One Year on from the Oliver McGowan Code: 6 Questions Care Providers Should Ask Now 

One year after the Oliver McGowan Code of Practice became final, the Care Quality Commission (CQC) has again highlighted the mandatory training requirement on learning disability and autism. 

The Code became final on 6 September 2025. On 14 September 2026, CQC again highlighted how registered health and social care providers are expected to meet the statutory requirement for staff training. 

For providers that spent the past year putting training arrangements in place, this is a useful moment to move beyond a simple question of “Have staff done the training?” 

The more important question is now: 

Can you demonstrate that the right people have received appropriate training, and that it is making a difference to practice? 

If you need a refresher on the law, Tier 1 and Tier 2, live training requirements and the structure of the Oliver McGowan Mandatory Training, our existing Oliver McGowan Mandatory Training guide covers these in detail. 

👉 Read CareTutor’s full Oliver McGowan training guide 

For organisations already implementing the requirement, here are six areas worth reviewing one year on. 

1. Have you assessed every role?

CQC makes clear that the requirement applies across all CQC-regulated services and settings, not only specialist learning disability or autism services. 

It can also include ancillary and administrative staff who may have contact with autistic people or people with a learning disability. 

Providers should therefore be able to show that they have considered the training needs of the whole workforce rather than automatically assigning training only to care workers. 

If a provider decides that a member of staff does not require the training, CQC says there should be a record explaining how that decision was reached. 

Ask yourself: could we explain our decisions if CQC asked tomorrow? 

2. Have you reviewed older training?

Many organisations provided autism or learning disability awareness training before the Code became final. 

That training should not automatically be assumed to meet the current requirement. 

CQC expects providers to review previous learning against Regulation 18 and the standards in the Oliver McGowan Code of Practice. 

This is particularly important where organisations have historically relied on short awareness courses or general induction content. 

Your review does not necessarily mean starting again. It means being able to demonstrate that the training being relied upon meets the standards required today. 

3. Is your evidence stronger than a completion certificate?

CQC may ask providers for: 

• Assessments of staff training needs. 

• Training plans. 

• Training schedules. 

• Evidence of completed learning. 

Inspectors may then speak with staff to explore their understanding. 

This is an important distinction. 

A learning management system showing 100% completion is useful evidence, but completion alone does not necessarily show that learning has changed practice. 

Providers should also consider how the training is reinforced through: 

• Supervision. 

• Team discussions. 

• Reflective learning. 

• Care planning. 

• Reasonable adjustments. 

• Communication support. 

• Observation of practice. 

The Code is ultimately intended to improve people’s experiences, not simply increase training statistics. 

4. Can staff explain what they would do differently?

A useful test is to ask workers what the training has changed. 

Could they explain how they would: 

• Adapt their communication? 

• Identify and make reasonable adjustments? 

• Avoid making assumptions about someone’s behaviour? 

• Support sensory needs? 

• Involve the person appropriately in decisions? 

• Recognise when someone may communicate pain or distress differently? 

CQC says its focus is on whether providers and staff deliver safe, person-centred care and treatment that meets individual needs. 

That means the strongest evidence may not always sit in the training record. It may be visible in how workers actually provide support. 

5. Are managers monitoring the requirement? 

CQC normally considers learning disability and autism training through the Safe and effective staffing and Governance, management and sustainability quality statements. 

This makes it a management and governance issue as well as a training issue. 

Registered managers and training leads should have oversight of: 

• Who requires training.
• What level isappropriate. 
• Who has completed it.
• Any outstanding live learning.
• New starters.
• Role changes.
• Refresher requirements.
• Gapsidentified through supervision or incidents. 

If CQC identifies concerns, inspectors may look at what action the provider has taken, how workers are supervised and whether competence is being maintained. 

6. Can you show the impact on people?

This may be the most important question of all. 

The Code exists because autistic people and people with a learning disability continue to experience poorer health outcomes, barriers to accessing care and inequalities in the quality of support they receive. 

A provider that has implemented training well should increasingly be able to demonstrate practical improvements. 

That could include examples of: 

• Better communication support. 

• Improved reasonable adjustments. 

• More personalised care plans. 

• Reduced distress. 

• Greater involvement in decisions. 

• Staff responding differently following learning. 

• Feedback from people receiving support and their families. 

This moves the conversation from “we completed the training” to “this is what changed because of it.” 

CQC sets out how it assesses the requirement in its guidance on training staff to support autistic people and people with a learning disability. 

Use the anniversary as a review point 

One year after the Code became final, providers do not necessarily need another large implementation project. 

What they do need is assurance that the arrangements they have introduced are working. 

A simple annual review could ask: 

Have we identified everyone? Is training appropriate to role? Is our evidence complete? Do staff understand the learning? Are managers monitoring it? Can we show an impact on people’s experience? 

If the answer to any of those questions is unclear, that gives you a practical starting point for improvement. 

Need a refresher on Oliver McGowan training? 

CareTutor has delivered a dedicated webinar explaining the Oliver McGowan training requirements, delivery options, evidence and funding in practical terms for adult social care providers. 

You can watch the recording alongside our other free social care webinars on the CareTutor website. Watch CareTutor’s Oliver McGowan webinar 

CareTutor provides Part 1 eLearning through its learning management system and, in partnership with First Response Training, arranges the required Part 2 delivery. Pathway LMS can also help organisations monitor completion and maintain clear workforce training records. 

Book Oliver McGowan training with CareTutor 

View current dates, prices and delivery options for Oliver McGowan Mandatory Training. 

Call 020 3129 5667 or email info@caretutor.org to discuss individual places, group bookings, on-site delivery or tracking the training through Pathway LMS.