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Registration Number: {{org_field_registration_no}}

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Verification of Expected Deaths by Registered Nurses Policy

1. Purpose

The purpose of this policy is to provide clear guidance on the verification of expected deaths by registered nurses working for {{org_field_name}}. This policy ensures that the verification process is carried out safely, legally, and in line with professional standards, while maintaining dignity, sensitivity, and respect for the deceased and their family.

This policy is written in accordance with the Regulation and Inspection of Social Care (Wales) Act 2016, the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, the Welsh Government statutory guidance for regulated services, Care Inspectorate Wales requirements, the Nursing and Midwifery Council Code, the Mental Capacity Act 2005 where relevant, the Social Services and Well-being (Wales) Act 2014 safeguarding framework, the Wales Safeguarding Procedures, and current national guidance on verification of death and death certification in England and Wales.

This policy recognises the statutory Medical Examiner system introduced in England and Wales from 9 September 2024. All deaths that are not investigated by a coroner must receive independent scrutiny by a Medical Examiner before registration. Verification of death by a competent registered nurse confirms that death has occurred; it does not certify the cause of death and does not replace the responsibilities of the attending medical practitioner, Medical Examiner, registrar, or coroner.

2. Scope

This policy applies to:

• Registered nurses employed by {{org_field_name}} who have been assessed as competent to verify expected deaths.
• Service users receiving palliative or end-of-life care where death is anticipated and managed under an agreed care plan.
• Care staff, family members, and other professionals who may be present at the time of death.
• GPs, emergency services, and other external professionals involved in the verification and certification process.

This policy applies only where the verification of expected death by registered nurses is included within {{org_field_name}}’s Statement of Purpose, contractual arrangements, clinical governance arrangements, and insurance/indemnity cover. If {{org_field_name}} does not employ or engage registered nurses to provide this function, care staff must not verify death and must follow the escalation procedure in this policy by contacting the GP, out-of-hours service, district nursing service, emergency services, or other relevant clinician as appropriate.

Where {{org_field_name}} introduces, withdraws, or materially changes the provision of nurse-led verification of expected death, the Registered Manager and Responsible Individual must review whether the Statement of Purpose requires amendment and whether CIW must be notified before the change is implemented.

It covers:

• The legal distinction between verification and certification of death.
• Criteria for expected deaths.
• Verification procedures and required documentation.
• Communication with families and healthcare professionals.
• Escalation procedures in cases of uncertainty.
• Staff training, competency, and governance.

3. Principles of Verification of Expected Deaths

3.1 Legal and Professional Status of Verification of Death

Verification of death is the clinical confirmation that life has ended. It may be undertaken by a registered nurse only where the nurse is competent, trained, authorised by {{org_field_name}}, acting within this policy, and acting within local health board, GP, palliative care, or end-of-life care arrangements where applicable.

Verification of death is not the same as certification of death. The registered nurse must not state or certify the medical cause of death, must not complete the Medical Certificate of Cause of Death, and must not advise the family that the death can be registered until the appropriate medical certification, Medical Examiner scrutiny, and registration processes have taken place.

Certification of the cause of death is completed by an attending medical practitioner where they are able to do so. Where the death is not investigated by a coroner, the Medical Examiner will scrutinise the proposed cause of death and the circumstances before the MCCD is sent to the registrar. Where the death is reportable to the coroner, the coroner will determine whether an investigation is required.

3.2 Definition of Expected and Unexpected Deaths

An expected death is a death that occurs as a result of a known, advanced, progressive, irreversible, or terminal condition where death was anticipated by an appropriate medical practitioner or specialist clinician and this is recorded in the person’s care records, advance care plan, palliative care plan, end-of-life care plan, or other relevant clinical record. The person’s personal plan must reflect their end-of-life wishes, preferred place of care, relevant contacts, DNACPR/ReSPECT or other clinical decision documentation where applicable, and the agreed actions to take when death occurs.

A DNACPR decision does not, by itself, mean that death is expected or that a registered nurse may verify death. The nurse must be satisfied that death was anticipated, that there is an agreed end-of-life plan, and that there are no suspicious, unexplained, traumatic, safeguarding, or coronial concerns.

An unexpected death is a death that is sudden, unexplained, not anticipated in the person’s care or clinical records, associated with an accident, fall, injury, choking, medication error, possible neglect, possible abuse, self-harm, violence, restraint, unlawful deprivation of liberty, or any other circumstance that may require police, safeguarding, emergency service, medical examiner, or coroner involvement.

Registered nurses must not verify an unexpected, suspicious, traumatic, or unexplained death under this policy. In such circumstances, staff must contact emergency services and follow the escalation, safeguarding, incident reporting, and evidence-preservation procedures in this policy.

3.3 Legal Distinction Between Verification, Certification, Medical Examiner Scrutiny and Registration

Verification of death is the process of confirming that death has occurred. A registered nurse may verify an expected death only where they are trained, competent, authorised by {{org_field_name}}, and acting within this policy and any applicable local health board or clinical protocol.

Certification of death is the process of stating the medical cause of death and completing the Medical Certificate of Cause of Death. This is undertaken by an attending medical practitioner where they are able to certify the cause of death. A registered nurse must not certify death, must not complete an MCCD, and must not give a medical cause of death to the family or representatives.

Medical Examiner scrutiny is required for deaths in England and Wales that are not investigated by a coroner. The Medical Examiner provides independent scrutiny of the proposed cause of death, considers whether coroner referral is required, and offers bereaved representatives an opportunity to raise questions or concerns. The MCCD is sent to the registrar after Medical Examiner scrutiny has been completed.

Registration of death is completed by the registrar following the appropriate certification and scrutiny process. Verification by a registered nurse does not authorise registration of the death.

3.4 Criteria for Registered Nurses to Verify an Expected Death

A registered nurse employed or formally engaged by {{org_field_name}} may verify an expected death only where all of the following apply:

• The nurse is currently registered with the Nursing and Midwifery Council and is working within their scope of competence.
• The nurse has completed training and competency assessment in verification of expected death and has been authorised by {{org_field_name}} to undertake this role.
• Verification of expected death is included within the service’s governance arrangements, insurance/indemnity arrangements, and, where relevant, Statement of Purpose.
• The death was expected and anticipated by an appropriate medical practitioner or specialist clinician.
• There is documented evidence in the person’s care record, personal plan, advance care plan, palliative care plan, end-of-life care plan, or clinical record that death was expected.
• The nurse has reviewed the person’s identity and relevant documentation before verification.
• There are no suspicious, unexplained, traumatic, safeguarding, neglect, abuse, medication, restraint, deprivation of liberty, accident, fall, choking, self-harm, or police-related concerns.
• There is no reason to believe that resuscitation should be attempted.
• There is no uncertainty about whether death has occurred.

3.5 Verification Procedure for an Expected Death

Step 1: Preparing for Verification

Before beginning verification, the registered nurse must:

• Confirm that it is safe and appropriate to enter the environment, including consideration of infection risks, environmental hazards, oxygen, medical devices, sharps, medicines, pets, other people present, and any potential police or safeguarding concerns.
• Confirm the identity of the deceased using at least two identifiers, such as full name, date of birth, address, NHS number, photograph, care record, medication record, family confirmation, or professional confirmation.
• Review the person’s care record, personal plan, advance care plan, palliative care plan, end-of-life care plan, DNACPR/ReSPECT or other clinical decision documentation where applicable.
• Confirm that death was expected and that verification by a registered nurse is permitted under this policy and any local clinical arrangement.
• Establish who is present, identify the next of kin or representative where possible, and communicate sensitively and respectfully.
• Explain that the nurse is verifying that death has occurred and is not certifying the medical cause of death.
• Stop the process and escalate immediately if any suspicious, unexplained, traumatic, safeguarding, or coronial concern becomes apparent.

Step 2: Clinical Verification of Death

The registered nurse must undertake a systematic clinical assessment to confirm the absence of signs of life, in accordance with current national and local guidance and the nurse’s verified competency. The assessment must include, as a minimum:

• No response to verbal stimuli.
• No response to appropriate physical stimuli.
• No observed respiratory effort.
• No breath sounds on auscultation.
• No central pulse on palpation.
• No heart sounds on auscultation.
• Fixed pupils with no response to light.
• No other signs of life.

The nurse must record the time that the verification assessment was completed. The recorded time of death must follow local clinical guidance and must distinguish, where relevant, between the time the person was found, the time staff were informed, the time verification commenced, and the time verification was completed.

If the nurse is uncertain whether death has occurred, or if any signs of life are present, the nurse must stop the verification process, call emergency services immediately, and commence or seek emergency clinical support unless there is a valid and applicable decision not to attempt cardiopulmonary resuscitation.

Step 3: Documentation

The registered nurse must complete the Verification of Expected Death Form and record the event in the person’s care record before the end of the shift, or sooner where required by local procedure. The record must include:

• Full name of the deceased.
• Date of birth.
• NHS number, where available.
• Address and exact location of death.
• Date and time the person was found, where known.
• Date and time staff were informed, where relevant.
• Date and time verification commenced.
• Date and time verification was completed.
• Name, role, NMC PIN, signature, and contact details of the verifying registered nurse.
• Evidence reviewed to confirm that death was expected.
• Identity checks completed.
• Clinical findings confirming absence of signs of life.
• Names and roles/relationship of people present.
• Details of family/representative communication.
• Details of GP, out-of-hours service, district nurse, palliative care team, medical examiner office, funeral director, police, emergency services, safeguarding team, CIW, commissioner, or other professionals contacted, including date, time, name of person spoken to, advice received, and actions agreed.
• Any relevant risks, including infection risk, implantable device, syringe driver, oxygen, medicines, controlled drugs, transdermal patches, medical equipment, or environmental concerns.
• Whether the body was moved, by whom, when, and why.
• Any reason verification was not completed and what escalation action was taken.

Records must be factual, contemporaneous, signed, dated, and retained in accordance with {{org_field_name}}’s record retention, confidentiality, data protection, safeguarding, and incident reporting procedures.

Step 4: Notifications and Communication After Verification

After verification of an expected death, the registered nurse must ensure that the following people or bodies are informed as appropriate:

• The GP, out-of-hours medical service, attending practitioner, district nursing service, palliative care team, or other relevant clinician, so that the death certification and Medical Examiner process can be initiated.
• The Medical Examiner office, where this is required by local health board or GP practice arrangements.
• The next of kin, representative, attorney, advocate, or other agreed contact, unless already present or unless doing so would be inappropriate or contrary to the person’s recorded wishes or legal arrangements.
• The funeral director, only where this is agreed in the care plan or by the next of kin/representative and after any required clinical, coronial, police, or safeguarding instructions have been followed.
• The Registered Manager or on-call manager.
• The service commissioner, where required by contract or where there are concerns about the circumstances of death.

The nurse must explain sensitively to the family or representative that verification confirms that death has occurred, but that the cause of death, Medical Examiner scrutiny, registration, and funeral arrangements are separate processes.

If the death is unexpected, suspicious, traumatic, unexplained, associated with an accident, fall, injury, medication error, safeguarding concern, possible neglect, abuse, restraint, deprivation of liberty, or any other reportable concern, the nurse must not proceed as a routine expected death. The nurse must contact emergency services and follow Section 3.6.

3.6 Escalation Procedures for Unexpected, Suspicious, Complex or Reportable Deaths

A registered nurse must not verify death as an expected death under this policy where:

• The death was not clearly anticipated and documented.
• The cause or circumstances of death are unknown, unclear, suspicious, violent, unnatural, or unexplained.
• The person had an accident, fall, injury, choking episode, burn, scald, pressure damage, medication incident, missed care, possible neglect, or other event that may have contributed to death.
• There are concerns about abuse, neglect, improper treatment, financial abuse, coercion, restraint, unlawful deprivation of liberty, or safeguarding.
• There are concerns about self-harm, suicide, assault, domestic abuse, or criminal activity.
• The person died during or shortly after a care intervention and the circumstances are unclear.
• The person was subject to a DNACPR decision but death was not expected or imminent.
• There is disagreement or significant concern from family, representatives, staff, or professionals about the circumstances of death.
• The nurse is uncertain whether death has occurred.

In these circumstances, the nurse or senior staff member must:

• Call 999 immediately where emergency, police, or urgent medical assistance is required.
• Preserve the scene and avoid moving the deceased or disturbing the environment unless necessary to preserve life, prevent further harm, or follow emergency service instructions.
• Leave medical devices, medicines, syringe drivers, transdermal patches, equipment, and records in place unless instructed otherwise by the police, coroner, emergency services, or relevant clinician.
• Contact the GP, out-of-hours doctor, district nurse, palliative care team, or other relevant clinician as appropriate.
• Inform the Registered Manager and Responsible Individual without delay.
• Consider whether a safeguarding referral is required under the Wales Safeguarding Procedures.
• Consider whether the death or related incident must be notified to CIW, the commissioner, local authority safeguarding team, police, coroner, Health and Safety Executive, professional regulator, or other body.
• Record all observations, decisions, communications, advice received, and actions taken.

Staff must not speculate about the cause of death or provide opinions about fault, blame, abuse, neglect, or clinical causation. All communication must be factual, compassionate, and in line with the duty of candour.

3.7 CIW Notifications for Domiciliary Support Services

For domiciliary support services, an expected death in a person’s own home is not automatically a CIW death notification solely because the person has died. However, the Registered Manager must review every death to determine whether a CIW notification is required because of the circumstances.

CIW must be notified without delay, using CIW Online and in the required form, where the death or surrounding circumstances involve a notifiable event, including but not limited to:

• Any abuse or allegation of abuse involving the service provider, staff member, or volunteer.
• Any allegation of misconduct by a member of staff.
• Any serious accident or injury to an individual.
• Any incident reported to the police.
• Any safeguarding referral made in respect of the individual, where this meets CIW notification criteria.
• Any event which prevents, or could prevent, the provider from continuing to provide the service safely.
• Any outbreak of infectious disease linked to the service.

Where the service provides accommodation, the death of an individual and the circumstances must be notified to CIW in accordance with the Regulations. This policy is for domiciliary care and must therefore be read in line with the regulated service type specified in {{org_field_name}}’s CIW registration and Statement of Purpose.

The Registered Manager is responsible for deciding whether CIW notification is required, recording the rationale, submitting the notification where required, and informing the Responsible Individual.

3.8 Coroner and Medical Examiner Considerations

The registered nurse must not decide whether a death is medically certifiable or whether the coroner will investigate. However, the nurse must escalate any concern that may indicate the death should be considered by the coroner, Medical Examiner, police, safeguarding team, or an attending medical practitioner.

The nurse must ensure that the GP, out-of-hours doctor, attending practitioner, district nurse, palliative care team, or Medical Examiner office is informed of any relevant facts, including falls, injuries, pressure damage, choking, medication incidents, safeguarding concerns, concerns about care, recent procedures, restraint, deprivation of liberty concerns, or family concerns.

Where the death is not investigated by the coroner, the Medical Examiner will provide independent scrutiny before the MCCD is sent to the registrar. Staff must cooperate with any request for factual information from the Medical Examiner office, GP practice, coroner’s office, police, safeguarding team, commissioner, or CIW, while maintaining confidentiality and data protection requirements.

3.9 Training, Competency, and Governance

Only registered nurses who are currently registered with the NMC, trained, competent, and formally authorised by {{org_field_name}} may verify expected deaths under this policy.

Before undertaking verification independently, the registered nurse must:

• Complete approved training in verification of expected death.
• Complete a competency assessment signed by an appropriately competent senior clinician, manager, or approved assessor.
• Understand the difference between verification, certification, Medical Examiner scrutiny, registration, and coroner investigation.
• Understand when not to verify death and when to escalate.
• Understand local arrangements for contacting the GP, out-of-hours service, district nursing service, palliative care team, Medical Examiner office, emergency services, police, safeguarding, commissioner, and CIW.
• Understand infection prevention, medical devices, implanted devices, oxygen, syringe drivers, medicines, controlled drugs, transdermal patches, and safe care after death.
• Understand documentation and record-retention requirements.

Competency must be reviewed at least every two years, sooner where practice changes, legislation changes, concerns are identified, the nurse has not undertaken verification for a prolonged period, or the nurse or manager identifies a need for refresher training.

{{org_field_name}} will maintain a register of nurses authorised to verify expected deaths. The register will include training dates, competency assessment dates, assessor details, renewal dates, NMC PIN, and any restrictions or conditions.

The Registered Manager will audit verification records at least annually, and more frequently where concerns are identified. Audit findings will be reported through governance arrangements and used to improve training, documentation, communication, and compliance.

4. Governance, Quality Assurance and Duty of Candour

{{org_field_name}} will ensure that verification of expected death is carried out safely, lawfully, compassionately, and in accordance with the person’s wishes, care plan, and the requirements of the regulated service.

The service will maintain:

• A standard Verification of Expected Death Form.
• A register of registered nurses authorised to verify expected deaths.
• A process for checking NMC registration and professional competence.
• Clear escalation pathways for unexpected, suspicious, traumatic, safeguarding, coronial, police, or CIW-reportable circumstances.
• Clear communication pathways with GPs, out-of-hours services, district nursing teams, palliative care teams, Medical Examiner offices, funeral directors, commissioners, safeguarding teams, CIW, and emergency services.
• Audit arrangements for verification records, incidents, delays, complaints, family feedback, and staff learning.
• Staff support arrangements following a death, particularly where the death was distressing, complex, or unexpected.

The service will act openly and transparently with individuals, families, representatives, commissioners, CIW, safeguarding bodies, and other relevant professionals where something has gone wrong or may have gone wrong. Where required, the service will follow its Duty of Candour, safeguarding, complaints, incident reporting, and notification procedures.

4.1 Care After Death

Following verification, staff must continue to treat the deceased with dignity, privacy, respect, and cultural sensitivity. Staff must follow the person’s recorded wishes and the wishes of the next of kin or representative where lawful and practicable.

Staff must:

• Provide compassionate support to family members and others present.
• Respect religious, cultural, spiritual, and personal wishes.
• Maintain privacy and dignity at all times.
• Follow infection prevention and control procedures.
• Follow local guidance regarding medical devices, syringe drivers, medicines, controlled drugs, transdermal patches, oxygen, sharps, and equipment.
• Not remove or alter anything where the death is unexpected, suspicious, traumatic, or potentially subject to police, coroner, safeguarding, or investigation processes, unless instructed by an appropriate authority.
• Record all care after death actions taken.

Personal property, medicines, and equipment must be managed in accordance with {{org_field_name}}’s medication, property, safeguarding, and record-keeping procedures.

4.2 Communication with Families and Representatives

Communication with families and representatives must be compassionate, clear, factual, and sensitive. Staff must explain:

• That verification confirms death has occurred.
• That verification does not certify the cause of death.
• That the GP, attending practitioner, Medical Examiner, coroner, registrar, and funeral director may each have separate roles.
• That funeral arrangements may not be able to proceed until the required certification, Medical Examiner, registration, or coroner processes have been completed.
• Who has been contacted and what will happen next.

Staff must avoid speculation about the cause of death. Any concerns raised by family members or representatives must be recorded and escalated to the Registered Manager, and where appropriate to the GP, Medical Examiner office, safeguarding team, commissioner, CIW, police, or coroner.

5. Related Policies

This policy should be read alongside:

• End-of-Life Care and Palliative Support Policy (DCW41)​
• Safeguarding Adults from Abuse and Improper Treatment Policy (DCW13)​
• Incident Reporting and Serious Event Review Policy (DCW22)​

• Duty of Candour Policy
• Mental Capacity and Best Interests Policy
• DNACPR/ReSPECT and Advance Care Planning Procedure, where applicable
• Medication Management Policy
• Infection Prevention and Control Policy
• Record Keeping and Confidentiality Policy
• Data Protection Policy
• Care After Death Procedure
• Notification to CIW and External Agencies Procedure
• Complaints Policy
• Whistleblowing Policy
• Staff Training, Competency and Supervision Policy
• Lone Working Policy
• Health and Safety Policy
• Handling Service Users’ Property and Possessions Policy

6. Policy Review

This policy will be reviewed at least annually, or sooner where there are changes to Welsh legislation, CIW requirements, Medical Examiner or death certification processes, NMC guidance, local health board procedures, safeguarding procedures, best practice guidance, the Statement of Purpose, service model, staffing arrangements, or following any incident, complaint, audit finding, safeguarding concern, or external recommendation.

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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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