COVID-M3.8

Recording Healthcare Worker Deaths

COVID-19 Inquiry · Module 3: Impact on Healthcare Systems · Issued 19 March 2026 · Addressed to: Department of Health and Social Care

Government responseWelsh Government: Accepted (Sep 2026)Scottish Government: Accepted in part (Sep 2026)Department of Health and Social Care: Accepted (Sep 2026)

DeliveryNo statement from Department of Health and Social Care found

Recommendation, verbatim from the inquiry

●Inquiry recommendation

The UK government, Scottish Government, Welsh Government and Northern Ireland Executive should work with their respective public health agencies and healthcare employers to develop nation-specific mechanisms to collect, analyse and publish data systematically on the deaths of healthcare workers in the event of a pandemic outbreak. The UK Statistics Authority should work with data providers to ensure that the data are comparable across the four nations of the UK.

COVID-19 Inquiry, Module 3: Impact on Healthcare Systems · 19 Mar 2026 Source PDF →

Published evidence summary

AI-generated evidence summary

In September 2026, the Department of Health and Social Care accepted the recommendation, stating that it will take a "proportionate, staged approach" to implementation (Department of Health and Social Care and Cabinet Office response, Sep 2026). The Scottish Government accepted the recommendation in principle in September 2026, proposing a phased approach to test data linkage while noting that differing data sources may prevent complete comparability across the UK (Scottish Government response, Sep 2026). The Welsh Government also agreed in September 2026 to adopt a staged approach, stating that practical, legal, and information governance issues must still be resolved before establishing a reporting mechanism (Welsh Government response, Sep 2026). The record holds no update since the department's response of September 2026 (Department of Health and Social Care and Cabinet Office response, Sep 2026).

AI-generated summary of the record on this page, checked by a second model and automatic checks, 26 Sep 2026.

Government response

●Welsh Government · Accepted · 17 Sep 2026

Words of: Welsh Government, UK Covid-19 Inquiry Module 3 report (Impact of Covid-19 pandemic on healthcare systems across the UK): Welsh Government response, 17 September 2026

8.1 The Welsh Government agrees with the Inquiry’s recommendation that, in the event of a future pandemic, there should be a clear way to record, analyse and publish information about the deaths of healthcare workers. This would help us understand how a pandemic has affected the workforce. It would also help public services take action to protect staff and be open with the public. 8.2 During the Covid‑19 pandemic, information about healthcare worker deaths came from several sources, including Public Health Wales, and other NHS organisations in Wales, and Office for National Statistics. These sources provided important intelligence, but they were designed for different purposes and each had limitations. Some information was available quickly but was not complete. Other information was more reliable for later analysis but was not available quickly enough to support urgent decisions. 8.3 The Welsh Government’s view is that no single existing data source is likely to meet all the needs of this recommendation. During a pandemic, data may be needed quickly to help protect staff, operational planning and urgent decision making. Over time, more detailed analysis may be needed to understand patterns by role, setting, areas and population groups. This means Wales may need to use more than one source of information. 8.4 There are significant practical and ethical issues to resolve. Any approach would need to be accurate, timely, and clear about who it includes. It should consider healthcare workers outside directly employed NHS roles, including primary care, community services and independent providers where relevant. It would also need to avoid implying that a death was caused by occupational exposure where that cannot be established. Any published information would need to be handled sensitively, with appropriate context, recognising the impact on families, colleagues and the wider workforce. 8.5 The Welsh Government will therefore take a proportionate, staged approach to implementation. It will work with the UK Government, the other devolved governments, the UK Statistics Authority, the Office for National Statistics, Public Health Wales, the NHS in Wales and relevant employers to identify the most appropriate approach for Wales and to support comparability across the UK as far as is possible. 8.6 The Welsh Government will ask the Office for National Statistics to include occupation routinely in mortality analysis for Wales during a future pandemic, where data quality allows. This will support better understanding of impacts on healthcare workers and other occupational groups.

8.7 Preparatory work will also need to consider the legal, information governance and operational arrangements that would allow any mechanism to be activated quickly in a future pandemic. This includes considering whether data sharing powers or notices would be required, how data quality would be assured, and how outputs would be communicated clearly and responsibly. The aim is not simply to create a publication, but to ensure that information is available in a form that can support decisions, protect the workforce and maintain public trust.

Response document: UK Covid-19 Inquiry Module 3 report (Impact of Covid-19 pandemic on healthcare systems across the UK): Welsh Government response

Site note: The Welsh Government's response to the Module 3 report, published on 17 September 2026 (ministerial foreword by Mabon ap Gwynfor MS and Nerys Evans MS). It mostly states no acceptance or rejection in words; those rows are marked noted. The passage covers Wales only.

●Scottish Government · Accepted in part · 17 Sep 2026

Words of: Scottish Government, UK Covid-19 Inquiry Module 3 report: Scottish Government response, page 9, 17 September 2026

This recommendation is accepted in principle. The recommendation is not accepted in full as whilst all four nations will endeavour that the data is comparable across the UK, different data sources may not make this completely possible.

Two workshops have been held with four nations colleagues and there was strong support for collecting healthcare worker (HCW) death data, with clear value across surveillance, protection, transparency, and recognition.

There are significant practical and ethical issues to resolve in delivery of this recommendation. Any approach would need to be accurate enough to command confidence, timely enough to be useful, and clear about coverage. There will also need to be consideration of the significant burdens reporting may have on employers especially during a pandemic.

No single data source meets all use cases; a mixed approach is likely required.

A phased approach is proposed. The first phase focuses on improving existing data collections and ensuring greater consistency through clearer definitions, enhanced reporting, and alignment across the UK. This will include developing minimum definitions and standards (e.g. “healthcare worker”) to improve consistency across the UK and exploring how current data sources and systems of reporting could be improved. However, their distinct purposes suggest different data sources, or a combined approach, will be needed, rather than a single measure.

The second phase, tests the feasibility of linking workforce and mortality datasets, alongside establishing the necessary legal, data-sharing, and governance frameworks, and embedding these processes into pandemic preparedness structures. Initial discussions for this phase propose data linkage of the Electronic Staff Record (ESR) on health worker employment status and Office for National Statistics (ONS) data on death as a promising, but currently underdeveloped, solution. Note that in Scotland this will be between eESS (Electronic Employee Support System) and National Records of Scotland (NRS). There are significant challenges in reporting data especially for those employed outside of NHS providers such as primary care, community services and independent providers and comparing with other professions and industries including social care.

The third phase is to move towards a more integrated analytical approach, combining early operational indicators with validated statistical outputs.

Response document: UK Covid-19 Inquiry Module 3 report: Scottish Government response, page 9

Site note: The Scottish Government's response to the Module 3 report, published on 17 September 2026 (ministerial foreword by Jenny Gilruth MSP and Angela Constance MSP). The passage covers Scotland only.

●Department of Health and Social Care · Accepted · 14 Sep 2026

Words of: UK government (Department of Health and Social Care), UK government response to the Covid-19 Inquiry Module 3 report (CP 1664), 14 September 2026

The government agrees that, in the event of a future pandemic, data on healthcare worker deaths plays a vital role in supporting and protecting the workforce as well as improving epidemic surveillance. The government will take a proportionate, staged approach to implement the recommendation.

Extract from: UK government response to the Covid-19 Inquiry Module 3 report

Site note: The Northern Ireland Executive published an initial response to the Module 3 report on 23 September 2026 (The Executive Office, "Executive initial Response to the Covid-19 Module 3 Report September 2026"). The site does not hold its text yet: the Executive Office's robots.txt does not allow automated fetching of its documents, and the Internet Archive held no copy when checked on 25 September 2026. So no Northern Ireland Executive response is recorded on this recommendation, and none should be read as absent.

Delivery

No statement on delivery from Department of Health and Social Care has been found in the sources searched. This is separate from the response above.

How this page is built

The recommendation and the government responses are verbatim from primary documents. Delivery statements and other bodies' findings are shown in their own words, each with its source. The summary is written by this site and labelled as such. The Index does not paraphrase sources or characterise intent; it records what has been published.