In England, the governing body, academy proprietor or PRU management committee owns the statutory arrangements for pupils with medical conditions. It can delegate work, but it remains legally accountable.
The headteacher leads implementation and individual healthcare plan development. Trained staff deliver agreed support. Healthcare professionals advise on clinical need and proficiency. The employer owns workplace first-aid provision.
Put those lines into one responsibility map with cover, evidence, escalation and a review date. This guide reflects England sources checked on 16 August 2026. It isn't clinical or legal advice.
Start with the body that retains accountability
Section 100 of the Children and Families Act 2014 places the duty on the school's appropriate authority. For a maintained school that is the governing body; for an academy, the proprietor; for a PRU, the management committee.
The Department for Education's statutory medical-conditions guidance says functions may be conferred on a governor, headteacher, committee or staff member. Legal responsibility stays with the appropriate authority.
Delegation therefore needs a visible return path. A board can ask a senior leader to run the policy, but it still needs evidence that plans, training, cover and review arrangements work in practice.
Complete the seven-line responsibility map
Use role titles that exist in your setting. Don't invent a “medical lead” title and assume the job is covered. Record the person, deputy, evidence location and escalation route beside each line.
| Responsibility | Accountable or operational role | Evidence to test |
|---|---|---|
| Statutory arrangements | Governing body, academy proprietor or PRU management committee | Approved policy, assurance record, review date and unresolved gaps |
| Policy implementation | Headteacher and the person identified to lead implementation | Staff awareness, working procedures, cover and monitored actions |
| Individual healthcare plans | Headteacher overall, with an agreed school lead and plan partners | Plan owner, source advice, consent, review status and implementation |
| Day-to-day support | Staff who have accepted the role and completed suitable training | Role-specific training, proficiency confirmation and available cover |
| Clinical advice | Relevant qualified healthcare professional | Attributed advice, date, scope, changes and route for clarification |
| First-aid arrangements | The employer, implemented through the school's assessed arrangements | Needs assessment, trained personnel, equipment, cover and communication |
| Pupil and family contribution | The pupil and parent or carer, supported to contribute accessibly | Attributed views, agreed actions, contact route and recorded disagreement |
The map records responsibility; it doesn't certify compliance or clinical competence. Training attendance is evidence that training occurred. A healthcare professional confirms proficiency where the plan requires it.
Separate school medical support from first-aid duties
These systems meet different duties. Section 100 concerns arrangements for pupils with medical conditions. The Health and Safety (First-Aid) Regulations 1981 place workplace first-aid responsibilities on the employer for employees.
DfE's non-statutory first-aid guidance for schools says the needs assessment should also consider pupils and visitors. It should account for staff absence and other working patterns.
A first-aid certificate doesn't automatically authorise every action in a pupil's healthcare plan. Use the plan, training requirements, local procedures and qualified advice to define the role. Don't merge separate responsibilities because both happen near the same cupboard.
Test whether the map survives an ordinary absence
Ask five questions for each plan or operational duty: who owns it today, who covers them, what information does the cover role need, how is suitability evidenced, and where does the person escalate uncertainty?
Then test a normal school day. Include reception, lessons, lunch, clubs, trips and supply cover where relevant. The answer may differ by time and place, which is why a single name in a policy header is rarely enough.
Staff can be asked to support pupils with medical conditions, including medicines, but the current statutory guidance says they cannot be required to do so. They need sufficient and suitable training before accepting the responsibility.
Let connected records change the operational question
This made-up example combines no real pupil, family, staff member, school or customer. A summer review shows every relevant pupil has a plan owner, so the policy dashboard appears complete.
The IHCP review dates are then viewed beside first-aid follow-up records, attendance and the September cover rota. Two plans depend on the same trained person during lunch, and one review is awaiting updated professional advice.
The question changes from “Does every plan have an owner?” to “Who can deliver each agreed arrangement when the usual person is unavailable, and who resolves the open advice?” The headteacher assigns an operational check and a dated review.
Those connected records don't prove that support caused an absence, that a staff member is clinically competent or that a plan is safe. They expose a cover and evidence question for human review.
Write escalation as a route, not a vague instruction
For each responsibility, record the trigger for seeking help, the first contact, the deputy route, the source document and the person who closes the loop. Use the pupil's current plan and the school's local procedures.
Clinical uncertainty goes to the appropriate healthcare route. An immediate emergency uses the school's emergency procedure. A safeguarding concern goes promptly to the DSL or deputy and the appropriate local or emergency route.
Don't copy treatment instructions into the responsibility map. It should point authorised staff to the controlled, current source. Health information is special-category data, so access should be necessary for the role and limited to the purpose.
Record the 2026 transition without bringing it forward
The DfE consultation outcome published on 6 July says the existing general medical-conditions guidance remains in force and will be updated in due course. Proposed wording isn't yet the general statutory guidance.
The maintained schools governance guide, updated 15 July, restates collective governing-body accountability and a person with overall implementation responsibility.
It also says new allergy safety duties apply from September 2026. Schools should track that transition separately against the allergy safety statutory guidance instead of treating every July proposal as already in force.
Where Student Radar fits
In Student Radar, authorised staff can use Medical Needs to review the structured roster and linked records. IHCPs keeps plan and review status visible, while First Aid keeps incident follow-up in its own workflow.
Linking those records can reveal a missing owner, overdue review or cover question. The software can't determine clinical need, confirm staff competence, choose an emergency route or transfer the appropriate authority's accountability.
Sources and further reading
- UK Parliament, Children and Families Act 2014, section 100, legislation enacted 13 March 2014; the duty came into force on 1 September 2014.
- Department for Education, Supporting pupils with medical conditions at school, statutory guidance for England, main document dated December 2015 and page updated 16 August 2017; confirmed in force on 16 August 2026.
- Department for Education, Proposal on support for pupils with medical conditions at school, consultation outcome published 5 March and updated 6 July 2026.
- Department for Education, Maintained schools: governance guide, guidance for England updated 15 July 2026.
- Department for Education, First aid in schools, early years and further education, non-statutory guidance for England updated 14 February 2022.
- Health and Safety Executive, First aid at work: Guidance on regulations, regulatory guidance published 2013 and amended in 2018 and 2024.
- Information Commissioner's Office, What is special category data?, data-protection guidance checked 16 August 2026.
To see how authorised health records can support an owned review without making clinical decisions, request a Health walkthrough.