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Mental Capacity Act Implementation Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} complies with the Mental Capacity Act 2005 (MCA), the Mental Capacity Act 2005 Code of Practice, the Deprivation of Liberty Safeguards (DoLS) framework where applicable, and the legal requirements governing consent, restrictive practice and deprivation of liberty in care homes in England.

This policy must be read and applied in accordance with:

• the Mental Capacity Act 2005;
• the Mental Capacity Act 2005 Code of Practice;
• Schedule A1 to the Mental Capacity Act 2005 concerning the Deprivation of Liberty Safeguards;
• the current Deprivation of Liberty Safeguards Code of Practice;
• the Human Rights Act 1998 and Article 5 of the European Convention on Human Rights;
• the Care Act 2014;
• the Equality Act 2010;
• the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including:
  • Regulation 9 – Person-centred care;
  • Regulation 10 – Dignity and respect;
  • Regulation 11 – Need for consent;
  • Regulation 12 – Safe care and treatment;
  • Regulation 13 – Safeguarding service users from abuse and improper treatment; and
  • Regulation 17 – Good governance;
• the Care Quality Commission (Registration) Regulations 2009, including statutory notification requirements relating to deprivation of liberty; and
• current CQC guidance concerning consent, mental capacity, restrictive practice and deprivation of liberty.

Care and treatment must only be provided with the consent of the relevant person unless there is a lawful basis for proceeding without that person’s consent. Where a person aged 16 or over lacks capacity to make a particular decision, {{org_field_name}} must act in accordance with the Mental Capacity Act 2005.

The purpose of this policy is also to ensure that people are supported to make their own decisions wherever possible; that capacity is assessed only when there is a proper reason to question it; that decisions made for people who lack capacity are made lawfully and in their best interests; and that any restriction of a person’s rights or freedom is lawful, necessary and proportionate.

2. Scope

This policy applies to all employees, agency workers, bank workers, volunteers, managers and other persons working for or on behalf of {{org_field_name}} whose work may involve supporting a person to make decisions, obtaining consent, assessing or contributing to the assessment of mental capacity, implementing best-interests decisions, using restrictive interventions or supporting a person who may be deprived of their liberty.

The Mental Capacity Act 2005 applies to people aged 16 and over.

The Deprivation of Liberty Safeguards applicable to care homes and hospitals apply to people aged 18 and over who meet the statutory qualifying requirements.

Where a person aged 16 or 17 may be deprived of their liberty, staff must immediately escalate the matter to the Registered Manager. A care-home DoLS authorisation must not be treated as the legal mechanism for authorising the deprivation of liberty of a person aged under 18. Appropriate legal advice and referral to the responsible public authority and/or court must be sought where required.

This policy also applies to interactions with:

• relatives and unpaid carers;
• attorneys appointed under a valid Lasting Power of Attorney;
• deputies appointed by the Court of Protection;
• Independent Mental Capacity Advocates;
• Relevant Person’s Representatives;
• advocates;
• local authorities;
• NHS bodies;
• healthcare professionals; and
• other persons lawfully involved in decisions concerning a person using the service.

Relatives or next of kin do not acquire legal decision-making authority merely because of their family relationship with the person. Any legal authority claimed by another person must be verified before they are permitted to make a decision on the person’s behalf.

3. Policy Statement

{{org_field_name}} is committed to ensuring that:

• People we support are assumed to have capacity unless proven otherwise.
• All practical steps are taken to support individuals in making their own decisions.
• Any decision made on behalf of a person lacking capacity is in their best interests and least restrictive.
• Mental capacity is assessed and recorded appropriately.
• Advance Decisions, Lasting Power of Attorneys (LPAs), and Court of Protection orders are respected.
• Staff receive ongoing MCA training and support to apply the Act correctly.

4. The Five Principles of the Mental Capacity Act

The following five statutory principles must be applied whenever staff are acting under the Mental Capacity Act 2005:

1. Presumption of capacity – A person must be assumed to have capacity unless it is established that they lack capacity in relation to the specific decision that needs to be made.
2. Support to make decisions – A person must not be treated as unable to make a decision unless all practicable steps to help them make the decision have been taken without success.
3. Right to make an unwise decision – A person must not be treated as unable to make a decision merely because they make a decision that other people consider unwise.
4. Best interests – Any act done or decision made under the Mental Capacity Act 2005 for or on behalf of a person who lacks capacity must be done or made in that person’s best interests.
5. Least restrictive option – Before an act is done or a decision is made on behalf of a person who lacks capacity, consideration must be given to whether the purpose can be achieved as effectively in a way that is less restrictive of the person’s rights and freedom of action.

These principles must be considered together. A diagnosis of dementia, learning disability, autism, mental illness, acquired brain injury or any other condition does not, by itself, establish that a person lacks capacity.

5. Assessing Mental Capacity

Mental capacity is decision-specific and time-specific. A person must not be described generally as having or lacking capacity without identifying the particular decision concerned.

A capacity assessment must only be undertaken where there is a reasonable basis for questioning the person’s ability to make the particular decision. Capacity must not be questioned solely because of the person’s age, appearance, diagnosis, disability, behaviour, communication method or because they have made a decision that others regard as unwise.

Before concluding that a person lacks capacity, all practicable steps must be taken to support the person to make the decision themselves. Depending on the person’s needs, this may include:

• providing information in an accessible format;
• using simple or alternative language;
• using pictures, objects, signs, British Sign Language or other communication methods;
• using communication aids;
• involving an appropriate interpreter or communication specialist;
• choosing an appropriate time and environment;
• treating pain, distress, infection, delirium or another potentially reversible cause affecting decision-making where appropriate;
• allowing sufficient time;
• breaking information into manageable stages; and
• involving someone who knows the person’s communication needs well, where this is appropriate and the person agrees or there is another lawful basis for doing so.

The assessment must address the statutory test.

Stage 1 – Impairment or disturbance

The assessor must establish whether the person has an impairment of, or disturbance in the functioning of, the mind or brain. The impairment or disturbance may be permanent or temporary.

Stage 2 – Ability to make the particular decision

The assessor must establish whether, because of that impairment or disturbance, the person is unable to make the particular decision at the time it needs to be made.

A person is unable to make the decision if they cannot do one or more of the following:

• understand the information relevant to the decision;
• retain that information for long enough to make the decision;
• use or weigh that information as part of the decision-making process; or
• communicate their decision by any means.

The fact that a person can retain information only for a short period does not automatically mean that they are unable to make the decision.

There must be a causal connection between the impairment or disturbance of the mind or brain and the person’s inability to make the particular decision.

Where capacity is disputed or the decision is particularly complex or serious, appropriate specialist professional input must be sought.

The person assessing capacity must record:

• the specific decision being assessed;
• why an assessment was required;
• the practicable steps taken to support the person to decide;
• the relevant information provided to the person;
• evidence relating to the impairment or disturbance of mind or brain;
• how the person’s ability to understand, retain, use or weigh information and communicate the decision was assessed;
• the conclusion reached;
• the reasons and evidence supporting that conclusion; and
• whether capacity is likely to fluctuate or improve and, if so, whether the decision can reasonably be delayed.

The conclusion that a person lacks capacity must be established on the balance of probabilities.

6. Best Interests Decision-Making

Where it has been established that a person lacks capacity to make a specific decision, any decision made or act carried out on their behalf under the Mental Capacity Act 2005 must be in their best interests.

The person making the decision must consider all relevant circumstances and must not determine best interests merely on the basis of the person’s age, appearance, condition or behaviour.

The decision-maker must:

• identify clearly the decision that needs to be made;
• consider whether the person is likely to regain capacity in relation to the matter and, where appropriate, whether the decision can reasonably be delayed until the person can decide for themselves;
• permit and encourage the person to participate as fully as reasonably practicable in the decision;
• consider the person’s past and present wishes and feelings, including any relevant written statement made when the person had capacity;
• consider the person’s beliefs and values that would be likely to influence their decision if they had capacity;
• consider other factors that the person would be likely to consider if able to do so;
• consider all reasonably available options;
• consider whether the intended outcome can be achieved in a less restrictive way; and
• record the reasoning demonstrating why the final decision is considered to be in the person’s best interests.

Where it is practicable and appropriate, the decision-maker must take into account the views of:

• anyone the person previously named as someone to be consulted;
• anyone engaged in caring for the person or interested in their welfare;
• an attorney acting under a valid and applicable Lasting Power of Attorney; and
• a deputy appointed by the Court of Protection whose authority covers the decision concerned.

Family members and next of kin must be consulted where appropriate but do not have an automatic legal right to make decisions for an adult who lacks capacity.

Where the statutory requirements for an Independent Mental Capacity Advocate apply, the responsible NHS body or local authority must be alerted so that an IMCA can be instructed as required by law. Staff must cooperate fully with an appointed IMCA and provide information necessary for the IMCA to carry out their statutory function, subject to applicable legal requirements.

For significant, complex or disputed decisions, a formal best-interests meeting should be convened where appropriate and the participants, evidence considered, options considered, views expressed, decision and rationale must be recorded.

Where there is a serious unresolved dispute about the person’s capacity or best interests which cannot appropriately be resolved through discussion, mediation, advocacy or professional consultation, advice must be obtained regarding referral to the Court of Protection.

Where the decision concerns life-sustaining treatment, the decision-maker must not be motivated by a desire to bring about the person’s death.

7. Lasting Powers of Attorney, Deputies, Advance Decisions and the Court of Protection

Before relying on another person’s claimed legal authority to make a decision for a person using the service, {{org_field_name}} must verify the nature and scope of that authority.

Lasting Power of Attorney

Where a person has appointed an attorney under a registered Health and Welfare Lasting Power of Attorney:

• the LPA must be verified;
• staff must identify the decisions covered by the attorney’s authority;
• the attorney may only make a decision within the scope of the authority granted;
• the attorney must act in accordance with the Mental Capacity Act 2005 and in the person’s best interests;
• a Health and Welfare attorney cannot override a decision made by the person while the person has capacity to make that decision; and
• an attorney may only consent to or refuse life-sustaining treatment where the LPA expressly gives the attorney authority to make decisions about life-sustaining treatment.

A Property and Financial Affairs LPA does not, by itself, give the attorney authority to make health and welfare decisions.

Court-appointed deputies

Where the Court of Protection has appointed a deputy:

• the court order must be checked;
• the deputy’s authority must be identified;
• the deputy must act only within the powers granted by the Court of Protection; and
• staff must not assume that a deputy has authority over a matter that is not covered by the court order.

Advance Decisions to Refuse Treatment

A valid and applicable Advance Decision to Refuse Treatment has legal effect and must be respected.

Where an Advance Decision relates to life-sustaining treatment, additional statutory requirements apply. It must be in writing, signed and witnessed and must contain an express statement that the decision is to apply even if life is at risk.

Where there is uncertainty about the existence, validity or applicability of an Advance Decision, urgent clinical and/or legal advice must be sought before proceeding, unless immediate action is lawfully required to provide treatment that cannot safely be delayed while the issue is resolved.

Copies or records of verified LPAs, deputyship orders and Advance Decisions relevant to the person’s care must be readily accessible to staff who require the information.

Court of Protection

The Court of Protection may determine questions concerning capacity or best interests, make decisions on behalf of a person who lacks capacity and appoint deputies.

Where there is an unresolved dispute about capacity, serious medical treatment, residence, care arrangements, contact, deprivation of liberty or another significant welfare matter that requires determination by the Court, the Registered Manager must ensure that the matter is escalated to the appropriate responsible body and appropriate legal advice is obtained.

8. Deprivation of Liberty Safeguards

The Deprivation of Liberty Safeguards form part of the Mental Capacity Act 2005 and provide a legal process for authorising a deprivation of liberty in a care home or hospital for an adult aged 18 or over who satisfies the statutory qualifying requirements.

A deprivation of liberty must not be identified solely by applying the former Cheshire West “acid test” of continuous supervision and control and not being free to leave.

Following the Supreme Court judgment of 2 June 2026 in A Reference by the Attorney General for Northern Ireland [2026] UKSC 16, whether arrangements amount to a deprivation of liberty requires a person-specific, multifactorial assessment.

The starting point must be the actual situation of the individual concerned. Staff and managers must consider, as relevant:

• the nature and type of restrictions imposed;
• the duration of the restrictions;
• the effects of those restrictions on the individual;
• the manner in which the restrictions are implemented;
• the extent to which the person objects to the arrangements;
• attempts by the person to leave;
• verbal and non-verbal indications that the person is unhappy or resisting the arrangements;
• refusals or physical rejection of care or treatment;
• whether physical restraint or intensive supervision is used;
• whether sedating or covert medication affects the person’s ability to express their wishes or objections;
• how far the circumstances are removed from ordinary restrictions encountered in everyday life;
• the relative normality of the person’s living arrangements; and
• the purpose and context of the arrangements.

No single factor is determinative.

The person’s wishes and feelings must be actively identified. Compliance must not automatically be treated as consent. Staff must consider what the person understands and wants and must provide all reasonably practicable communication support required to enable the person to express their wishes and feelings.

For the specific purpose of determining whether there is a deprivation of liberty under Article 5 of the European Convention on Human Rights, the Supreme Court has established that a person who lacks mental capacity under the Mental Capacity Act 2005 in relation to their care and residence may nevertheless, in some circumstances, be capable of giving valid consent to confinement through their current wishes and feelings. This is a distinct legal issue from consent to care and treatment under Regulation 11 and the Mental Capacity Act 2005.

Staff must not use this Article 5 concept of valid consent as a substitute for the Mental Capacity Act requirements governing capacity and consent to care and treatment.

Where there is serious doubt about whether the person consents to the arrangements, no conclusion of valid consent to confinement should be drawn.

Where there is doubt about whether arrangements amount to a deprivation of liberty, where the person fluctuates between appearing content and objecting, where restrictions are significant, or where Article 5 may be engaged, the matter must be escalated immediately to the Registered Manager and a referral must be made to the appropriate local authority for consideration under the DoLS process.

Where a deprivation of liberty in the care home may be required, the care home, as managing authority, must request a standard authorisation from the appropriate supervisory body in accordance with Schedule A1 to the Mental Capacity Act 2005.

Where the legal requirements for an urgent authorisation are met and the deprivation needs to begin before the standard authorisation process can be completed, the managing authority must follow the statutory urgent authorisation procedure. An urgent authorisation must be in writing and must not exceed seven days unless lawfully extended by the supervisory body in accordance with Schedule A1.

The care home must:

• maintain accurate records of all DoLS requests and authorisations;
• comply with any conditions attached to an authorisation;
• ensure relevant staff know about the authorisation and its conditions;
• monitor whether the arrangements remain necessary and proportionate;
• reduce restrictions where they are no longer required;
• request a review where the statutory grounds for review arise;
• support the person’s access to their Relevant Person’s Representative and any appointed Independent Mental Capacity Advocate;
• support the person to exercise their right to challenge an authorisation through the Court of Protection;
• ensure that the person’s wishes and feelings continue to be considered; and
• avoid treating a DoLS authorisation as authority for restrictions or treatment outside its lawful scope.

Existing DoLS authorisations must not automatically be cancelled solely because of the June 2026 Supreme Court judgment. Where it appears that the person may no longer be deprived of their liberty under the revised legal test, the Registered Manager must liaise with the supervisory body regarding review of the person’s circumstances.

Where a deprivation of liberty may arise outside a care home or hospital, the DoLS care-home authorisation procedure does not apply and appropriate advice must be sought regarding authorisation through the Court of Protection or other applicable legal mechanism.

8.1 Restrictive Practice and Restraint

{{org_field_name}} must ensure that restraint or other restrictive practices are not used unless there is a lawful justification for their use.

For a person who lacks capacity in relation to the matter, any restraint carried out in reliance on the Mental Capacity Act 2005 must:

• be connected with an act that is in the person’s best interests;
• be necessary to prevent harm to the person; and
• be a proportionate response to the likelihood and seriousness of that harm.

Restrictive practices must not be used for punishment, staff convenience, coercion or because there are insufficient staff or resources.

Before using a restrictive intervention, staff must consider whether the intended purpose can be achieved safely in a less restrictive way.

Restrictive practices may include, depending on the circumstances:

• physical restraint;
• physical intervention;
• restrictions on leaving the building or particular areas;
• locked doors;
• continuous or intensive supervision;
• restrictions on contact or activities;
• bedrails or equipment that prevents free movement;
• restrictions relating to mobility aids;
• covert medication;
• sedating medication used to control behaviour; and
• technological monitoring or other measures that significantly restrict freedom.

The cumulative effect of individual restrictions must also be considered when determining whether arrangements may amount to a deprivation of liberty.

Any restraint or significant restrictive practice must be:

• based on an individual assessment;
• clearly justified;
• the least restrictive reasonably available option;
• used for no longer than necessary;
• recorded accurately;
• incorporated into the person’s care and risk-management arrangements where ongoing;
• regularly reviewed; and
• escalated for consideration of a deprivation-of-liberty authorisation where the overall arrangements may amount to a deprivation of liberty.

Where restraint or restrictive practice is suspected to be unnecessary, disproportionate, degrading, abusive or otherwise unlawful, staff must take immediate action to safeguard the person and report the concern in accordance with the service’s safeguarding, incident-reporting and whistleblowing procedures.

9. Roles and Responsibilities in Implementing the Mental Capacity Act

All staff must:

• presume that a person has capacity unless it is established otherwise in relation to the specific decision concerned;
• support people to make their own decisions;
• recognise that an unwise decision does not, by itself, establish lack of capacity;
• obtain and respect valid consent;
• respect a person’s right to refuse or withdraw consent where they have capacity to do so;
• follow documented capacity assessments and best-interests decisions relevant to their role;
• recognise and report changes or fluctuations in capacity;
• identify and report restrictive practices;
• recognise circumstances that may amount to a deprivation of liberty;
• comply with any applicable DoLS authorisation and its conditions;
• respect valid and applicable Advance Decisions and the lawful authority of attorneys and deputies; and
• escalate concerns where they believe that a person’s rights under the Mental Capacity Act may not be being respected.

The person responsible for the particular decision or action must:

• determine whether there is a proper reason to assess capacity;
• ensure all practicable steps are taken to support the person to decide;
• assess capacity or arrange an appropriate assessment where required;
• ensure that the assessment is decision-specific and time-specific;
• document the assessment and evidence supporting the conclusion;
• where the person lacks capacity, ensure that any decision made on their behalf follows the statutory best-interests process; and
• seek specialist, multidisciplinary or legal advice where required by the complexity or seriousness of the matter.

Senior staff must:

• support staff to apply the Mental Capacity Act correctly;
• escalate complex or disputed matters;
• ensure restrictive practices are appropriately authorised, recorded and reviewed;
• monitor changes in people’s capacity and care arrangements; and
• ensure concerns about possible deprivation of liberty are promptly escalated.

The Registered Manager must:

• ensure that this policy is implemented;
• ensure that staff receive appropriate training and support;
• maintain oversight of significant capacity and best-interests decisions;
• maintain oversight of restrictive practices and DoLS;
• ensure that DoLS applications and reviews are made when required;
• ensure that conditions attached to DoLS authorisations are implemented;
• ensure required statutory notifications are submitted to CQC;
• ensure that unresolved disputes are escalated appropriately; and
• monitor compliance through governance, audits and review.

10. Recording, Documentation and CQC Notifications

Records relating to mental capacity and best-interests decision-making must be accurate, complete, contemporaneous and sufficiently detailed to demonstrate how the requirements of the Mental Capacity Act 2005 have been applied.

Where applicable, records must include:

• the specific decision concerned;
• the person’s consent;
• reasons for questioning capacity;
• all practicable steps taken to support the person to decide;
• the capacity assessment and evidence supporting its conclusion;
• whether capacity may fluctuate or improve;
• the best-interests decision-making process;
• the person’s participation;
• the person’s past and present wishes and feelings;
• relevant beliefs and values;
• people consulted and the views they expressed;
• alternatives and less restrictive options considered;
• the final decision and reasons for reaching it;
• any disagreement or dispute and how this was managed;
• details of restrictive interventions;
• the legal basis relied upon for care or treatment where the person cannot consent;
• relevant Advance Decisions;
• verified Lasting Powers of Attorney;
• relevant Court of Protection orders or deputyship orders;
• IMCA involvement where applicable;
• DoLS applications;
• urgent authorisations;
• standard authorisations;
• conditions attached to authorisations;
• reviews and requests for reviews;
• Relevant Person’s Representative details; and
• action taken to comply with an authorisation and its conditions.

Capacity assessments and best-interests decisions must be reviewed where the decision needs to be reconsidered, where circumstances materially change, where there is evidence that the person’s capacity may have changed or where new information becomes available.

A capacity assessment must not be treated as a permanent or blanket determination of incapacity.

CQC notification of deprivation-of-liberty outcomes

The Registered Manager must ensure that CQC is notified, in accordance with the Care Quality Commission (Registration) Regulations 2009 and current CQC notification requirements, as soon as the service knows:

• the outcome of an application to deprive a person of their liberty;
• the outcome of a relevant application to the Court of Protection concerning deprivation of liberty; or
• that such an application has been withdrawn.

CQC must not be notified merely because a DoLS application has been submitted. The notification requirement relates to the outcome or withdrawal of the application.

Evidence of the CQC notification and its submission must be retained.

Any dispute or significant concern regarding capacity, consent, best interests, restraint or deprivation of liberty must be escalated promptly to the Registered Manager.

11. Training and Competency

All staff whose roles involve providing care, treatment or support to people using the service must receive Mental Capacity Act training appropriate to their role.

Training must cover, as applicable:

• the five statutory principles of the Mental Capacity Act 2005;
• obtaining and recording consent;
• supporting people to make their own decisions;
• decision-specific and time-specific assessment of capacity;
• the statutory capacity test;
• best-interests decision-making;
• consultation requirements;
• Lasting Powers of Attorney;
• Court of Protection deputies and orders;
• Advance Decisions to Refuse Treatment;
• Independent Mental Capacity Advocacy;
• restrictive practices and restraint;
• recognising a potential deprivation of liberty;
• the current legal test for deprivation of liberty following the Supreme Court judgment of 2 June 2026;
• the DoLS application, urgent authorisation and review processes;
• the rights of people subject to DoLS;
• CQC notification requirements relating to DoLS outcomes; and
• recording, escalation and safeguarding requirements.

Staff who undertake or are responsible for capacity assessments or best-interests decisions must have sufficient knowledge, skills and competence for the decisions for which they are responsible. Specialist advice or assessment must be obtained where the complexity or seriousness of the decision requires it.

Mental Capacity Act training will be refreshed annually and additionally where significant legislation, case law, statutory guidance or CQC requirements change.

Competence must not be established solely by completion of training. Managers must monitor the application of the Mental Capacity Act in practice through appropriate supervision, discussion, observation, case review and audit.

12. Safeguarding, Concerns and Complaints

Any concern that a person is being subjected to unlawful, unnecessary or disproportionate restraint, coercion, control, restriction or deprivation of liberty must be taken seriously and acted upon immediately.

Where there is reason to suspect abuse, neglect, improper treatment or unlawful restriction, staff must:

• take immediate action to protect the person from avoidable harm;
• report the concern to the Registered Manager or designated safeguarding lead without delay;
• follow the service’s safeguarding procedures;
• make or support a referral to the relevant local authority safeguarding team where the Care Act 2014 safeguarding criteria are met;
• preserve relevant records and evidence;
• consider whether police or another statutory body must be informed; and
• make any notification to CQC or another regulator that is legally required.

A safeguarding concern must not be dismissed solely because a restrictive practice is recorded in a care plan or because a DoLS authorisation exists. The actual practice must remain lawful, necessary, proportionate and within the scope of any applicable legal authority.

People using the service, their representatives and others acting on their behalf must have access to the service’s complaints procedure and must be supported to raise concerns without fear of discrimination or disadvantage.

Complaints or concerns relating to capacity, consent, best interests, restraint or deprivation of liberty must be investigated and responded to in accordance with the organisation’s complaints and safeguarding procedures, and any required action must be implemented and monitored.

13. Policy Review

This policy will be formally reviewed at least annually and sooner where necessary.

An earlier review must take place where there is:

• a relevant change to legislation or regulations;
• significant new or amended statutory guidance;
• relevant case law affecting the Mental Capacity Act, consent, restraint or deprivation of liberty;
• a material change to CQC requirements or guidance;
• a safeguarding incident or regulatory finding indicating that this policy may be inadequate;
• a significant complaint or legal challenge;
• an internal audit finding requiring amendment; or
• evidence that staff practice is not consistent with the requirements of this policy.

The Registered Manager must ensure that significant legal or regulatory changes are communicated to staff promptly and must not delay necessary changes to practice until the next scheduled annual policy review.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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