement
- The Code of Practice now forms CQC’s specific benchmark for assessing Regulation 18 (Staffing)
- Generic in-house learning disability/autism training may not meet the standard unless verified against the Code
- Inspectors can reasonably request tier-by-tier, name-by-name training completion records
Frequently Asked Questions
What is the Oliver McGowan Mandatory Training?
It’s the standardised training on learning disability and autism that the Health and Care Act 2022 made a statutory requirement for CQC-registered health and social care providers. It’s named after Oliver McGowan, whose death highlighted serious gaps in staff understanding of learning disability and autism, and it’s the preferred and recommended training of its kind for the sector.
Which staff need Tier 1 versus Tier 2 training?
Tier 1 is awareness-level training for staff with indirect or occasional contact with people who have a learning disability or autism — administrative, reception, estates, or support roles. Tier 2 is for staff who provide direct care or support, or who make decisions about service delivery, including managers, clinicians, and all frontline care staff. Getting a staff member assigned to the wrong tier is one of the more common compliance gaps.
What changed with the Oliver McGowan Code of Practice in September 2025?
The statutory duty to provide the training existed from 1 July 2022, but it was strengthened on 6 September 2025 when the Oliver McGowan Code of Practice came into force. This Code of Practice now forms the specific benchmark CQC uses to assess compliance with Regulation 18 (Staffing) — meaning CQC has a much more concrete standard to inspect against than it did before.
Is this different from other learning disability or autism awareness training we already provide?
It can be, and that’s a real risk if you haven’t checked. The Oliver McGowan Mandatory Training is the specific standardised training recommended for meeting the statutory requirement — generic or in-house learning disability awareness training your service already delivers may not satisfy CQC’s expectations under the Code of Practice unless it genuinely matches the standard the Code sets.
How does CQC actually check this during an inspection or assessment?
Since the Code of Practice now forms the benchmark for Regulation 18 (Staffing), inspectors can reasonably ask for training records showing which staff completed which tier, when, and whether refresher training is scheduled where required — treating gaps in this specific training the same way they’d treat any other staffing compliance gap.