{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

---

Verification of Expected Deaths by Registered Nurses Policy

1. Purpose

The purpose of this policy is to establish clear guidelines for the verification of expected deaths by registered nurses within {{org_field_name}}, ensuring compliance with the latest Care Inspectorate Wales (CIW) regulations, the Regulation and Inspection of Social Care (Wales) Act 2016, and best practice guidelines from professional nursing and healthcare bodies. This policy aims to provide a structured approach to verifying expected deaths in a dignified, lawful, and sensitive manner, ensuring the needs of residents, families, and staff are met while maintaining regulatory compliance.

2. Scope

This policy applies to the verification of an expected death of an adult resident aged 18 years or over within {{org_field_name}} by a registered nurse who:

• holds current registration with the Nursing and Midwifery Council (NMC);
• has completed appropriate education and training in verification of expected adult death;
• has been formally assessed and recorded as competent to undertake verification of expected adult death;
• is working within their professional competence and the NMC Code; and
• is authorised to undertake verification of expected adult death under {{org_field_name}}’s clinical governance arrangements and any applicable local agreement or pathway with the relevant NHS body, GP practice or other healthcare provider.

This policy applies only where the death is expected and the circumstances meet the criteria set out in this policy.

Verification of death confirms that death has occurred. It does not determine or certify the medical cause of death and does not replace the statutory death-certification process.

Where the service provides accommodation to a child under the age of 18, the death of that child must be managed under the applicable child-death procedures and statutory notification arrangements. This adult verification procedure must not be applied to a child unless there is separate, specific clinical governance authority and an applicable professional or local protocol permitting this.

3. Related Policies

This policy should be read in conjunction with:

• CHW38 – End of Life and Palliative Care Policy: Ensuring dignified care in the final stages of life.
• CHW11 – Safe Care and Treatment Policy: Supporting clinical governance in resident care.
• CHW36 – Communication and Engagement with Service Users and Families Policy: Ensuring effective communication with families and carers.
• CHW25 – Notification of Other Incidents Policy: Outlining reporting requirements following a death.
• CHW18 – Risk Management and Assessment Policy: Managing risk and ensuring appropriate responses to expected deaths.

4. Policy Statement

{{org_field_name}} is committed to ensuring that the verification of expected deaths by registered nurses is conducted in a professional, compassionate, and legally compliant manner. Our approach is designed to provide reassurance to families, ensure respect and dignity for the deceased, and maintain accurate records for regulatory compliance. This policy supports timely and appropriate verification while working in collaboration with general practitioners (GPs) and other healthcare professionals.

5. Definition of Expected Death and Distinction Between Verification and Certification

An expected death is a death which is anticipated as a consequence of a recognised and irreversible illness, frailty or clinical condition and for which appropriate advance clinical assessment and end-of-life planning have taken place.

Verification of death is the clinical process of establishing and formally recording that death has occurred. A registered nurse may verify an expected adult death where the nurse has been assessed as competent, the circumstances meet this policy and the activity is permitted under the organisation’s clinical governance arrangements and applicable local agreement.

Verification of death is separate from medical certification of the cause of death. A registered nurse verifying death must not complete the Medical Certificate of Cause of Death (MCCD) or determine the medical cause of death unless separately legally authorised to do so in another professional capacity.

Since 9 September 2024, every death in England and Wales is subject to independent scrutiny. A death which is not investigated by a coroner will normally be scrutinised through the statutory Medical Examiner system. The attending medical practitioner and Medical Examiner will complete the applicable statutory death-certification process before the relevant information is sent to the registrar.

6. Criteria for Registered Nurse Verification of an Expected Adult Death

A registered nurse may verify an expected adult death only where all applicable criteria below are satisfied:

• The identity of the resident can be confirmed reliably against the resident’s care and clinical records.
• The resident is aged 18 years or over.
• The resident’s death was clinically anticipated and there is sufficient documented clinical information to demonstrate that the death is expected.
• The resident’s current personal plan, end-of-life documentation and available clinical records have been reviewed before verification.
• Any applicable advance care planning documentation, including any current DNACPR decision, has been checked. The absence of a DNACPR form does not, by itself, establish that verification cannot occur; however, where no DNACPR decision is available, there must be clear clinical justification that death is irreversible and that resuscitation is not indicated in the circumstances.
• The registered nurse holds current NMC registration.
• The registered nurse has completed appropriate education and training and has been formally assessed as competent to undertake verification of expected adult death.
• The registered nurse is authorised to undertake the procedure under {{org_field_name}}’s clinical governance arrangements and any applicable local agreement or pathway.
• There are no new, unexplained or suspicious circumstances associated with the death.
• There are no findings which cause the registered nurse to doubt that the death is expected.
• The registered nurse has considered relevant risks associated with infection, radioactive implants and implantable medical devices.
• Any implantable cardioverter-defibrillator (ICD) has been identified and appropriate action for deactivation has been undertaken or initiated where required.
• There is no known information indicating that the body must be preserved without disturbance for a police or coroner investigation.

The registered nurse must not proceed with verification under this procedure where:

• there is any doubt that death has occurred;
• the circumstances are unexpected, unexplained or suspicious;
• there is evidence of new or unexplained trauma, injury, bruising, unusual markings or other findings which may require investigation;
• there is uncertainty as to the resident’s identity;
• the death is associated with circumstances requiring immediate police involvement; or
• the nurse considers that the situation is outside their competence or the scope of the applicable local agreement.

Where any of these circumstances apply, the nurse must follow the emergency, medical, police, safeguarding and/or coroner escalation pathway appropriate to the circumstances and must not alter, remove or unnecessarily disturb equipment or the body where this could compromise an investigation.

7. Procedure for Verification of an Expected Adult Death

7.1 Initial checks and preparation

Before commencing verification, the registered nurse must:

• confirm the identity of the resident against available care and clinical documentation;
• review the resident’s personal plan and relevant end-of-life and clinical records;
• confirm that the death was expected and that nurse verification is permitted under the applicable local agreement and clinical governance arrangements;
• establish whether a current DNACPR decision or equivalent clinical decision is available and review it where relevant;
• undertake an immediate assessment of the circumstances surrounding the death;
• consider whether there are any new, unusual, unexplained or suspicious findings;
• identify any known or suspected infectious disease;
• identify any implantable medical device, including an implantable cardioverter-defibrillator, and any known radioactive implant;
• use appropriate standard infection prevention and control precautions; and
• ensure the privacy, dignity, cultural, spiritual and religious needs of the resident and those important to them are respected so far as reasonably practicable.

Where suspicious or unexplained circumstances are identified, the nurse must stop the expected-death verification procedure, avoid unnecessary disturbance of the resident or the immediate environment and follow the appropriate police, medical, safeguarding and/or coroner escalation procedure.

Current professional guidance specifically requires consideration of suspicious circumstances before expected-death verification and identifies infection risks, implantable devices and radioactive implants as matters which must be considered.

7.2 Verification examination

The registered nurse must undertake the examination systematically and must observe the resident for a continuous minimum period of five minutes to establish that irreversible cardio-respiratory arrest has occurred.

During the examination the nurse must establish:

• absence of a central pulse on palpation for at least one minute;
• absence of heart sounds on auscultation for at least one minute;
• absence of spontaneous respiratory effort throughout the five-minute observation period;
• absence of pupillary response to light in both eyes; and
• after five minutes of continued cardio-respiratory arrest, absence of motor response to an appropriate stimulus, such as a trapezius squeeze, or absence of cerebral response using an appropriate recognised technique in accordance with current professional guidance.

If spontaneous cardiac or respiratory activity occurs at any point during the observation period, the five-minute observation period must recommence.

If the registered nurse has any doubt about the findings or whether death can properly be verified, they must not declare verification complete and must seek advice from an appropriate medical practitioner or emergency clinical service.

Where non-invasive ventilation or other equipment could produce apparent chest movement, the registered nurse must take account of the effect of that equipment and follow current professional and local clinical guidance before completing verification.

7.3 Official time of death

The official time of death recorded by the registered nurse must be the time at which the verification examination is completed.

Where family members or other persons witnessed the resident’s last breath at an earlier time, that information may be recorded separately as an observed or reported time, but it must not replace the formal time of verification.

7.4 Documentation

Immediately following verification, the registered nurse must complete the organisation’s Verification of Expected Adult Death documentation and make an accurate contemporaneous entry in the resident’s records.

The record must include, as applicable:

• the resident’s full name;
• date of birth and other appropriate identifying information;
• date and location of verification;
• the time the verification examination commenced;
• the official time of death, being the time verification was completed;
• confirmation that the death was expected;
• the clinical findings used to verify death;
• confirmation that the five-minute observation requirement was completed;
• relevant information concerning infection risks;
• details of any implantable medical device or radioactive implant identified;
• relevant actions taken concerning an implantable cardioverter-defibrillator;
• any unusual findings and action taken;
• the name, professional designation and NMC PIN or other identifier of the registered nurse, where required by local documentation;
• persons notified;
• communication with the resident’s family or representative; and
• any escalation, advice or referral undertaken.

Records must be accurate, contemporaneous, secure and managed in accordance with applicable data protection and statutory record-keeping requirements.

7.5 Notification to the attending medical practitioner and Medical Examiner pathway

The registered nurse must notify the relevant GP, attending medical practitioner or healthcare service of the death in accordance with the agreed local pathway, providing the date and official time of verification and other information reasonably required.

The registered nurse must not advise the family that the GP will automatically issue the MCCD.

The statutory process applicable since 9 September 2024 requires every death to receive independent scrutiny. Where the death is not investigated by a coroner, the relevant attending medical practitioner and statutory Medical Examiner service will undertake the applicable death-certification and independent scrutiny process.

The service must co-operate with reasonable requests from the attending medical practitioner and Medical Examiner service and ensure that relevant records and information are made available through appropriate lawful arrangements.

7.6 Where a coroner or police referral may be required

Where the circumstances of the death are unexpected, unexplained, suspicious or otherwise raise concern, the registered nurse must not assume that the death can proceed through the routine expected-death pathway.

The nurse must immediately follow the applicable local escalation procedure, which may include contact with:

• an attending medical practitioner or out-of-hours medical service;
• the police;
• the local safeguarding authority; and/or
• other relevant statutory services.

The statutory decision as to whether a death requires investigation by a coroner must be dealt with through the applicable legal death-notification and coroner arrangements. Staff must preserve potential evidence and avoid unnecessary disturbance of the body or equipment where an investigation may be required.

7.7 Family and representative communication

The registered nurse or other appropriate staff member must:

• communicate the death sensitively and compassionately;
• explain, in clear language, what will happen next;
• explain that verification of death and medical certification of the cause of death are separate processes;
• avoid promising when death-registration documentation will be available;
• explain, where appropriate, that the death may need to be considered by the Medical Examiner or coroner before registration can proceed;
• take account of the resident’s and family’s recorded cultural, religious and spiritual wishes;
• provide information about bereavement support and practical next steps; and
• record significant communication with the family or representative.

7.8 Care after death

Care after death must not commence until verification has taken place unless immediate action is necessary for safety.

Where there is any possibility that the death may require police or coroner investigation, tubes, lines, drains, medication patches, pumps or other devices must not be removed unless instructed by an authorised person or unless immediate safety requires otherwise.

Where the death is proceeding through the expected non-coronial pathway, care after death must be undertaken in accordance with the organisation’s applicable procedure, the resident’s wishes and current professional guidance.

8. Clinical Governance, Competence and Monitoring

{{org_field_name}} will maintain effective clinical governance arrangements for registered nurse verification of expected adult death.

These arrangements must include:

• a clear written policy defining when registered nurse verification may and may not be undertaken;
• an applicable local agreement or pathway with relevant NHS, primary care or other healthcare partners where required;
• initial education and training appropriate to verification of expected adult death;
• formal assessment and documented sign-off of competence before a registered nurse undertakes verification independently;
• access to appropriate equipment, including a functioning stethoscope, pen torch and reliable means of timing the examination;
• arrangements for registered nurses to seek timely medical advice where there is doubt or uncertainty;
• arrangements for registered nurses to maintain their knowledge and competence through continuing professional development, reflection, supervision and review;
• maintenance of a record of authorised and competent registered nurses;
• periodic review of verification documentation and practice as part of the service’s quality assurance and clinical governance arrangements; and
• prompt action where an incident, error, concern or change in national guidance identifies a need to revise practice.

9. Responsibilities

Service Provider

The service provider is responsible for ensuring that:

• registered nurse verification of expected adult death is undertaken only where compatible with the service’s Statement of Purpose and clinical governance arrangements;
• an appropriate policy, procedure and local clinical pathway are in place and kept up to date;
• only suitably qualified, trained, skilled, competent and experienced registered nurses undertake verification;
• sufficient equipment and resources are available;
• relevant deaths and other notifiable events are reported to Care Inspectorate Wales in accordance with Regulation 60 and Schedule 3 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended; and
• systems are in place to monitor compliance and address identified risks or deficiencies.

Responsible Individual

The Responsible Individual must maintain appropriate oversight of the service’s governance and compliance arrangements and satisfy themselves that this policy is being implemented effectively.

Registered Manager

The Registered Manager is responsible for:

• implementing this policy within the service;
• confirming that appropriate local agreements and escalation arrangements are available;
• maintaining evidence of staff training and competency;
• ensuring staff have access to current policies and clinical guidance;
• ensuring verification records and related notifications are completed appropriately;
• ensuring incidents or concerns are investigated and learning is implemented; and
• escalating clinical governance or regulatory concerns to the service provider and Responsible Individual.

Registered Nurses

A registered nurse undertaking verification is professionally accountable for their own practice and must:

• maintain current NMC registration;
• undertake verification only where trained, assessed as competent and authorised to do so;
• work within the limits of their competence;
• establish that the circumstances meet this policy before commencing verification;
• undertake and document the clinical examination correctly;
• seek medical or other appropriate assistance where there is uncertainty;
• identify and act upon unexpected, unexplained or suspicious circumstances;
• communicate sensitively with family members and representatives;
• complete accurate contemporaneous records; and
• participate in competency review, supervision and continuing professional development.

Attending Medical Practitioner and Medical Examiner

The registered nurse’s verification does not transfer responsibility for certification of the medical cause of death to the nurse.

The relevant attending medical practitioner and statutory Medical Examiner service are responsible for their respective functions within the death-certification and independent scrutiny process. Where the death requires investigation by a coroner, the applicable coroner process takes precedence.

10. Statutory and CIW Notifications Following a Death

The death of a resident accommodated as part of a care home service is a notifiable event under the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended.

In accordance with Regulation 60 and Schedule 3, the service provider must notify Care Inspectorate Wales of:

• the death of an individual for whom accommodation is provided; and
• the circumstances of the death.

The notification must:

• be made without delay;
• normally be made within 24 hours of the event in accordance with CIW statutory guidance;
• be made in writing;
• contain sufficient details of the event and circumstances; and
• be submitted in the manner and form required by CIW, currently through the applicable CIW Online notification process.

The Registered Manager must ensure that responsibility for submitting the notification is clearly allocated and that evidence of submission is retained.

A CIW notification is separate from:

• notification to the resident’s GP or attending medical practitioner;
• the statutory Medical Examiner process;
• any notification or referral to the coroner;
• any police notification;
• any safeguarding referral;
• notification to commissioners or placing authorities where required; and
• communication with the resident’s family or representative.

Where the circumstances of the death also meet another statutory notification threshold, all applicable notifications must be completed. Making one notification does not remove the requirement to make another notification to a different statutory body where required.

11. Medical Examiner and Statutory Death-Certification Process

Verification of death by a registered nurse confirms only that death has occurred. It does not certify the medical cause of death.

From 9 September 2024, every death in England and Wales must receive independent scrutiny through one of two statutory routes:

• investigation or consideration through the coroner system where applicable; or
• independent scrutiny by a statutory Medical Examiner where the death does not require coroner investigation.

For a non-coronial death, the attending medical practitioner will, where able to do so under the applicable legislation, propose the medical cause of death. The Medical Examiner will independently scrutinise the cause and circumstances of the death and engage with the bereaved as required by the statutory process.

Following completion of the appropriate scrutiny and certification process, the relevant medical certificate information is transmitted to the registrar in accordance with the statutory process.

Staff of {{org_field_name}} must:

• promptly notify the appropriate medical practitioner or healthcare service of the resident’s death in accordance with the agreed local pathway;
• make relevant care and clinical records available lawfully and promptly where required for Medical Examiner scrutiny;
• co-operate with reasonable enquiries concerning the resident’s care and circumstances of death;
• provide accurate information about implantable medical devices where known;
• escalate any concerns about the circumstances of death through the appropriate clinical, safeguarding, police or coroner pathway; and
• explain to families that the verification of death undertaken in the care home is separate from the subsequent statutory certification, scrutiny and registration processes.

Staff must not guarantee that an MCCD will be issued, state that the death will not be referred to a coroner, or advise a family that they may register the death until the appropriate statutory process has confirmed the next steps.

12. Policy Review

This policy will be reviewed annually or updated in response to changes in legislation, CIW requirements, or professional guidance. Any amendments will be communicated to all staff to ensure continued compliance and high standards of care.

---

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}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.