How to Commission Oliver McGowan Mandatory Training

Oliver McGowan Mandatory Training (OMMT) is now a legal requirement for every CQC-registered health and social care provider in England. The Oliver McGowan Code of Practice, which came into force in September 2025, sets the standard against which CQC will assess compliance, and inspections are already underway.

For many employers, the question is no longer whether to commission OMMT. It is how to do it well.

This post sets out the key decisions involved in commissioning Oliver McGowan Mandatory Training, the questions worth asking before you commit to a provider, and what good commissioning actually looks like in practice.

What Oliver McGowan Mandatory Training actually requires

Before commissioning anything, it helps to be clear on what the training requirement involves.

Oliver McGowan Mandatory Training is delivered in two tiers. ‘Tier 1’ is designed for staff with indirect or occasional contact with people with a learning disability or autistic people, administrative, reception, and support roles. ‘Tier 2’ is for staff who provide direct care, support, or make decisions about service delivery, including registered managers and frontline care workers.

Both tiers consist of two parts: an eLearning module (Part 1) and a live, interactive session (Part 2). Critically, both tiers must be co-delivered by people with lived experience of learning disability or autism. This is not optional. It is a core requirement of the Code of Practice and a key quality indicator that Skills for Care’s Quality Assured Care Learning Service (QACLS) assesses providers against.

Employers who commission training that lacks this co-delivery element, regardless of what the provider calls it, are not meeting the statutory requirement.

The problem with how most employers commission OMMT

The market for Oliver McGowan Mandatory Training has expanded rapidly. That is broadly positive, but it has also created a commissioning environment where it is increasingly difficult to distinguish between providers who genuinely meet the standard and those who use reassuring language without the substance behind it.

Courses described as ‘accredited’, ‘quality-assured’, ‘CPD-certified’, or ‘mapped to Oliver McGowan’ are not necessarily the same thing. Each of these terms has a different meaning, and in some cases, none of them confirms that the training meets the requirements of the Code of Practice.

The result is that some employers commission training in good faith, spend the budget, issue the certificates, and remain non-compliant. That is an uncomfortable position to be in when a CQC inspector arrives.

The risks are real. CQC inspectors are actively checking OMMT compliance as part of routine assessments, and expect providers to demonstrate how they assessed each staff member’s training needs and provide evidence of completion by individual. Providers who cannot demonstrate this are vulnerable to enforcement action, and any resulting ratings are public, permanent, and visible to commissioners, families, and prospective staff.

Key questions to ask when commissioning Oliver McGowan Mandatory Training

Good commissioning of OMMT comes down to asking the right questions before you sign anything. Here are the ones that matter most.

‘Is the provider QACLS-approved or working towards it and are they NHS England accredited?’

Skills for Care operates the Quality Assured Care Learning Service (QACLS), which assesses training providers against the Oliver McGowan quality framework. QACLS is still in its early phases of rollout, which means employers can currently commission from providers who are not yet QACLS-approved, provided those providers hold NHS England accreditation for OMMT delivery.

However, the direction of travel is clear. Over time, DHSC intends that only QACLS-approved providers will be eligible for LDSS reimbursement funding, the only cost-reimbursement route currently available to employers commissioning OMMT. Employers who align themselves now with providers who are actively working towards QACLS approval will be better placed to avoid disruption to their funding claims and compliance position as the scheme matures.

In short: NHS England accreditation is the current minimum bar. QACLS approval is where the sector is heading.

‘Are experts with lived experience co-delivering both Tier 1 and Tier 2?’

This is a non-negotiable requirement of the Code of Practice. Ask specifically whether experts with lived experience are involved in ‘both’ tiers, and ask how they are recruited, trained, and compensated. A provider who cannot answer this question clearly is a provider worth approaching with caution.

‘What evidence will you receive for CQC purposes, and does it support an LDSS claim?’

CQC expects providers to demonstrate how they assessed each staff member’s training needs, and to evidence completion by individual, through training needs assessments, plans, and records of training delivered. Ask your provider what documentation they supply at the end of delivery and confirm it captures each staff member’s name, role, tier completed, and certificate date in a format you can present to an inspector.

Equally important: confirm whether the provider’s delivery is eligible for reimbursement through the Learning and Development Support Scheme (LDSS). LDSS is currently the only government-funded cost reimbursement route available to adult social care employers commissioning OMMT. Eligible claims require the training to have been delivered and paid for within the relevant financial year, with appropriate completion certificates and invoices retained as evidence. If a provider cannot confirm their LDSS eligibility, that is a significant gap worth resolving before you commit.

‘How is the training structured around your workforce?’

OMMT is not one-size-fits-all. Tier allocation should be based on each staff member’s role and their level of contact with people with a learning disability or autistic people. A provider who cannot support you to make those allocations properly, or who assigns everyone to the same tier regardless of role, is not delivering the training as intended.

‘What does the live Part 2 session actually involve?’

The interactive live session is where the quality of OMMT delivery is most visible. Ask to see the session structure, the learning outcomes, and how the lived experience of co-trainers is integrated – not just as an introduction, but throughout.

What good commissioning looks like

The employers who get the most from Oliver McGowan Mandatory Training tend to approach it as a workforce development decision, not just a compliance tick-box.

That means building OMMT into a wider training pathway that connects to induction, Care Certificate completion, and ongoing professional development. It means treating the experts with lived experience who co-deliver the training with the professional recognition they deserve. And it means using the training as an opportunity to genuinely improve how your workforce understands and supports autistic people and people with a learning disability, which is, of course, the point.

Compliance and quality are not in tension here. Done properly, Oliver McGowan Mandatory Training can strengthen staff confidence, reduce safeguarding risk, and provide substantive evidence for CQC inspection across multiple domains.

Download EdgeWorks™ OMMT Buyer’s Guide

We have produced a Oliver McGowan Mandatory Training Buyer’s Guide specifically for social care employers commissioning Oliver McGowan Mandatory Training. It covers the key compliance requirements, the questions to ask providers, the red flags to watch for, and what a compliant commissioning process looks like from start to finish.

It is short, practical, and free.

EdgeWorks™ holds QACLS approval from Skills for Care and works with a number of social care employers to deliver Oliver McGowan Mandatory Training that meets the full requirements of the Code of Practice. If you would like to talk through your organisation’s requirements, contact us at hello@edgeworks.co.uk or call 0330 995 0840.