Incident reporting in care homes: the form, the review, CQC notifications and RIDDOR

An incident report in a care home has three parts: the form completed by the person who was there, a formal review by a manager within a set time, and a record of what was learned and changed. Alongside those sit three separate decisions about who else needs to know: whether the incident stays as an internal review, whether it must be notified to CQC, and whether it is reportable to the HSE under RIDDOR. Most homes do the form well, the review late, the learning not at all, and confuse the three notification routes. Inspectors look hardest at the learning.

The short answer

Set a low threshold for writing a form, so near misses and small events are captured. Have the witness write it in their own words before the end of the shift. Have a manager review every form within a set time, usually 72 hours for most incidents and the same day for anything serious, and record the review separately from the form. At review, make three explicit decisions and record each with the reason: is this an internal matter only, does it meet a CQC notification category under the Registration Regulations, and does it meet a RIDDOR category? Add the safeguarding referral decision and the duty of candour decision where relevant. Then close the loop: what changed in the person's plan, the environment or the staffing, and when you will check it worked. This article works through each stage with a table of who to tell, a checklist, a procedure and what inspectors ask.

What counts as an incident

Define it in your policy and make the definition wide. Falls, medication errors including near misses, injuries of any kind, behaviour that put anyone at risk, missing person episodes, safeguarding concerns, choking episodes, pressure damage found, equipment failures, staff injuries, unexpected deaths, complaints that reveal a safety issue, and anything a worker thinks a manager should know about. The threshold for writing a form should be low. Homes that only record serious incidents have no near-miss data, and the near misses are where the pattern shows first.

Make the distinction between an incident and a routine event clear so staff are not writing forms for things that belong in the daily note. A person who is unsettled for an hour and settles is a daily note. A person who hits a worker is an incident. A person who is found on the floor is an incident even if unhurt. A dose that was nearly given to the wrong person is an incident. When in doubt, write the form; the review can downgrade it.

The form: the witness's own words

The form is written by the person who was there, in their own words, before the end of their shift. Not by the senior from a verbal account, and not the next day. Second-hand forms lose the detail that makes the review useful, and forms written the next day are written from memory that has already tidied itself.

The form should ask for facts, in order: date, time, place, who was present; what was happening before; what the person did and said; what staff did and said; how it ended; any injury and what was done about it; who was told at the time. It should ask for the person's own account, gathered when they are ready, recorded separately and in their words. It should not ask for a 'type of behaviour' from a dropdown, because that invites a label rather than a description. In learning disability and mental health homes the form should link to the ABC chart or the risk record in the care record so the incident feeds the plan rather than sitting in a separate file.

Keep the form short enough to complete in ten minutes. A form that takes forty minutes will be written at the end of the shift from memory, or not at all.

Immediate actions before any paperwork

The form comes after the person is safe. The immediate sequence for any incident with injury or risk is: make the area safe, attend to the person, call emergency services if needed, inform the senior, preserve anything that might matter such as a broken piece of equipment or the position of a person after a fall once they are safe, tell the family if the person wishes or lacks capacity to decide, and then write the form. For a medication error, contact the GP or pharmacist or 111 for advice before anything else and record the advice. For a fall, follow the post-fall protocol including the checks for head injury and the decision about moving the person. For a missing person, follow the missing person procedure including police contact at the agreed threshold. Record the times of each step; the timeline is often what the review and any external body want to see first.

At a glance: who needs to know and when

This table is a guide. Check the current CQC notification guidance and the HSE's RIDDOR guidance for health and social care for the exact wording, and record the decision and the reason for each incident whether the answer is yes or no.

CQC notifications: what, when and how

CQC notifications are made under the Care Quality Commission (Registration) Regulations 2009, not under the fundamental standards. The categories that matter most for care homes are the death of a person using the service, the death or unauthorised absence of a person detained under the Mental Health Act, and the other incidents category: serious injury, abuse or allegation of abuse, incidents reported to or investigated by the police, applications to deprive someone of their liberty and their outcomes, and events that prevent or threaten to prevent the service running safely and properly. Notifications are submitted through the CQC provider portal, without delay, and you receive a reference.

The common failures are notifying late because the manager was off, not notifying a safeguarding allegation because it turned out to be unfounded, and not notifying a DoLS outcome. Notify on the facts as they stand; an allegation that is later unsubstantiated was still an allegation. Record the notification reference on the incident form and keep a notifications log with date, category and reference. Our guide to CQC notifications and what to report goes through every category with examples.

RIDDOR: what it is and why it matters

RIDDOR is the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013, and it requires the responsible person, usually the employer, to report certain work-related incidents to the HSE. For care homes the categories that arise are: the death of anyone from a work-related accident; specified injuries to workers, such as fractures other than fingers and toes, amputations, loss of sight, and injuries leading to unconsciousness; injuries that keep a worker off normal duties for more than seven consecutive days; injuries to non-workers, including residents, that arise out of or in connection with work and result in the person being taken from the scene directly to hospital for treatment; occupational diseases; and dangerous occurrences such as a collapsed hoist or scaffold.

The question that confuses homes is residents' falls. The HSE guidance is that an injury to a resident is reportable when it arises from a work activity or a failure of the home's arrangements, such as a fault with equipment, an unsafe environment, a moving and handling procedure not followed, or a risk assessment not in place, and the person is taken to hospital for treatment. A fall that results from the person's own medical condition, with the home's risk controls in place and followed, is generally not reportable. Record the decision and the reasoning either way. RIDDOR matters because it is a criminal offence not to report a reportable incident, because the HSE uses the reports to target inspection, and because an unreported RIDDOR incident found later by an inspector goes straight to the well-led judgement. The report is made online to the HSE; over-seven-day injuries within 15 days, everything else without delay.

COSHH and RIDDOR

COSHH, the Control of Substances Hazardous to Health Regulations, sits alongside RIDDOR. An exposure to a hazardous substance that causes injury or illness, such as a chemical burn from an undiluted cleaning product or a needlestick with a known infection risk, can be a RIDDOR dangerous occurrence or occupational disease. Your COSHH assessments are part of the evidence that the home's arrangements were in place.

Safeguarding: the referral decision

Any incident that involves possible abuse or neglect, including by another resident, a family member, a worker or the service itself, needs a safeguarding decision at review: does this meet the threshold for a referral to the local authority under section 42 of the Care Act? The council decides whether to make an enquiry; the home's duty is to refer when there is reasonable cause to suspect abuse or neglect and the person is at risk and unable to protect themselves. Record the decision either way, with the reason. Where you refer, record the date, who you spoke to, the reference, and the outcome when it arrives. Where the concern involves a worker, follow your own disciplinary and DBS referral procedures alongside the safeguarding referral, and consider whether the police need to be told. Our guide to safeguarding adults in care homes covers the referral thresholds and Making Safeguarding Personal.

Duty of candour: when to apologise and how to record it

Regulation 20 requires openness when a notifiable safety incident occurs: an unintended or unexpected incident in the course of care that, in the reasonable opinion of a health professional, has or could have resulted in death, severe harm, moderate harm or prolonged psychological harm. When that threshold is met, the home must tell the person or their representative in person, explain what happened, apologise, offer support, and follow up in writing, and keep a record of all of it. The review is where the duty of candour decision is made and recorded. Note that an apology is not an admission of liability, and that the duty applies whether or not the person or family has complained. Homes that handle this well find that families trust them more, not less, and that complaints fall.

The formal review

The review is a separate record from the form, completed by a manager or deputy who was not the witness, within the time set in your policy. It looks at what happened, why, what was done, whether the response followed the plan and the policy, whether the plan needs to change, whether anyone else needs to know, and what will be checked and when. Use this procedure.

1. Read the form, the person's account, the care plan, the risk assessment and the last week of daily notes.
2. Speak to the witness and, where possible, the person. Ask what might have helped.
3. Build the timeline. Note anything before the incident that might have contributed: time of day, medication, environment, staffing, a change in routine, physical health.
4. Decide and record: internal only, CQC notification category or none, RIDDOR category or none, safeguarding referral or not, duty of candour applies or not. Give a reason for each.
5. Decide what changes: the care plan or risk assessment, the environment, the staffing, the training, the equipment, the policy. Name who will do it and by when.
6. Record the review, link it to the form, and set a check date to confirm the change happened and worked.
7. Add the incident to the monthly trend review.
8. Feed back to the witness what was decided and why.

The review is what inspectors read. A form with no review is a record of something that happened; a form with a review that changed the plan is evidence of a home that learns.

The learning: closing the loop

Learning means something changed. Most incident systems stop at 'care plan updated'. Ask what actually changed in the person's day, whether every shift knows, and whether the change worked. A review that adds 'staff to be vigilant' to the plan has changed nothing. A review that moves a person's room away from the noisy corridor, changes the evening medication time after discussion with the GP, adds a two-minute warning before the day service transport arrives, or replaces a hoist sling has changed something you can check in a month.

Check it. Put a date in the diary to look at whether the incident recurred and whether the change was kept. Record the check. Where a change did not work, say so and try the next thing. That loop, incident, review, change, check, is what the single assessment framework's outcomes evidence category is looking for. It is also the difference between a home where the same fall happens three times and a home where it happens once.

Trends: the monthly look

Individual reviews find individual causes. Trends find the causes nobody sees on the day. Once a month, look at every incident by person, by type, by time of day, by day of week, by location and by staff on duty. The patterns are usually obvious once they are on one page: falls clustered between 6pm and 8pm when the evening staff are doing medicines; behaviour incidents on the days the day service is closed; medication errors on the shift after the senior's day off; injuries on the unit with the broken hoist that was reported twice. Record the trend review, the conclusions and the actions, and take it to the provider's quality meeting.

An incident reporting system that can filter by those fields in a few taps makes this a twenty-minute task. On paper it is an afternoon with a highlighter, which is why most paper homes do it quarterly at best. Whatever you use, the compliance view of the home should show incidents open for review, notifications made, and trends by month, because those are the three questions an inspector will ask.

Falls, medication errors and behaviour incidents: the three big categories

Three categories account for most incidents in most homes, and each has its own review questions. For falls, the post-fall protocol, the falls risk assessment, footwear, lighting, the time since the last continence support, medication that affects balance, and whether the pattern suggests a physical cause needing a GP review. Our guide to falls in care homes covers the assessment and post-fall procedure. For medication errors, the type of error, the stage of the process where it happened, the competency and workload of the worker, the MAR or eMAR design, the pharmacy's part, and the advice sought; an eMAR that flags missed and late doses turns many errors into near misses caught during the round. For behaviour incidents, the antecedent, the setting events, the sensory environment, the staff response against the PBS plan, and whether the plan needs revising with the data. Review each category against its own questions and the reviews get sharper.

Involving the person and the family

The person's account is part of the record, gathered when they are ready and recorded in their words. Where the person lacks capacity to give an account, record what you observed of their response and what their representative said. Tell the family what happened when the person wishes it or cannot decide, and record when and what was said. Where the duty of candour applies, follow it. Where it does not, honesty still applies; families find out, and a family told by the home the same day trusts the home, while a family that finds a bruise on Sunday and hears nothing does not. Record the conversation in the incident record, not just in the daily note.

Staff and the just culture

Staff write forms when they trust what happens next. A worker who was disciplined for reporting a medication near miss will not report the next one, and the home loses the data that would have prevented the error after that. Build a just culture: honest mistakes are reviewed for the system cause, reckless behaviour is dealt with, and reporting is thanked. Say it in policy, in induction and in team meetings, and show it in how reviews are written. Feed back to every worker who writes a form what was decided and what changed. A worker who sees their form change a care plan writes the next one; one who hears nothing stops.

Learning disability and mental health homes: incidents and restrictions

In learning disability, autism and mental health services, incidents carry extra questions. Was any physical intervention or restriction used, by whom, was it in the plan, was it the least restrictive option, was it recorded separately as required and was the person debriefed? Does the incident change the PBS plan or the risk plan, and has the ABC data been updated? Did the incident involve a person's capacity or a DoLS or LPS condition? Is the person's own account recorded in their words and without labels? Inspectors applying Right support, right care, right culture will read incident records for whether the home responded by understanding the person or by adding restriction. A review that adds a restriction should show why nothing less would do and when it will be reviewed.

Deaths: expected, unexpected and LeDeR

Every death is recorded and every death is notified to CQC. An expected death under an end of life plan with the GP's involvement is notified and reviewed for the quality of the care in the last days. An unexpected death is a serious incident: preserve the scene, contact the GP and, where the GP cannot certify, the police and coroner, notify CQC without delay, consider RIDDOR if the death arose from a work activity, and inform the family. Where the person had a learning disability, the death should be notified to the LeDeR programme so it can be reviewed. Record every step with times. Review the incident with the same rigour as any other and look at the weeks before for anything that was missed.

Incident reporting checklist

• Policy defines an incident widely and sets review timescales.
• Form completed by the witness in their own words before the end of the shift.
• Person’s own account gathered and recorded separately.
• Immediate actions and times recorded, including advice sought.
• Review by a manager within the policy timescale, recorded separately from the form.
• Explicit decisions recorded with reasons: CQC notification, RIDDOR, safeguarding referral, duty of candour.
• Notification references logged on the incident.
• Change made, owner and date named, and check date set.
• Feedback given to the witness.
• Monthly trend review recorded and taken to the provider.

Common mistakes

• Forms written by the senior from a verbal account, or the next day.
• No separate review, so the form is the whole record.
• Notifying CQC late because the manager was off and nobody else knew how.
• Not notifying an allegation of abuse because it was later unsubstantiated.
• Deciding RIDDOR by instinct with no recorded reasoning.
• 'Staff to be vigilant' as the learning.
• No check that the change happened or worked.
• Trends reviewed quarterly or never, so the same incident happens three times.

What inspectors ask about incidents

The inspector will ask for the incident log for the last three months and pick three. For each they will want the form, the review, the notification decisions and references, what changed, and whether it worked. They will check the timescales against your policy. They will look for the person's account. They will then ask a worker what they would do if they saw an incident, and whether they get feedback on forms they write. Finally they will ask the manager about trends: what the last quarter showed and what changed because of it. A home that can answer all of that from one record per incident, with the review, the notification references and the check attached, is showing safe and well-led at the same time. That is what a system such as Kiwi, with incidents that carry a formal review step and notification decisions against the person, is built to produce. If you want to see the review workflow and the trend view, book a demo.

What good looks like on inspection day

The inspector picks a fall from six weeks ago. The form was written by the night worker at 3.40am in her own words with the timeline. The person's account was recorded the next morning. The review by the deputy at 9am the same day records: not a CQC notification because there was no serious injury; not RIDDOR because the person was checked and not taken to hospital and the risk controls were in place; no safeguarding concern; duty of candour not triggered but the family rang at 8am and the call is recorded. The review changed the night check times and asked the GP to review a sedating medication; both are dated. The check three weeks later records no further falls. The monthly trend review for that month shows the fall as one of four at night on the same unit, and the action was the lighting on the corridor, which was changed, with the invoice attached. The night worker, asked by the inspector, says she got feedback on her form and knows the checks changed. Nothing was assembled for the visit.

Final conclusion

Incident reporting is three things done in order: a form written by the person who was there, a review by a manager that makes the notification decisions explicitly and changes something, and a check that the change worked. Around that sit the three notification routes, internal, CQC and RIDDOR, plus safeguarding and the duty of candour, each decided and recorded with a reason every time. Set the threshold low, review within the timescale, look at trends monthly, feed back to staff, and involve the person and the family honestly. Do that and the same incident stops happening three times, which is the whole point of writing it down.

Frequently asked

Which incidents must a care home notify to CQC?

Under the Registration Regulations 2009: the death of a person using the service, the death or unauthorised absence of a person detained under the Mental Health Act, serious injuries, abuse or allegations of abuse, incidents involving the police, applications to deprive someone of their liberty and their outcomes, and events that stop or threaten the service running safely. Notify without delay through the provider portal and record the reference on the incident.

Is a resident’s fall reportable under RIDDOR?

Only if the injury arose out of or in connection with a work activity or a failure of the home’s arrangements, such as faulty equipment, an unsafe environment or a risk assessment not in place, and the person was taken from the scene directly to hospital for treatment. A fall caused by the person’s own condition with risk controls in place and followed is generally not reportable. Record the decision and the reasoning either way.

Who should complete the incident form?

The person who witnessed the incident, in their own words, before the end of their shift. A manager or deputy who was not the witness then completes a separate review. Forms written second-hand or the next day lose the detail that makes the review useful.

How quickly should an incident be reviewed?

Set the timescale in your policy: the same day for anything serious, including anything that might need a CQC notification, RIDDOR report or safeguarding referral, and within 72 hours for everything else. Record the review separately from the form and link the two.

What is the duty of candour and when does it apply to a care home incident?

Regulation 20 requires the home to be open when a notifiable safety incident occurs, meaning an unintended or unexpected incident that has or could have caused death, severe harm, moderate harm or prolonged psychological harm. You must tell the person or their representative in person, explain, apologise, offer support and follow up in writing, and record it all. An apology is not an admission of liability.

When should a care home make a safeguarding referral after an incident?

When there is reasonable cause to suspect abuse or neglect, including by another resident, a family member, a worker or the service itself, and the person is at risk and unable to protect themselves. Refer to the local authority safeguarding team, record the date, contact, reference and outcome, and notify CQC in parallel where the incident is an allegation of abuse.

What should an incident reporting system for care homes do?

Let the witness write the form quickly on a device in their own words, hold the person’s account separately, prompt a manager review with a due date, record the CQC, RIDDOR, safeguarding and duty of candour decisions with reasons, link the incident to the care plan and any ABC chart, and show trends by person, type, time, location and staff for the monthly review.

Why is RIDDOR important for care homes?

Because failing to report a reportable incident is a criminal offence, because the HSE uses reports to decide where to inspect, and because an unreported incident found later by a CQC inspector undermines the well-led judgement. It also forces the home to ask whether an injury arose from its own arrangements, which is the question that prevents the next one.

Sources

• CQC: statutory notifications guidance under the Care Quality Commission (Registration) Regulations 2009
• RIDDOR 2013
• HSE: RIDDOR reporting guidance for health and social care
• CQC: Regulation 20 duty of candour guidance
• GOV.UK: Care Act 2014 statutory guidance, section 42 safeguarding enquiries
• NHS England: LeDeR learning from lives and deaths of people with a learning disability and autistic people
• Local Government Association: Making Safeguarding Personal
• CQC: Regulation 17 good governance guidance