Critical findings arising from an inspection of the anatomy department at University College Cork (UCC) have been “addressed”, the Medical Council has stated.
The inspection in September 2023 found that copies of the medical certificate of the cause of death (MCCD) and death registration certificate were not kept at the UCC Department of Anatomy and Neuroscience with the anatomical donors’ records.
“Most of the information contained on medical certificates of the cause of death appeared to be recorded, but copies of the legal documents were not present,” stated the Council’s inspection report. Copies of consent forms and other donation records had been scanned and entered onto a custom-made database on a secure server.
The Council’s Code of Practice for Anatomical Examination requires that a copy of the MCCD and death registration certificate should be kept at the institution receiving a donor’s body. The Code describes recommended practices and does not constitute primary or secondary legislation in human tissues or anatomical examination.
According to section IX of the Anatomy Act 1832: “Body not to be removed from its place of death for 48 hours, not without notice to the district inspector, or to some surgeon, nor without a certificate of the cause of death.”
On foot of the inspection, the Council approved UCC’s licence for the practice of anatomical examination on condition that it obtained and kept a copy of the MCCD and death registration certificate for each donor (within six months of the inspection) and implemented training on the requirements of the Code of Practice for all staff involved in any aspect of anatomical examination (within six months of approval of the inspection report).
UCC subsequently sought copies of the MCCD and death registration certificate pertaining to 196 anatomical donors, according to correspondence released by the Council under Freedom of Information law.
In correspondence to the Council in March 2024, Prof Paula O’Leary, Dean and Head of the School of Medicine; and Prof Aideen Sullivan, the then Head of the Department of Anatomy and Neuroscience and anatomy licence holder, outlined that two staff members had spent “a large proportion of their working hours” seeking the records since receipt of Council correspondence in December 2023.
The steps taken by UCC included writing to doctors requesting copies of the MCCD for 196 donors. However, this was “not a straightforward task and required multiple phone calls”.
In 50 cases, the doctors had sent a copy of the MCCD, but many “were not pleased with the request and questioned the legitimacy of same”. The College had obtained almost all the death registration certificates by this point.
The UCC correspondence stated that previous Council anatomy inspections and subsequent reports in 2016, 2018, and 2022 “did not raise as an issue that the forms that we have been using and in which cause of death is recorded were not in compliance with legislation”.
In December 2024, the Council emailed Prof Gerard O’Keeffe, Head of the Department of Anatomy and Neuroscience and anatomy licence holder, noting that the Council had previously sought Senior Counsel advice regarding the findings of the 2023 inspection.
“Given the nature of the request for Senior Counsel’s advices, it is noted that significant time has passed with no conclusion to date, I would like to assure you that UCC’s Anatomy Licence approval status will be extended until such time that the Medical Council is in a position to make any final decisions,” outlined the Council’s email.
The Medical Independent asked the Medical Council if other medical schools were found to have kept copies of the cited records, and whether this had been routinely reviewed during anatomy inspections in recent years. The Council’s spokesperson said: “Yes, other medical schools have and all have been reviewed over the years.”
Under the new Human Tissue Act 2024, medical schools must hold the MCCD before anatomical examination can take place. “The death certificate is not explicitly required under this section for anatomical examination, although it may still be relevant for other administrative or legal purposes,” said the Council spokesperson. The anatomical examination part of the Act has not yet been commenced.
A College spokesperson said: “UCC’s anatomical donation programme is committed to upholding the highest quality standards and all staff are fully appraised on the relevant processes, regulations, and necessary documentation. The conditions and recommendations, which were first outlined in the 2023 Medical Council inspection report, have been met.”
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