The Oliver McGowan Code of Practice: What Primary Care Providers Need to Know and Do

On 6 September 2025, the Oliver McGowan Code of Practice officially came into force. This marks a significant milestone in ensuring safer, fairer, and more person-centred care for autistic people and people with a learning disability.

From this date, the Code is a statutory requirement under the Health and Care Act 2022, and the Care Quality Commission (CQC) will use it to assess whether practices and Primary Care Networks (PCNs) are meeting their obligations around staff training.

With primary care being the first point of contact for many patients, compliance with this Code is not simply about ticking boxes—it is about building trust, ensuring equity, and reducing health inequalities.

We heard the CQC discuss this at The Primary Care Show in June, and all assessments will include this requirement.

Why This Code Matters in Primary Care

The Code was developed following the tragic death of Oliver McGowan and highlights systemic failures in the way health services supported autistic people and those with a learning disability.

In general practice and PCNs, staff at every level—from reception and administration through to GPs and nurses—play a vital role in creating a safe, inclusive experience for patients. The Code ensures that training is:

• Mandatory for all staff.
• Appropriate to the level of contact they have with patients.
• Designed to improve awareness, communication, and quality of care.

This approach means that no member of the team is overlooked. Everyone who contributes to a patient’s experience has a part to play.

What the Code Requires from GP Practices and PCNs

CQC-registered primary care providers must now demonstrate that:

• All staff receive training in how to interact appropriately with autistic people and people with a learning disability.
• Training is tailored to roles—whether that is a receptionist managing appointment bookings and greeting patients, a healthcare assistant supporting long-term condition reviews, or a GP providing direct clinical care.
• Training is recorded and evidenced, with up-to-date logs available for inspection.
• Practices can show how training supports safe, person-centred, and effective care.

Understanding the Training Standards

The Oliver McGowan Code sets clear training requirements:

• Tiered training levels:
  • Tier 1: Awareness training for staff with indirect or occasional contact (e.g. reception, admin).
  • Tier 2: Enhanced training for staff with direct patient responsibilities (e.g. clinicians, nurses, GPs, practice managers).
• Training components:
  • 90 minutes of mandatory e-learning.
  • Live, interactive training (minimum 1 hour for general staff; a full day for clinicians and leaders).
  • Training that is co-produced and co-delivered with people who have lived experience.
  • Accredited and independently quality assured.
  • Refreshers every 3 years.

Auditing Training in Your Practice

With the Code now active, practices should audit and map all current training against the new requirements.

Key questions to ask:

• Do staff training plans cover autism and learning disability appropriately?
• Is training co-produced with lived experience experts?
• Are staff correctly allocated to Tier 1 or Tier 2 based on their role?
• Are records accurate and up to date?

Creating an action plan will help identify gaps, reduce risk, and provide evidence for CQC inspections.

CQC’s Approach to Compliance

CQC will look for:

• Documented training records, plans, and schedules.
• Evidence of staff understanding and competence through interviews.
• Proof that training aligns with the Oliver McGowan Code standards.

Failure to comply may lead to concerns under Regulation 18: Staffing, and potentially other regulations such as person-centred care and safeguarding.

Final Thoughts

The Oliver McGowan Code of Practice is more than a regulatory requirement—it is a commitment to safer, fairer, and better healthcare.

By embedding this training across your practice or PCN, you will:

• Improve patient experiences and outcomes.
• Reduce inequalities in access to primary care.
• Demonstrate compliance and readiness for CQC inspections.

How BAXCQC Can Help

At BAXCQC, we work with GP practices and PCNs to:

• Audit your existing training
• Map staff to the correct training tiers
• Develop action plans for compliance
• Provide evidence frameworks for CQC inspections.

 Contact BAXCQC today to ensure your team is fully compliant and inspection ready.