Department of Health, Social Services and Public Safety (DHSSPS)
Tuesday, 8 March, 2011

The purpose of this consultation document was to set out recommendations to improve the current process for certifying deaths in Northern Ireland, and to invite views on the proposed options for future arrangements for death certification here.

For over sixty years the death certification process in Northern Ireland, England, Wales, and Scotland has remained largely unchanged. In 2003, however, the 3rd Report of the Shipman Inquiry concluded that arrangements for death registration, cremation certification and coronial investigation in England and Wales had failed either to deter Dr Harold Shipman from killing his patients or to detect his crimes after they had been committed.

The Luce Review, also published in 2003, and which extended to Northern Ireland, also made recommendations to improve death certification processes.

In 2009, an inter-Departmental Working Group was established to make recommendations on improving death certification arrangements. It involved representatives from three Departments (DHSSPS, DFP, DOE) as well as a range of organisations with a particular interest or involvement in post-death procedures. The Working Group reported to an inter-Departmental Steering Group, jointly chaired by the Chief Medical Officer and the Registrar General for NI.

The changes are designed to ensure that arrangements for certifying deaths are consistent and fair to all bereaved families and are sufficiently robust to inspire public confidence and to prevent any potential abuse by unscrupulous individuals.

COMMENTS ON DEPARTMENT OF HEALTH, SOCIAL SERVICES AND PUBLIC SAFETY (DHSSPS)
REVIEW OF DEATH CERTIFICATION IN NORTHERN IRELAND

The Royal College of Physicians of Edinburgh is pleased to respond to the DHSSPS on its consultation on the Review of Death Certification in Northern Ireland.

The College sought comments from four of its expert Fellows in Northern Ireland.  All respondents commented that the current system for the certification of death in Northern Ireland could be improved.  All respondents agreed that raising the standard of certification and improved monitoring would be important in maintaining public confidence in the system.

The document proposed two models for future death certification arrangements in Northern Ireland.

The first model essentially continues current arrangements but with enhanced training and surveillance.  Three of the four respondents preferred this option, perhaps followed by further consideration of the alternative outlined in option two at a future date.  One respondent felt that option one would not meet the major recommendations, but also had concerns about option two with concerns expressed that it was not a single system and that scrutiny arrangements could still be circumvented.

The respondents who favoured option one did so because it would be relatively cost neutral and would not delay the time between death and interment, which is important for patients in Northern Ireland who are buried quickly after death.  One respondent commented that any new governance procedures that would be deemed mandatory should be adequately resourced, but it was not clear from the documentation that this was the case.  Further, it was not at all clear that either option would enhance detection or reveal situations when medical errors or incidents of misconduct or neglect directly contributed to the death of the patient.

Option two involves the introduction of option one and the addition of the establishment of a new post of medical examiner.  The respondents would generally welcome the opportunity to avail themselves of the support of a medical examiner.  However, there were concerns expressed in relation to the estimated costs of establishing the service and the proposal to finance these costs by charging a fee for certification of all deaths.  There were further concerns about inevitable delays in completion of death certificates, especially during out-of-hours and at weekends given the shift pattern of medical working.  One respondent referred to an additional work load which may not be properly resourced, especially if clinicians were required to provide reports for review by the medical examiner.

One respondent would have welcomed scrutiny of a sample of death certificates, especially in circumstances where concerns had been raised.  This appears to be the preferred model of the working group considering this issue in Scotland.

Whilst most respondents favoured option one, none ruled out further consideration of option two at a future date.  Given the current political and financial climate and with the inevitable delay in certification of death and the introduction of what may be perceived as a universal “death tax”, it may be difficult to attract sufficient public support to allow immediate implication of option two.