Thank you for all your work to implement the Death Certification Reforms on 9 September 2024. In the 5 months since that date, there have been around 224,000 deaths registered and based on 2023 trends we estimate that there have been around 183,000 cremations since 9 September 2024. We are extremely grateful for your ongoing support in helping to embed these important changes that better protect the public.
Hazardous medical device information
As expected with changes of this magnitude, there have been some teething issues, in particular around the flow of information relating to hazardous medical devices. We have heard, in particular, some concerns about the frequency with which ‘don’t know’ is ticked on form Cremation 6.
The need for information about hazardous medical devices to be passed through the system predates the Death Certification Reforms: prior to 9 September 2024, in coronial cases the coroner would only notify the crematorium about medical devices present in the deceased person if they had this information as a result of examining medical notes or completing a post-mortem examination. This information would usually have been included as part of the e-mail sent alongside the form Cremation 6. If the coroner did not know whether a device was present, they would simply provide the form Cremation 6 and no further information.
Post 9 September 2024, where information relating to hazardous medical devices is available, we expect the coroner to provide that information on form Cremation 6; this includes whether the device has been removed or not. We therefore expect the same procedures to be used when the coroner indicates they don’t know as was the case prior to the 9 September 2024 when this information was not provided. This might include the MR making enquiries with the coroner’s office.
If the presence of hazardous medical devices is not known and the coroner’s office has confirmed they do not have the information (and the coroners have provided this information on form Cremation 6) then you may find it useful to get in touch with the referring Attending Practitioner (AP), or the pathologist (if known).
In relation to non-coronial cases, it is the responsibility of the AP to complete the MCCD and to provide information relating to hazardous medical devices from deceased patient’s medical notes. Guidance is provided to the AP on how to complete the MCCD, which includes a list of potentially hazardous implantable medical devices. You can find this guidance at this link: https://www.gov.uk/government/publications/medical-certificate-of-cause-of-death-mccd-guidance-for-medical-practitioners/guidance-for-medical-practitioners-completing-medical-certificates-of-cause-of-death-in-england-and-wales. MRs should therefore direct questions and concerns related to the presence of hazardous medical devices to the AP, copying in their local ME for information.
In the very small minority of cases where there is no AP and the case has been passed from the coroner to the ME because the death was natural, an ME MCCD will be issued. In such a case, where information about hazardous implants is available in patient records available to the ME, the ME will add that information to the MCCD, so it flows through to the registrar.
We recognise there continue to be issues in ensuring that crematoria have accurate and complete information on the presence of hazardous medical devices and we want to take this opportunity to reassure you all that we are taking these concerns very seriously, and we continue to work with officials across government as well as key stakeholders to ensure we reach a more satisfactory position as quickly as possible.
Steps we have taken so far include:
- Working with the Department and Health and Social Care to ensure that APs understand that it is their responsibility to complete the MCCD, including providing information on hazardous medical implants, and the impact of failing to pass on this relevant information has on crematoria.
- Working with the Chief Coroner’s Office on this same issue – we have asked coroners when selecting the ‘don’t know’ option for presence of hazardous implant on form Cremation 6 to provide the rationale for that conclusion so that the recipient of the form can understand the reason, before determining suitable next steps.
Medical referees
As you will all know, in October 2024 we conducted a survey of crematorium managers and MRs on the future of medical referees. We thank all participants for their input.
We are currently analysing the responses and considering next steps and will engage further with the sector once our policy analysis is complete, but we want to take this opportunity to reiterate that any change to the role of the MR will be subject to consultation with stakeholders and will require the laying of legislation. We are committed to working with the sector to determine a suitable lead-in time to support any change required. We also recognise the importance of allowing the current system to stabilise before any further actions are taken, and will provide an update, including timings for any next steps, in due course.