### CQC regulation in England **Legislation: CQC regulated activities.** 2014 Regulated Activities Regulations, regulation 3(3–4), Schedule 2 paragraph 10 and regulation 20. [S22](https://thirlwall-wiki.pages.dev/sources/index.md#s22) **Who and where:** Regulation 3 limits regulated activities to England. Schedule 2 excepts specified armed-services care, related training and services supplied on their behalf under agreements. Armed services include reserves. **What it means:** This exception concerns regulated activities under these Regulations. It is not an exemption from all healthcare law. Regulation 20 places candour duties on registered persons for regulated activities; notification depends on its incident definitions. **Internal questions:** Which organisation provides each activity? Does the precise exception cover the service or arrangement? Which provider's registration and duties apply to NHS-hosted or contracted care?

### Legal protection for civilian workers who speak up **Legislation: protected disclosures.** Employment Rights Act 1996 (ERA), sections 43A–43B, 43K, 47B, 103A, 191 and 244. [S43](https://thirlwall-wiki.pages.dev/sources/index.md#s43) **Who and where:** Eligible workers, including covered civilian Crown employment under section 191. The Act generally extends to Great Britain; these provisions do not extend to Northern Ireland. Worker status and overseas jurisdiction need individual assessment. **What it means:** Protection depends on a qualifying disclosure and a permitted disclosure route. Section 47B concerns detriment; section 103A concerns employee dismissal. Agency and other arrangements require the definitions in section 43K. MOD policy alone cannot establish eligibility. **Internal questions:** Who is the employer, and does the person meet the relevant worker or employee definition? Which jurisdiction and disclosure route apply? Which exclusions or other legal protections are relevant?

### The Armed Forces legal boundary **Legislation: Armed Forces boundary.** ERA section 192 and Schedule 2 paragraph 16. [S23](https://thirlwall-wiki.pages.dev/sources/index.md#s23) **Who and where:** Service as a member of the naval, military or air forces has a distinct statutory application provision. **What it means:** The official text includes a transitional substitution note and prospective amendments. Reading the displayed section 192 alone cannot establish operative tribunal rights. MOD's extension of Public Interest Disclosure Act 1998 (PIDA) principles is a separate policy commitment. [S15](https://thirlwall-wiki.pages.dev/sources/index.md#s15) **Internal questions:** What is the operative provision after commencement and transitional rules are checked? Which rights and remedies apply to the person's service and employment status?

### Mandatory Defence healthcare regulations **Mandatory Defence regulation.** DSA02 v4.0, chapter 1 paragraphs 2–6, p.4, and paragraph 8, pp.4–5. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) **Who and where:** Staff responsible for Defence healthcare worldwide, including Service personnel, civilians and contractors. The framework includes healthcare support, assurance, management and leadership. **What it means:** The regulatory articles do not replace legislative obligations. DSA02 requires comparison with applicable host-nation requirements and use of the more stringent standards. It distinguishes mandatory legislative and Defence-regulatory language from advisory language. **Internal questions:** Which provider, activities and responsible persons are covered? What applicable national, international and host-nation requirements must be considered alongside Defence regulation?

### Defence healthcare guidance **Defence Code of Practice (DCOP).** DSA03 v3.0, January 2026, chapter 1 paragraphs 3–9, p.5. [S12](https://thirlwall-wiki.pages.dev/sources/index.md#s12) **Who and where:** Guidance for those responsible for Defence healthcare worldwide, read with DSA02. **What it means:** DCOP supports compliance with Defence regulations; it is not legislation. Equivalent approaches are permitted, with justification where required. Its UK and overseas provisions retain the need to establish applicable law. **Internal questions:** Which DCOP provisions support the activity? Is an alternative approach used, and what establishes that it meets the regulatory requirement?

### Professional standards **Professional standards.** GMC *Good medical practice*, introduction and paragraphs 69–71, 75–76; NMC Code, introduction and sections 10, 14, 16–17. [S20](https://thirlwall-wiki.pages.dev/sources/index.md#s20), [S21](https://thirlwall-wiki.pages.dev/sources/index.md#s21) **Who and where:** GMC standards address registered doctors, physician associates and anaesthesia associates wherever they practise, according to relevance. NMC registration covers nurses and midwives in the UK and nursing associates in England; duties apply within professional scope, including leadership roles. **What it means:** These standards govern professional conduct, including records, safety concerns and response. Command or employer arrangements do not establish that a professional duty has been discharged. Professional registration does not resolve overseas legal requirements. **Internal questions:** Which registration, role and scope apply? Who holds the relevant professional and leadership responsibilities, including during placements or overseas practice?

### MOD protection for people who raise concerns **MOD policy protection.** April 2026 Raising a Concern policy, paragraphs 17 and 22–24, p.4; paragraphs 44 and 47–53, pp.8–9. [S15](https://thirlwall-wiki.pages.dev/sources/index.md#s15) **Who and where:** The policy states that it covers everyone working in Defence, past and present. It identifies additional DMS arrangements by reference to JSP 950. **What it means:** MOD extends PIDA principles to Service personnel as policy. That commitment is distinct from statutory worker protection. The public reference to JSP 950 does not verify its current internal provisions. **Internal questions:** Which policy and reporting routes cover each staff group? How do local healthcare, command, contractor and NHS arrangements connect? How are policy protection and any statutory protection identified separately? These sections are a bounded reference, not a complete account of healthcare or employment law. Devolved law, overseas arrangements and particular contracts require their own scope assessment. [CHECK-00](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-00) records the separate applicability questions; [CHECK-16](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-16) addresses reporting and protection.

### Command responsibility and changes to services **Who and when:** The Level 1 Responsible Person directs the service. The Provider must also manage changes that could affect safety. **Required response:** Article 1001(1), p.10, requires processes that demonstrate command intent, the services and patient needs covered, organisational dependencies, operating status, and an assessment of safety and compliance. Article 1003(1), p.12, requires a system to identify, record and manage changes. These include a new Responsible Person, a Responsible Person’s absence of 28 days or more, changed services or operating status, and an adverse assurance change affecting safe operation. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) **Thirlwall relevance and internal questions:** Leadership and follow-through depend on responsibilities surviving postings, absences and organisational change. Which current appointment holds each responsibility, who provides cover, and how are unresolved risks handed over? [R13](https://thirlwall-wiki.pages.dev/recommendations/index.md#r13), [R17](https://thirlwall-wiki.pages.dev/recommendations/index.md#r17); [CHECK-00](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-00), [CHECK-13](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-13).

### Safeguarding and suspected deliberate harm **Who and when:** The Provider and Responsible Persons must maintain effective protection. An allegation or evidence of abuse triggers investigation; proof of abuse is not the stated threshold. **Required response:** Article 2004(1–3), p.20, requires protection from abuse and improper treatment, effective prevention systems, and investigation immediately on awareness of an allegation or evidence. Article 1004(1)(f), p.14, includes abuse and allegations in the immediate-reporting requirement. It specifies the Automated Significant Event Reporting (ASER) and safeguarding systems; the opening paragraph says the specified tool should be used. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) JSP 834 Volume 1, chapters 3–4, pp.14–22, supplies related policy on incidents and allegations. [S16](https://thirlwall-wiki.pages.dev/sources/index.md#s16) **Thirlwall relevance and internal questions:** Who can protect patients immediately, restrict contact and obtain independent clinical advice? How do safeguarding, police referral and employment processes connect without delaying protection? [R4](https://thirlwall-wiki.pages.dev/recommendations/index.md#r4), [R9](https://thirlwall-wiki.pages.dev/recommendations/index.md#r9), [R10](https://thirlwall-wiki.pages.dev/recommendations/index.md#r10); [CHECK-04](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-04), [CHECK-09](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-09), [CHECK-10](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-10).

### Complaints and patient concerns **Who and when:** The Provider must operate an accessible complaints system. A received complaint requires investigation; an identified failure requires a response. **Required response:** Article 2006(1–2), p.23, requires investigation and necessary, proportionate action on failures. The system must identify, receive, record, handle and respond to complaints from patients and others about the service. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) **Thirlwall relevance and internal questions:** Complaints may contain safety information that also engages safeguarding or incident duties. Who recognises that overlap, records action on the failure and checks the response? Patient complaints and staff speaking-up protections remain distinct. [R9](https://thirlwall-wiki.pages.dev/recommendations/index.md#r9), [R14](https://thirlwall-wiki.pages.dev/recommendations/index.md#r14), [R16](https://thirlwall-wiki.pages.dev/recommendations/index.md#r16); [CHECK-09](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-09), [CHECK-14](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-14), [CHECK-16](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-16).

### Candour **Who and when:** All personnel delivering Defence healthcare must be open with relevant persons. The Provider has further duties when it becomes aware of a *notifiable safety incident*. **Required response:** Article 2008(1–6), pp.25–26, requires in-person notification as soon as reasonably practicable, reasonable support, an account of known facts, an apology, secure records and written follow-up. If the relevant person cannot be contacted in person or declines to speak, paragraph 5 specifies the exception and record of attempted contact. The trigger depends on the separate provider and harm definitions in paragraphs 7–9, pp.26–27. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) **Thirlwall relevance and internal questions:** Which definition applies, who assesses the incident, and who provides notification and follow-up? The organisational requirement, professional duties and proposed NHS manager reforms are different authorities. [R13](https://thirlwall-wiki.pages.dev/recommendations/index.md#r13); [CHECK-13](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-13).

### Leader competence **Who and when:** Responsible Persons must be able and competent to perform their roles. The chain of command has an explicit response duty when a Defence employee no longer meets Article 2007's suitability criteria. **Required response:** Article 1002(1), p.11, requires terms of reference, ability to perform the role and the necessary skills, qualifications, experience and competence. Article 2007(1–4), p.24, covers suitability, effective recruitment and professional registration where legally required. If the criteria cease to be met, the chain of command must take necessary, proportionate action and inform the relevant regulator where the person is registered with a healthcare or social-care regulator. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) **Thirlwall relevance and internal questions:** How are concerns assessed before a posting or appointment, and who makes any professional referral? Neither rank nor registration alone demonstrates management suitability. [R13](https://thirlwall-wiki.pages.dev/recommendations/index.md#r13); [CHECK-13](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-13).

### Speaking up **Authority, scope and response:** MOD's April 2026 Raising a Concern policy covers everyone working in Defence, past and present. Paragraphs 17 and 22–24, p.4, address protection, scope and the additional DMS route. Paragraphs 47–53, pp.8–9, distinguish policy and statutory protection. These are policy provisions; statutory rights require the separate [workforce and jurisdiction assessment](#legal-protection-for-civilian-workers-who-speak-up). [S15](https://thirlwall-wiki.pages.dev/sources/index.md#s15) **Thirlwall relevance and internal questions:** Which current route receives the concern, who owns the safety response, and how can a reporter bypass an implicated manager? Which protection covers military, civilian, agency and contractor staff? [R16](https://thirlwall-wiki.pages.dev/recommendations/index.md#r16); [CHECK-16](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-16).

### Records, monitoring and escalation **Who and when:** The Provider needs effective governance throughout delivery, not only after an incident. **Required response:** Article 3002(1–2), p.29, requires effective systems to monitor and improve quality and safety, identify and mitigate risk, maintain secure and complete records, and seek and act on feedback. Patient records must be accurate and contemporaneous; management and staff records are also required. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) **Thirlwall relevance and internal questions:** Who receives unresolved risks and concerning patterns? Who checks incomplete information and failed handovers? A dashboard or completed record does not itself demonstrate action. Neonatal reporting requirements retain their own service scope. [R5](https://thirlwall-wiki.pages.dev/recommendations/index.md#r5), [R6](https://thirlwall-wiki.pages.dev/recommendations/index.md#r6), [R7](https://thirlwall-wiki.pages.dev/recommendations/index.md#r7); [CHECK-05](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-05), [CHECK-06](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-06), [CHECK-07](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-07).

### Child deaths and external referral **Who and when:** The Provider must have systems for immediate reporting of the incidents specified in Article 1004(1), pp.13–14. These include deaths, specified injuries, abuse allegations and threats to safe service delivery. The specified reporting tool depends on the incident category. **Required response:** Maintain immediate-reporting systems. Paragraph 1 says the specified tools should be used; these include ASER, Sentinel Report and Defence Accident Investigation Branch routes, according to the category. This distinction preserves the source's mandatory reporting duty and its advisory wording on tool use. Paragraphs 2–3 additionally require reporting without delay of specified coroner reports to DMSR and of Never Events through a Sentinel Report. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) JSP 834 Volume 1, chapter 3, pp.14–19, addresses related incident and overseas child-death arrangements. [S16](https://thirlwall-wiki.pages.dev/sources/index.md#s16) **Thirlwall relevance and internal questions:** Who makes each notification, including outside normal hours? Which local police, safeguarding and death-investigation requirements also apply? Internal reporting does not by itself discharge an external legal requirement. The [England death-duty reference](#death-notification-and-child-death-review-in-england) identifies the external roles and triggers. [R8](https://thirlwall-wiki.pages.dev/recommendations/index.md#r8), [R9](https://thirlwall-wiki.pages.dev/recommendations/index.md#r9), [R11](https://thirlwall-wiki.pages.dev/recommendations/index.md#r11); [CHECK-06](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-06), [CHECK-08](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-08), [CHECK-11](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-11).

### Staffing and shared care **Who and when:** The Provider must maintain safe care, adequate staffing and continuity when care is shared or transferred. **Required response:** Article 3001(2)(a–c, i), p.28, requires risk assessment, reasonably practicable mitigation, competent staff and timely care planning with other providers and patients. Article 3003(1–2), p.30, requires sufficient suitably qualified and experienced staff, with the support, training, development, supervision and appraisal needed for their duties. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) **Thirlwall relevance and internal questions:** Who holds responsibility while a patient waits or moves between services? How are clinical and leadership capacity, temporary staff and supervision covered? The [inspection comparisons](https://thirlwall-wiki.pages.dev/inspection-findings/index.md) show why these questions matter, within their dated service limits. [R5](https://thirlwall-wiki.pages.dev/recommendations/index.md#r5), [R13](https://thirlwall-wiki.pages.dev/recommendations/index.md#r13), [R14](https://thirlwall-wiki.pages.dev/recommendations/index.md#r14); [CHECK-05](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-05), [CHECK-13](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-13), [CHECK-14](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-14).

### Inspection and oversight CQC's selected Defence inspections provide evidence about care. DMSR's regulatory and enforcement responsibilities are distinct. The [inspection and enforcement section](#inspection-enforcement-and-closure) explains who can require action and what remains unverified about closure. [S10](https://thirlwall-wiki.pages.dev/sources/index.md#s10) [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) [S14](https://thirlwall-wiki.pages.dev/sources/index.md#s14) **Thirlwall relevance and internal questions:** Which body inspects the service, who can require improvement, and who independently examines assurance quality? [R14](https://thirlwall-wiki.pages.dev/recommendations/index.md#r14), [R15](https://thirlwall-wiki.pages.dev/recommendations/index.md#r15); [CHECK-14](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-14), [CHECK-15](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-15).

### Completing improvements **Authority and response:** Alongside DSA02's effective-governance requirement, JSP 815 Element 12, paragraph 24, p.5, requires suitable assurance. Expectations 12.4–12.5, pp.16–17, address leadership review and corrective action. These are published Defence safety requirements, not proof of their implementation. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) [S26](https://thirlwall-wiki.pages.dev/sources/index.md#s26) **Thirlwall relevance and internal questions:** Who owns the action, what evidence shows that the safety concern is resolved, and who can accept closure? An administrative completion date does not demonstrate effective change. [R17](https://thirlwall-wiki.pages.dev/recommendations/index.md#r17); [CHECK-17](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-17).

### Monitoring equipment and insulin **Authority and response:** DSA02 Article 3001(2)(e–g), p.28, requires safe equipment use and safe medicines management. Where the Provider supplies equipment or medicines, quantities must be sufficient for patient safety and needs. The Inquiry's specific camera, biometric and laboratory proposals are distinct. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) **Thirlwall relevance and internal questions:** What controls stock access and urgent laboratory escalation? Which clinical, privacy and legal conditions apply to any monitoring proposal? [R1](https://thirlwall-wiki.pages.dev/recommendations/index.md#r1), [R2](https://thirlwall-wiki.pages.dev/recommendations/index.md#r2); [CHECK-01](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-01), [CHECK-02](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-02).

### Bereavement and specialist pathology No dedicated current public Defence pathway or capacity assessment was verified in this bounded review. General safe-care duties do not establish a particular referral pathway or specialist capacity. **Thirlwall relevance and internal questions:** Who arranges bereavement support, specialist referral and continuity across providers? Which agreements establish access? Absence of a verified public pathway does not establish that arrangements are absent. [R3](https://thirlwall-wiki.pages.dev/recommendations/index.md#r3), [R12](https://thirlwall-wiki.pages.dev/recommendations/index.md#r12); [CHECK-03](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-03), [CHECK-12](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-12).

### Notification to a coroner **Who and when:** A registered medical practitioner must notify the relevant senior coroner when a circumstance in regulation 3(1) applies. These include suspected death due to neglect, violence, injury or medical treatment, or another suspected unnatural death. They also include an attending practitioner's inability to establish the cause after reasonable steps, and specified absence or unavailability of an attending practitioner. Suspicion is sufficient for the circumstances expressed in those terms; proof is not required. The full list, including identity and detention circumstances, remains in regulation 3. [S46](https://thirlwall-wiki.pages.dev/sources/index.md#s46), regulations 2–3. **Required response:** Notify the senior coroner for the area where the body lies as soon as reasonably practicable. Give the specified known information and any further information the doctor considers relevant. Notification must be written unless exceptional circumstances justify an oral notification, which requires subsequent written confirmation. The duty does not apply if the doctor reasonably believes that the coroner has already been notified under these Regulations or a referral has been made under the specified certification provisions. An assumption that someone else will notify is insufficient. [S46](https://thirlwall-wiki.pages.dev/sources/index.md#s46), regulations 1(2), 2(2) and 4.

### Certification and medical-examiner scrutiny **Who and when:** The certification regulations apply to deaths that require registration under Part 2 of the Births and Deaths Registration Act 1953. An attending practitioner is a registered medical practitioner who attended the person before death. Regulation 3(2) provides exceptions, including another attending practitioner having supplied a certificate to the examiner and the coroner having decided to investigate. [S47](https://thirlwall-wiki.pages.dev/sources/index.md#s47), regulations 1–3. **Required response:** Where regulation 3 applies, the attending practitioner must review the relevant records and information as soon as practicable. They must prepare and sign the certificate, or refer the death to the coroner if they cannot establish the cause. A signed certificate and the reviewed records and information must go to the appropriate medical examiner. The attending practitioner must be available, as far as reasonably practicable, to answer the examiner's enquiries. [S47](https://thirlwall-wiki.pages.dev/sources/index.md#s47), regulations 3 and 7. The examiner must make necessary enquiries and take reasonable steps to discuss the cause with a qualified informant or another appropriate person. That person must have an opportunity to raise matters that could require a coroner's investigation. The examiner must refer the death if unable to confirm the cause, or if they form the opinion that the statutory notification duty arises. Regulations 15–20 provide a separate route for certain coroner referrals where an attending practitioner is absent or unavailable. [S47](https://thirlwall-wiki.pages.dev/sources/index.md#s47), regulations 6, 8, 10 and 15–20. An examiner appointed by an English NHS body must not act if insufficiently independent under regulation 6. Their functions include reporting serious clinical-governance, patient-safety or public-health concerns under local arrangements. Their functions also include meeting reasonable child-death review information requests where the coroner has decided there is no duty to investigate. [S48](https://thirlwall-wiki.pages.dev/sources/index.md#s48), regulations 6–7.

### Child-death review and requested information **Who and when:** The statutory review partners are the local authority and each integrated care board whose area overlaps it. They must arrange review of each death of a child normally resident in the area. This is not limited to unexpected deaths. They may also arrange review of a non-resident child's death in their area if they consider it appropriate. [S49](https://thirlwall-wiki.pages.dev/sources/index.md#s49), sections 16M(1–2) and 16Q(2). **Required response:** Partners must arrange analysis, inform people whom they consider should take resulting action, and publish reports at intervals they consider appropriate. A person or body receiving an information request under section 16N must comply. The request specifies the information and recipient; information supplied may be used only for the review purpose. Providing Defence healthcare does not itself make Defence a statutory review partner. [S49](https://thirlwall-wiki.pages.dev/sources/index.md#s49), sections 16M(3–6), 16N and 16Q(2). **Statutory guidance:** Working Together 2026, paragraph 447, says practitioners in all agencies should notify the review partners when they learn of any child's death. The route is the local Child Death Overview Panel administrator, or equivalent, using the child-death notification form. This is a separate instruction from the request-triggered duty in section 16N. Review partners must have regard to the statutory guidance under section 16Q(1). [S50](https://thirlwall-wiki.pages.dev/sources/index.md#s50), chapter 6, p.156; [S49](https://thirlwall-wiki.pages.dev/sources/index.md#s49). **Thirlwall relevance and internal questions:** These existing duties are distinct from R8's hospital-baby clarification and R11's proposed neonatal contact and scrutiny arrangements. The [implementation tracker](https://thirlwall-wiki.pages.dev/implementation/index.md) records the published NHS clarification and its delivery limits. [S30](https://thirlwall-wiki.pages.dev/sources/index.md#s30) [S32](https://thirlwall-wiki.pages.dev/sources/index.md#s32) [S38](https://thirlwall-wiki.pages.dev/sources/index.md#s38) For Defence, the remaining questions concern the applicable external route, responsible practitioner, records access and coordination between services. See [CHECK-08](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-08) and [CHECK-11](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-11). Public sources do not establish how each Defence service fulfils these requirements.

### Who inspects? DMSR regulates, assures and enforces Defence-delivered healthcare. CQC provides independent inspection within the published Defence programme. DMSR selected the facilities inspected in 2025/26; CQC also used follow-up visits to assess earlier concerns. [S10](https://thirlwall-wiki.pages.dev/sources/index.md#s10) [S14](https://thirlwall-wiki.pages.dev/sources/index.md#s14), Summary of inspection activity The Cyprus and South East reports state that the inspected DMS services are outside CQC's statutory enforcement powers under the Health and Social Care Act 2008. They identify DMSR's enforcement role and its commitment to ensuring implementation of observations and recommendations. That commitment does not establish completion. These reports do not determine the legal position of every NHS-hosted or contracted arrangement. [S44](https://thirlwall-wiki.pages.dev/sources/index.md#s44), p.3; [S45](https://thirlwall-wiki.pages.dev/sources/index.md#s45), p.1

### Who can require corrective action? DSA02 chapter 1, paragraphs 8(j–k), pp.5–6, distinguishes two roles: - **Responsible Person:** holds compliance responsibilities within the defined area. Four levels connect senior organisational responsibility to delivery at a unit or facility. - **Accountable Person:** the individual to whom enforcement action should be directed. This person should hold the authority and resources to secure the required improvement. The same individual may also be a Responsible Person. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) Paragraph 9, p.6, gives DMSR a range of responses to non-compliance: advice and guidance, Corrective Action Requirements, and enforcement notices. The notices are an Improvement Notice, an Urgent Improvement Notice and a Prohibit Notice. The document says action may be incremental; it does not prescribe an automatic sequence. A CQC recommendation is not, by itself, evidence that DMSR issued one of these requirements or notices. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11)

### Who confirms closure? **The exact internal closure authority is not established by these public sources.** DSA02 paragraphs 9–10 and footnotes 2–3, p.6, identify the detailed corrective-action, enforcement and appeals guide as Defence Intranet only. Its thresholds, evidence requirements and delegations need separate confirmation. [S11](https://thirlwall-wiki.pages.dev/sources/index.md#s11) Keep three records distinct: a provider's statement that work is complete, a CQC follow-up finding, and any regulator acceptance required and documented under the applicable process. A better overall rating does not show that every action has closed. Cyprus retained safety concerns alongside a Good overall rating. [S44](https://thirlwall-wiki.pages.dev/sources/index.md#s44), pp.3–5 **Internal questions:** Which current procedure applies, who has authority to accept closure, and what evidence demonstrates that the safety concern is resolved? See [CHECK-14](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-14), [CHECK-15](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-15) and [CHECK-17](https://thirlwall-wiki.pages.dev/internal-policy-checks/index.md#check-17).