UK Covid-19 Inquiry Module 3 report: Scottish Government response

Recommendation 1 - Ensure that decision-making on infection prevention and control is underpinned by clear structures and a cautious approach to transmission risk

Chair’s recommendation:

The UK Government must ensure that there is a body (equivalent to the UK Infection Prevention and Control Cell) in place ready to be convened at the outset of any future pandemic, to consider and draft infection prevention and control guidance for healthcare settings. This body must:

• have clear lines of responsibility and a clear, pre-defined role and remit during a pandemic
• have multidisciplinary membership, including experts in the science of viral transmission as well as those with clinical expertise
• ensure that its guidance accounts for the risk of all plausible routes of transmission until sufficient evidence emerges to rule out specific routes; and
• ensure that guidance clearly explains the underlying rationale for the precautions recommended

Separately, the Department of Health and Social Care, NHS National Services Scotland, Public Health Wales and the Public Health Agency (Northern Ireland) should review the national infection prevention and control manuals and any future guidance to ensure that the approach to identifying risk of transmission is not confined solely to specific procedures. Emphasis should be placed on a combination of risk factors, such as rates of transmissibility, environment, setting and procedure.

Scottish Government response:

Whilst this recommendation is not directed at the Scottish Government, a range of work is underway to strengthen structures and drive improvement on the ground:

• The Scottish Government is committed to working closely with the UK Government, and other devolved governments, on proposals in relation to pandemic preparedness as it relates to IPC (Infection Prevention and Control) structures. The Scottish Government recognises the importance of engaging on a four nations basis and has already met with the UK Government and other devolved governments to discuss what structures may be convened to support working in the event of, and responding to, another pandemic
• On 27 July 2026, Scotland became the first nation in Europe to publish an integrated Infection Prevention and Control (IPC) Strategy covering both health and social care. The strategy aims to reduce preventable infections across all settings, including hospitals, care homes and community care. The strategy identifies eight priority areas, including stronger governance and leadership, enhanced IPC programmes, improved data and surveillance, and expanded workforce education and training. It is the first dedicated Scottish Government IPC strategy covering care homes and social care, reflecting lessons learned from the Covid-19 pandemic. The next phase of this work will be the development of three-yearly action plans with stakeholder oversight and assurance built in from the outset. The action plans will have a focus on turning the policy ambition into change on the ground, for example by strengthening IPC practice, scrutiny and organisational roles and responsibilities. To inform this work Scottish Government is funding the ALLIANCE to facilitate community engagement, including from those impacted by health and care associated infections, ensuring experiences can influence the action plans and outcomes
• Public Services Delivery (PSD) Scotland was formed on 1 April 2026, replacing NHS Education for Scotland (NES) and NHS National Services Scotland (NSS). It is a national delivery organisation that brings together expertise in national infrastructure, digital and data services, clinical service delivery, education and workforce development, planning, and transformation to support better outcomes for people and communities across Scotland
• The organisation plays a key role in informing policy development and implementation by providing evidence, professional knowledge, analytical capability and operational experience. Working across organisational and professional boundaries, PSD Scotland supports the design, delivery and improvement of services that meet the needs of people, communities and the workforce
• On 3 August 2026 PSD Scotland published the updated Transmission-Based Precautions (TBP) guidance within both the National Infection Prevention and Control Manual (NIPCM) and the Care Home Infection Prevention and Control Manual (CHIPCM). Ahead of publication and reflecting broad stakeholder involvement in the development of the guidance, NHS Boards have been preparing for implementation of this evidence-based guidance. Scottish Government is committed to working with PSD Scotland, Health Boards and providers in other health and social care settings to support staff in operationalising updated IPC Guidance in the National Infection Prevention and Control Manual