One of the most common questions a registered manager faces after an incident is not how to make a CQC notification — it is whether this specific incident requires one at all. The statutory notification framework covers a defined range of events, but the thresholds are not always immediately clear, and the consequences of getting the judgment wrong run in both directions: failing to notify when required is a regulatory breach, while notifying unnecessarily creates administrative burden without regulatory benefit.
This article sets out the notification thresholds for each category of notifiable event, providing a practical decision framework for registered managers who need to determine quickly whether a specific incident triggers a statutory notification obligation.
The Statutory Framework
CQC's notification requirements derive from the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and the Care Quality Commission (Registration) Regulations 2009. Regulation 18 of the Regulated Activities Regulations sets out the duty to notify CQC of incidents affecting service users, while the Registration Regulations cover notifications relating to the provider's operational status — changes to the registered manager, premises, or regulated activities.
The obligation to notify is not discretionary. Where an event meets the statutory threshold, notification is legally required regardless of whether the provider believes the event reflects poorly on the service, whether it has already been reported to another body, or whether internal investigation is still ongoing. Notifying another body — the local authority safeguarding team, the police, the coroner — does not substitute for a CQC notification where one is required.
Notifications must generally be made without delay and in any case within the timeframes specified for each category. “Without delay” is interpreted by CQC as meaning as soon as reasonably practicable after the event occurs and the registered person becomes aware of it.
Death of a Service User
The threshold: notification is required whenever a service user dies while receiving regulated care, regardless of the cause of death, the circumstances, or whether the death was expected.
This is one of the most straightforward notification obligations in the framework precisely because there is no threshold judgment to make. A service user who dies of natural causes following a terminal illness, who dies unexpectedly following a fall, or who dies in hospital after being admitted from the care setting — all require notification. The provider does not need to assess whether the death was related to the care provided before making the notification.
The common misunderstanding is that only unexpected or unexplained deaths require notification. This is incorrect. All deaths of service users in receipt of regulated care must be notified, regardless of whether the coroner has been informed, a death certificate has been issued, or safeguarding enquiries are underway.
Serious Injury
The threshold: notification is required where a service user sustains an injury that is life-threatening, results in permanent or long-term impairment, or requires hospital admission for treatment.
Not every injury requires notification — minor injuries do not, and the judgment about whether an injury is serious enough to notify is genuinely a threshold judgment. The practical test is whether the injury required hospital admission for treatment. A cut treated at the service without hospital admission is below the notification threshold in most cases. A fracture requiring admission, surgical treatment, or resulting in permanent impairment to mobility crosses it.
Category 3 or Category 4 pressure ulcers that develop while a service user is in the care of the service are notifiable serious injuries. Category 1 and Category 2 pressure ulcers are generally below the notification threshold, though their development and management should be documented carefully.
Falls resulting in fractures are common notification triggers. A hip fracture following a fall is a straightforward notification. Bruising or soft tissue injury without fracture or hospital admission is generally below the threshold, though the fall and injuries should still be recorded.
Medication errors that result in harm meeting the serious injury threshold — for example, an overdose requiring hospital treatment — are notifiable. Errors identified and corrected without harm are not notifiable as serious injuries, though they should be recorded and reviewed.
Allegations of Abuse
The threshold: notification is required where an allegation is made that a service user has been abused, or where abuse is suspected, regardless of whether the allegation has been substantiated, investigated, or referred to other agencies.
This threshold is deliberately low. CQC does not require the provider to investigate, assess credibility, or reach a view on whether abuse occurred before making the notification. The obligation arises from the allegation or suspicion itself.
The ten categories include physical, sexual, psychological or emotional, financial or material, neglect and acts of omission, discriminatory, organisational or institutional abuse, modern slavery, domestic abuse, and self-neglect. An allegation falling within any of these categories triggers the notification obligation.
Allegations must not be substantiated before notification. A claim subsequently found to be unsubstantiated still required notification at the point it was made. Waiting for an investigation outcome creates a compliance risk.
Allegations Against a Registered Manager or Provider
The threshold: notification is required where an allegation is made against the registered manager, nominated individual, or registered provider in relation to abuse of a service user. The same low threshold applies: the allegation need not be substantiated and investigation need not be complete.
Missing Service Users
The threshold: notification is required where a service user goes missing from the service and the registered person is unable to locate them.
The practical trigger is when the service search has not located the service user and the police have been contacted. A person who briefly leaves but is located quickly without police involvement is generally below the notification threshold. A person who cannot be located after a reasonable search, where police have been notified, requires CQC notification without further delay.
The question is not whether the service user eventually returns safely — it is whether they were missing and unlocated when notification was required. Someone who prompts a police search and is then found safe still required notification when the criteria were met.
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The threshold: notification is required when a DoLS authorisation is granted for a service user, and when an authorisation is reviewed, suspended, or ends.
This category is frequently overlooked. The obligation is not simply to apply for authorisation where required — it is to notify CQC when authorisation is granted and when it changes status. Services with high numbers of DoLS authorisations should have a system for ensuring notifications are made promptly.
Events Affecting the Operation of the Service
The threshold: notification is required for events that affect or are likely to affect the service's ability to deliver care safely, including unexpected incidents affecting the running of the regulated activity.
This includes fire, flooding, power failure, and other incidents affecting the physical environment or operational capacity. It can also include significant staff shortages affecting safe care and incidents involving police attendance in connection with events affecting service users.
The question is whether the event has or is likely to have a material impact on safe care. A boiler failure in mild weather may be below the threshold; a winter failure leaving vulnerable residents without adequate heating crosses it.
Changes to Registration
Registered providers must also notify CQC of changes to registration status, including changes to the registered manager, address or location of the regulated activity, regulated activities being carried out, or the legal entity of the provider.
These are not incident notifications, but they are equally mandatory and time-sensitive. A change of registered manager must be notified promptly and accompanied by an application for the new manager's registration where necessary.
The Practical Decision Framework
When an incident occurs, work through this sequence:
- Has a service user died? If yes, notify without delay.
- Has a service user sustained an injury requiring hospital admission, that is life-threatening, or that has resulted in permanent impairment? If yes, notify without delay.
- Has an allegation of abuse been made, or is abuse suspected? If yes, notify regardless of investigation outcome.
- Is a service user missing and unlocated despite search, with police contacted? If yes, notify without delay.
- Has a DoLS authorisation been granted, changed, or ended? If yes, notify as required.
- Has an event materially affected safe care delivery? If in doubt, notify — the cost of an unnecessary notification is administrative; the cost of a missed notification is regulatory.
When in doubt, the default position should be to notify. CQC does not penalise providers for notifying events close to the threshold. It does penalise providers for failing to notify events that clearly met it.