Introduction

Training on learning disabilities and autism, which meets the standards set by the Oliver McGowan code of practice, is now a statutory requirement for all CQC-registered health and social care providers. The requirement was introduced under the Health and Care Act 2022, which came into force on 1 July 2022, and was strengthened on 6 September 2025 with the commencement of the Oliver McGowan Code of Practice.

This Code now forms the benchmark against which CQC will assess compliance with Regulation 18 (Staffing) of the Health and Social Care Act 2008 (Regulated Activities) Regulations. All providers must ensure that every member of staff from frontline care workers to ancillary staff such as porters, receptionists, and catering teams receives training on learning disability and autism that is appropriate to their role

The requirement arose in response to persistent health inequalities. LeDeR (Learning from Lives and Deaths) reviews have repeatedly shown that autistic people and people with a learning disability die around 20 years earlier than the general population, often from preventable causes, and experience significant barriers when accessing health and care

The case of Oliver McGowan, who tragically died in 2016 after receiving inappropriate care and medication, brought national attention to the lack of training across services. Oliver’s death became the catalyst for reform, leading to the development of a standardised national training package co-designed and co-delivered with autistic people and people with a learning disability.

This update provides members with a complete reference guide to Oliver McGowan training what it involves, what CQC expects, how it is funded, where the uncertainties remain, and what actions providers should take.

What the Training Involves

Structure of the Training

The Oliver McGowan Mandatory Training (OMMT) is the preferred and recommended training[1], it is treated as an exemplar of learning disability and autism training to meet the requirements in the code of practice. It delivered as a two-part, two-tier programme:

• Tier 1 – Awareness training for staff in roles with indirect or occasional contact, such as administrative, reception, estates, or support staff.
• Tier 2 – For staff who provide care, support, or make decisions about service delivery, including managers, clinicians, and all frontline staff.
• Tier 3 – Additional or specialist training for roles requiring deeper expertise. Tier 3 sits outside the OMMT package and must be commissioned separately. Examples may include advanced autism specialisms, PBS (Positive Behavioural Support), or clinical postgraduate qualifications

Each tier has two parts:

• Part 1 – A 90-minute e-learning module, free to access via NHS e-Learning for Healthcare (e-LfH). All staff must complete this. If more than six months passes before completing Part 2, Part 1 must be refreshed.
• Part 2 – An interactive component co-delivered by people with lived experience:

• For Tier 1, a one-hour live interactive remote session.
• For Tier 2, a full-day (or two half-days) face-to-face session.

Indicative Durations

• Tier 1: Around 2.5 hours in total (90-minute e-learning + 1-hour live session).
• Tier 2: Around 1.5 hours e-learning + 1 full day (or two half-days) face-to-face.

 

Refresh Requirements

Training should be refreshed at least every three years, or sooner if a staff member’s role changes or if further learning needs are identified. Providers should ensure this cycle is built into their learning management or HR systems.

 

The Four Standards in the Code of Practice

The Code of Practice requires all training to meet four minimum standards. These apply whether providers use the Government’s OMMT package or an alternative:

1. Coverage of the Core Capabilities Frameworks
   • Training must include the essential capabilities set out in the Core Capabilities Framework for Supporting People with a Learning Disability and the Core Capabilities Framework for Supporting Autistic People.
   • These frameworks define the skills, knowledge, and behaviours required across roles and settings.
2. Application into Practice
   • Training must go beyond awareness. Staff should have structured opportunities to explore how what they have learned will apply in their day-to-day work.
   • Providers must be able to show how learning is embedded through supervision, appraisal, and practice.
3. Live and Interactive, with Lived Experience
   • A minimum element of the training must be delivered live and interactively.
   • Crucially, this training must be co-produced and co-delivered by people with a learning disability and autistic people, alongside subject experts.
4. Evidence-Based and Quality Assured
   • Training must be grounded in evidence, trialled, evaluated, and subject to ongoing quality assurance.
   • Autistic people and people with a learning disability must be meaningfully involved in the evaluation and development of training content

 

Supporting Lived-Experience Trainers

Providers must ensure that lived-experience trainers are properly supported and remunerated. Failure to do so risks undermining both the quality of delivery and compliance with the Code of Practice.

 

Approved Trainer List

Employers and participants can check that trainers delivering the training are approved to deliver Oliver’s training by accessing the Oliver’s Training approved trainer list.  Personal contact details of individual approved trainers are withheld for privacy reasons. We do share contacts of the providers who have a team of approved trainers for Tier 1 and/or Tier 2 below.

 

Training Provider List

Employers can find details of training providers offering the standardised The Oliver McGowan Mandatory Training on Oliver’s Training provider list. This list contains the contact details of training providers who have a team of trainers approved to deliver Tier 1 and/or Tier 2 of Oliver’s Training.

Employers have a few options regarding how they can ensure their staff complete Oliver’s Training. For further information about Oliver’s Training and how to access it, please visit the FAQ on accessing the Oliver’s Training webpage.

CQC’s Regulatory Expectations

Legal Basis

The legal duty is set out in the Health and Care Act 2022, which amended Regulation 18 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. It requires providers to ensure all staff receive appropriate training, professional development, supervision, and appraisal. OMMT fulfils the new statutory requirement for training on learning disability and autism.

How CQC Will Assess Compliance

CQC will use the Code of Practice as the basis for assessing whether providers are meeting the regulation. Inspectors will:

• Role Mapping – Expect providers to map every role to Tier 1, Tier 2, or additional training, with written justifications.
• Training Records – Review completion logs, including dates, trainer details, and version of package delivered.
• Competence in Practice – Look beyond training records to see whether staff can apply their learning in areas such as:

• obtaining consent,
• delivering safe and person-centred care,
• treating people with dignity and respect,
• safeguarding, and
• adapting care to meet individual needs

 

Enforcement Approach

CQC has stated it will take a risk-based and proportionate approach, but providers may face enforcement if they:

• cannot evidence that staff have been trained appropriately,
• have not considered the requirements of the Code, or
• have not mitigated risks arising from staff not being trained

Importantly, while OMMT is the Government’s recommended model, it is not the only acceptable training. CQC will accept alternative training if providers can demonstrate it meets the four standards and the requirements of Regulation 18.

 

Commissioner Oversight

In addition to CQC, commissioners may also test compliance with the Oliver McGowan Code of Practice as part of contract monitoring and tendering processes. Providers should be prepared for checks beyond regulatory inspection.

Funding

Current Arrangements

The Department of Health and Social Care (DHSC) has committed to supporting rollout of Oliver McGowan training in adult social care through a dedicated funding stream:

• Window: Training delivered between April 2025 – March 2026 is eligible for reimbursement.
• Mechanism: Claims made via the Learning and Development Support Scheme (LDSS) online portal.
• Costs:

• Part 1 e-learning is free.
• Part 2 is chargeable. Providers must pay upfront and claim reimbursement.

• Evidence: Providers must retain invoices, attendance records, and certificates as proof of completion

 

Quality Assurance of Providers

Skills for Care operates the Quality Assured Care Learning Service (QACLS), which assesses training providers against defined standards. Quality-assured providers are awarded a Quality Assured Care Learning Mark. Over time, only training delivered by QACLS-approved providers may be eligible for reimbursement

The Quality Assured Care Learning Service (QACLS) includes both general quality standards and Oliver-McGowan-specific measures, such as ensuring lived-experience trainers are employed, supported, and paid fairly. Over time, DHSC intends that only training delivered by QACLS-approved providers will be eligible for reimbursement, though this is being phased in gradually.

 

Evaluation and Data Sharing

Providers are expected to carry out pre- and post-training evaluations, retain this information, and be ready to share data with DHSC, NHS England, or Skills for Care if requested. Evaluation evidence will also strengthen compliance during inspection.

 

Beyond March 2026

DHSC has not yet confirmed whether funding will continue beyond March 2026, or at what level. This remains a major point of uncertainty. Care England is pressing for clarity, given the scale of training required across the sector.

What Members Should Do Now

• Map roles to tiers

Assign every staff role to Tier 1 or Tier 2 (noting any Tier 3 needs where specialist training is required) and build a three-year refresh cycle into your HR or learning management system.

 

• Procure compliant training

To make it easier to evidence compliance, use accredited OMMT providers or, if delivering in-house, ensure your provision is accredited. Training must be co-delivered by autistic people and people with a learning disability, with appropriate support and remuneration for those trainers.

 

• Schedule delivery

All staff should complete the 90-minute e-learning module, followed by the correct Tier-specific interactive session:

• Tier 1 = 1-hour live online session.
• Tier 2 = 1 full-day (or two half-days) face-to-face session.

 

• Evidence and records

Keep clear evidence of compliance, including attendance logs, certificates, role mapping records, and pre-/post-training evaluations. Embed Oliver McGowan training into induction, supervision, and appraisal to demonstrate learning is applied in practice.

• Funding

Where available, claim reimbursement for eligible training through Skills for Care’s Learning & Development Support Scheme (LDSS). Retain invoices, provider details, and booking records to support claims.

• Be inspection-ready

Maintain a consolidated inspection pack containing:

• Training policies and role mapping.
• Refresh cycles.
• Schedules and bookings.
• Evidence of trainer/provider accreditation.
• Completion rates and certificates.
• Examples of practice change (e.g., reasonable adjustments, communication and consent processes, sensory/environmental adaptations).

 

Common Pitfalls to Avoid

• Using non-accredited or non-approved training that does not meet the four standards.
• Omitting ancillary staff, bank/agency staff, or new starters.
• Failing to implement a refresh cycle.
• Weak evidence that learning has been applied in practice.
• Not supporting or paying lived-experience co-trainers appropriately

Final Note

The Oliver McGowan Code of Practice is a landmark reform. It imposes a significant new responsibility on providers but also presents an opportunity to transform the way services understand and support autistic people and people with a learning disability.

The requirement is now in force, and CQC will expect to see evidence of compliance. While much of the framework is clear, several critical issues remain unresolved. Care England is actively working with DHSC, NHS England, Skills for Care, and CQC to seek urgent clarity on these grey areas and will continue to update members as new information becomes available.

In the meantime, providers should focus on role mapping, delivering and evidencing training, preparing claims for reimbursement, and embedding learning into practice. Doing so will not only ensure regulatory compliance but also help address the longstanding inequalities that the Oliver McGowan training was designed to tackle.

References

• Care Provider Alliance. Webinar: An Update on the Oliver McGowan Code of Practice for Registered Care Providers. 15 September 2025. (Accessible here)
• Care Quality Commission (CQC). Brief Guide: Mandatory Training Requirement on Learning Disability and Autism. 8 September 2025. (Accessible here)
• Care Quality Commission (CQC). Training Staff to Support Autistic People and People with a Learning Disability. Updated 8 September 2025. (Accessible here)
• Skills for Care. The Oliver McGowan Mandatory Training on Learning Disability and Autism (Oliver’s Training). (Accessible here)
• NHS England. Training Providers and Approved Trainers. (Accessible here)
• Skills for Care. Quality Framework for Adult Social Care Training Provision of The Oliver McGowan Mandatory Training on Learning Disability and Autism (‘Oliver’s Training’). (Accessible here)
• Department of Health and Social Care (DHSC). The Oliver McGowan Code of Practice: Standards for Training on Learning Disability and Autism for CQC-Registered Providers. (Accessible here)

[1] https://www.cqc.org.uk/guidance-providers/nhs-trusts/brief-guides-inspection-teams/mandatory-training-learning-disability-autism