Oliver McGowan Mandatory Training: Implementation Checklist for September 2025

The Oliver McGowan Mandatory Training on Learning Disability and Autism became a statutory requirement for all CQC-registered providers under the Health and Care Act 2022. From September 2025, compliance is no longer optional. Evidence of completion must be available at inspection.

What the training requires

The training is structured in two tiers:

Tier 1 applies to all health and social care staff who may have contact with autistic people or people with a learning disability. It consists of a one-hour e-learning module covering awareness and communication.

Tier 2 applies to staff who provide direct care and support to autistic people or people with a learning disability. It includes a face-to-face training day led by trainers with lived experience.

The key distinction is that it is the employer's responsibility to determine which tier applies to each staff member, not the individual employee's. A registered manager who cannot demonstrate that this assessment was made, and that appropriate training was completed and recorded, is in breach of the requirement.

What CQC will look for at inspection

At inspection, CQC will expect to see:

• Evidence that every staff member has been assessed as Tier 1 or Tier 2
• Completion records for all Tier 1 modules, current within the provider's renewal window
• Attendance records for Tier 2 training, including trainer qualifications evidence
• A clear process for ensuring new starters complete the training before working unsupported with service users

This is not a policy question. CQC will look for evidence of actual implementation. Records should name individual staff members and show current compliance status.

The compliance tracking challenge

Oliver McGowan training adds a new training requirement to what may already be a complex competency matrix. For providers managing 50+ staff across multiple roles and locations, tracking completion manually via spreadsheets or paper files significantly increases the risk of a compliance gap going undetected.

The CVE within Survelix maintains a live competency ledger that can be configured to include Oliver McGowan training as a mandatory requirement for relevant role types. Expiry windows, tier classifications, and completion records are all tracked in real time. Non-compliant staff are automatically flagged and can be blocked from scheduling until compliance is restored.

Implementation checklist

Use this checklist to prepare for September 2025 compliance:

• Audit current staff list. Identify all staff who have any potential contact with autistic people or people with a learning disability.
• Assign Tier 1 or Tier 2 status to each staff member. Document the rationale for each assignment.
• Identify any staff who have already completed equivalent training. Check whether it meets the Oliver McGowan standard. Not all autism awareness training qualifies.
• Schedule Tier 2 training days. Note that trainers with lived experience are required. This is not a standard e-learning delivery.
• Update your training matrix to include Oliver McGowan as a mandatory requirement for relevant roles.
• Set a renewal cadence. The current guidance indicates three-yearly renewal for most roles, though this may be updated. Check CQC's current position.
• Configure your compliance tracking system to enforce Oliver McGowan completion as a scheduling prerequisite for relevant roles.

How Survelix supports compliance

Survelix's CVE can be configured to enforce Oliver McGowan training compliance at the point of rostering. When a staff member's training status is non-compliant, whether through non-completion or expiry, they cannot be added to a shift serving affected service users. This prevents inadvertent deployment of non-compliant staff and maintains an auditable record of compliance status over time.

The EAL can generate evidence packs that map Oliver McGowan compliance data against the relevant SAF quality statements, specifically those under the Safe and Effective key questions — in the format expected at CQC inspection.