Insights from Module 3 of the UK Covid-19 Inquiry: Learning disability and the pandemic

Module 3 investigated the impact of the Covid-19 pandemic on the UK’s healthcare systems. The Inquiry’s Module 3 report was published on 19 March, 2026.

Mencap put forward crucial evidence on the lived experiences of people with learning disabilities during the pandemic, highlighting how existing health inequalities were further exacerbated in this period. 

What concerns the Inquiry report explored

Mortality rates

The report includes some shocking statistics on mortality rates:

In the spring of 2020, it is estimated that people with learning disabilities died at six times the rate of the general population.

Between January to November 2020, even after adjusting for personal and household characteristics, mortality rates for people with learning disabilities were 70% higher than for people without a learning disability. 

These figures are deeply concerning

Visiting restrictions and communication barriers

The report also highlights the crucial role carers and loved ones played for individuals with learning disabilities, who often relied on support to understand medical treatment. Mandatory PPE (namely face masks) further intensified communication barriers by obscuring facial expressions and preventing lip reading. 

Although visiting guidance was updated in April 2020 to allow visitors for people with learning disabilities, inconsistent application of the guidance still left people without essential support. 

This may have had harmful consequences, with vulnerable patients struggling to understand what was happening - resulting in distress and non-compliance with treatment.

The report recommends that guidance be published for the implementation of visiting restrictions in hospitals in the event of a future pandemic, to be reviewed every three years. 

Clinical Frailty Scale (CFS)

Early in the pandemic, the National Institute for Health and Care Excellence (NICE) recommended the use of the ‘Clinical Frailty Scale’ as an assistive tool to facilitate staff decision-making regarding intensive care treatment. It did not, at this stage, fully specify when the CFS should – or should not – be used. 

The CFS scores patients based on a combination of age, perceived frailty and pre-existing medical conditions. The use of the CFS risked unfairly disadvantaging individuals with learning disabilities, who were potentially denied intensive care treatment based on an artificially high CFS score. 

NICE guidance was amended in March 2020 to clarify that the CFS should not be used for “younger people, people with stable long-term disabilities, learning disabilities or autism”.

However, as Jackie O’Sullivan, Acting Chief Executive Officer of Mencap, noted in evidence, by the time the guidance had been amended, the “genie was out of the bottle”. 

The Inquiry report references the concerns raised by Mencap as to the potentially discriminatory impact of the CFS, and suggests that guidance on foreseeable clinical issues, such as application of the CFS, is developed well in advance of any future pandemic.

DNACPR (Do Not Attempt CPR) Decisions

Concerns were raised to the Inquiry regarding ‘blanket’ DNACPR notices for patients with disabilities. Mencap highlighted that some DNACPRs were put in place inappropriately due to a patient’s learning disability and voiced families’ concerns that CFS scores had been wrongly used to determine DNACPR decisions for people with learning disabilities. 

Although national guidance issued in April 2020 reiterated that blanket DNACPRs were not appropriate, Mencap expressed concern in evidence that, by that stage, once again “the genie was out of the bottle,” and damage had already been done. 

The Inquiry report states that “it is vital that doctors involved in making or implementing DNACPR decisions receive sufficient training on DNACPR notices and how to conduct discussions about them”.

Conclusion

Sadly, the rights and needs of people with learning disabilities were not adequately considered during the pandemic. The high mortality rate for people with a learning disability (as outlined in the Inquiry report), is particularly shocking.

I'm pleased that some of the harm and inequalities experienced by people with a learning disability were brought to light during the UK Covid-19 Inquiry. However, it is clear that more must be done going forwards to ensure that their rights are promoted, and future planning must be proactive, not reactive.

The Inquiry has now concluded the hearing of live evidence. The Inquiry will be reporting on modules 4-10 over the coming months.

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The full Module 3 report can be accessed online.