Letter from Deputy Registrar General to the College:
"My predecessor wrote to a number of you in November 2010 to let you know that we were proposing to make changes to the medical certificate of cause of death (MCCD).
At that time, we proposed adding to the MCCD the Community Health Index (CHI) number and the certifying doctor’s General Medical Council reference number. In addition, and in anticipation of further changes flowing from the Certification of Death (Scotland) Act 2011, which was being considered by the Scottish Parliament at that time, we proposed making provision for a counter signature by a second doctor, and for information to be provided in respect of the handling of the deceased person’s body.
As many of you will be aware, the Certification of Death (Scotland) Act 2011 received royal assent on 20 April 2011 and full implementation is due to take place early in 2014. Provisions in the Act are designed to:
- introduce a single system of independent, effective scrutiny applicable to deaths that do not require a Procurator Fiscal investigation;
- improve the quality and accuracy of Medical Certificates of Cause of Death (MCCDs);
- improve public health information and clinical governance in relation to deaths.
As a result, we now intend to re-prescribe the MCCD and wish to give you a further opportunity to comment on the proposed changes and to suggest any additional changes that you think should be made.
For ease of reference, I have attached the existing MCCD (Appendix A) and a draft of the proposed new version (Appendix B). In particular, you will note that we are now proposing a double sided form with information to be provided on both sides. We are also proposing that there be a record of issue sheet with each pad of forms, instead of the existing counterfoil and a draft of that is also attached (Appendix C). You will also wish to note that we propose that the guidance on completion of the form will be published only on an NHS website: it will not be part of the pad of MCCDs. This will allow the guidance to be updated as appropriate without the need for it to be re-printed.
You will note that we have retained the space requiring the “Time of death”. However, this is one of the areas that causes the greatest difficulty for doctors. The time given can vary from the actual time the deceased died to the approximate time, to the time the body was found and it is not always clear what the time given on the form represents. We would therefore invite your views on whether recording the time of death on the MCCD and the death register serves any purpose, and whether we should continue to record it.
Registrars are currently instructed to retain completed MCCDs for 3 years and your views on whether this retention period is appropriate and should continue would also be appreciated.
As part of the new process, we also need to re-prescribe the Certificate of Registration of Death (Form 14) which is the certificate the person having charge of the place of interment or cremation must have before the interment or cremation takes place. A copy of the re-prescribed Form 14 is attached at Appendix D. Any comments on this form would also be welcome."
COMMENTS ON DEPUTY REGISTRAR GENERAL
PROPOSALS TO CHANGE THE CONTENT AND FORMAT OF THE MEDICAL CERTIFICATE OF CAUSE OF DEATH
The Royal College of Physicians of Edinburgh is pleased to respond to the consultation on the final changes to the Medical Certificate of Cause of Death (MCCD) as proposed by the Registrar General’s Office.
The College has sought the views of representatives from acute care, palliative care and care of the elderly. All are broadly content with the proposed changes; they report the amended form is much clearer and prefer the record of issue sheet to the current counterfoil system.
Up to date guidance is helpful, and clear notification of the website where such guidance will be maintained on the face of the form is welcome. The guidance could perhaps include advice on how best to approximate the time of death and make it very clear which grades of doctors are permitted to certify death.
Certifying doctors remain nervous that the requirement for review may cause distress to some bereaved relatives if this delays the release of the body to funeral directors. This may become more prevalent with changing shift patterns and rising numbers of less than full time doctors. There will also continue to be complications resulting from slow access for some doctors to the full patient records as happens for patients treated in different hospitals, but this is not a new issue.