Supporting pupils with medical conditions policy

The rule: section 100 and the 2015 statutory guidance

Section 100 of the Children and Families Act 2014 requires the appropriate authority for a maintained school, an academy, an alternative provision academy or a pupil referral unit in England to make arrangements for pupils with medical conditions: “The appropriate authority for a school to which this section applies must make arrangements for supporting pupils at the school with medical conditions.” Subsection (2) adds that it “must have regard to guidance issued by the Secretary of State”, and that guidance is Supporting pupils at school with medical conditions, last revised in December 2015.

The Act itself does not use the word policy; the guidance does. Paragraph 9 says “Governing bodies should ensure that all schools develop a policy for supporting pupils with medical conditions that is reviewed regularly and is readily accessible to parents and school staff.” Paragraph 16 puts it more firmly: “Governing bodies must make arrangements to support pupils with medical conditions in school, including making sure that a policy for supporting pupils with medical conditions in school is developed and implemented.” The guidance explains that to have regard means “to take account of the guidance and to carefully consider it. Having done so, there would need to be a good reason to justify not complying with it.” In the guidance, governing body includes the proprietor of an academy (in practice the academy trust) and the management committee of a PRU.

• Covered: governing bodies of maintained schools (excluding maintained nursery schools), management committees of PRUs, and proprietors of academies, including alternative provision academies but not 16 to 19 academies.
• Not covered: under section 100(3) the duty does not apply to a pupil who is a young child for the purposes of Part 3 of the Childcare Act 2006; the guidance says early years settings “should continue to apply the Statutory Framework for the Early Years Foundation Stage”. Independent schools, non-maintained special schools and further education colleges are outside section 100; the guidance names independent schools among those it is provided only “to assist and guide”.
• Statutory text and advice: the guidance says “This document contains both statutory guidance and non-statutory advice. The non-statutory advice is presented in text boxes.” This guide cites the numbered paragraphs as the statutory text and the boxes as the advice after them.

Since 1 September 2026 there is a second, narrower rule. Section 100A, inserted by section 34 of the Children's Wellbeing and Schools Act 2026, says “The arrangements made under section 100 by the appropriate authority for a school to which that section applies must include an allergy safety policy.” Section 05 sets out what that adds.

What the policy should include: the checklist in the 2015 guidance

Paragraphs 10 to 27 of the 2015 guidance list what the governing body should ensure the policy, or the arrangements around it, covers. In order, with the statutory paragraph first and the advice beneath it in brackets:

1. Implementation and a named person (paragraph 10). How the policy will be implemented, “including a named person who has overall responsibility for policy implementation”. (The advice adds who makes sure enough staff are trained, that relevant staff are told about a child's condition, cover for staff absence and turnover, briefing for supply teachers, risk assessments for visits and activities off the timetable, and monitoring of individual healthcare plans.)
2. What happens when the school is told (paragraph 11). The procedures to follow “whenever a school is notified that a pupil has a medical condition”. (The advice: for a new starter, arrangements in place by the start of term; for a new diagnosis or a mid-term move, “every effort should be made to ensure that arrangements are put in place within two weeks”; and “Schools do not have to wait for a formal diagnosis before providing support to pupils.”)
3. Individual healthcare plans (paragraphs 12 to 14). The role of IHPs and who is responsible for developing them; plans “reviewed at least annually, or earlier if evidence is presented that the child's needs have changed”. What a plan should record is covered in medication records in school.
4. Roles and responsibilities (paragraphs 15 and 16). The policy should clearly identify “the roles and responsibilities of all those involved”; section 03 below.
5. Staff training and support (paragraphs 17 to 19). How training needs are assessed and how and by whom training is commissioned and provided; that any member of staff supporting a pupil has had suitable training; and the one staff rule written as a must: “Staff must not give prescription medicines or undertake healthcare procedures without appropriate training”. (The advice: whole-school awareness training and induction for new staff, and “A first-aid certificate does not constitute appropriate training in supporting children with medical conditions.”)
6. The child's role (paragraph 20). Arrangements for children competent to manage their own health needs and medicines. (The advice: wherever possible children carry their own medicines and devices; a child who refuses medicine is not forced, and parents are told.)
7. Managing medicines (paragraph 21). The procedures for managing medicines on the premises. (The advice covers parental written consent for under-16s, no aspirin unless prescribed, accepting only in-date, labelled medicines in the original container, storage, inhalers and adrenaline pens not locked away, disposal and controlled drugs.)
8. Record keeping (paragraph 22). “written records are kept of all medicines administered to children”; the detail is in medication records in school.
9. Emergencies (paragraph 23). What should happen in an emergency. (The advice: each IHP defines what an emergency is for that child and what to do, and if a child needs to go to hospital, staff stay with them until a parent arrives or go with them in the ambulance.)
10. Trips, residential visits and sport (paragraph 24). Arrangements “clear and unambiguous about the need to support actively pupils with medical conditions to participate in school trips and visits, or in sporting activities, and not prevent them from doing so”.
11. Unacceptable practice, insurance and complaints (paragraphs 25 to 27). Section 04 below.
12. Allergy safety (section 100A, since 1 September 2026). The arrangements must now include an allergy safety policy; section 05 below.

The advice also suggests the policy may refer to home-to-school transport, which is the local authority's responsibility, defibrillators, and asthma inhalers held for emergency use, which “is entirely voluntary”. In writing the policy, “schools may wish to seek advice from any relevant healthcare professional.”

Roles: governors, headteacher, staff, parents, pupils and health

The governing body, or the academy trust board, holds the duty. Paragraph 4 of the 2015 guidance lets it confer functions “on a governor, a headteacher, a committee or other member of staff as appropriate”, but says it “remains legally responsible and accountable for fulfilling its statutory duty”, and paragraph 8 says it “must ensure that the arrangements they put in place are sufficient to meet their statutory responsibilities”. The DfE's maintained schools governance guide (section 7.8.3) and academy trust governance guide (section 7.10.3), both updated in July 2026, repeat the duty; the trust guide says “Trust boards (except 16 to 19 academies) must ensure arrangements are in place to support pupils with medical conditions.” Both guides leave it to the board to decide whether and how to delegate the creation, maintenance and approval of policy documents, unless other guidance says otherwise.

The rest of the roles are in the guidance's advice boxes, and the policy should name who does each:

• Headteacher: makes sure the policy is developed and implemented with partners, that staff who need to know are aware of a child's condition and that enough trained staff are available, including in emergencies. “Headteachers have overall responsibility for the development of individual healthcare plans.” The headteacher also makes sure staff are insured, and contacts the school nursing service about a child who has not yet been brought to the school nurse's attention.
• School staff: “Any member of school staff may be asked to provide support to pupils with medical conditions, including the administering of medicines, although they cannot be required to do so.” Administering medicines is not part of teachers' professional duties, but every member of staff should know what to do when a pupil with a medical condition needs help.
• Parents: should give the school “sufficient and up-to-date information about their child's medical needs”, may be the first to tell the school about a condition, are key partners in the IHP, and should be contactable at all times.
• Pupils: should be fully involved in discussions about their support and contribute to, and comply with, their IHP.
• School nurses: every school has access to school nursing services, which are responsible for telling the school when a child has a medical condition that will need support, before the child starts where possible.
• Local authorities: commission school nurses, have a duty under section 10 of the Children Act 2004 to promote co-operation, and should be ready to arrange education when it is clear a child will be away from school for 15 days or more because of health needs.
• NHS commissioners: the 2015 text gives this role to clinical commissioning groups. Section 19 of the Health and Care Act 2022 replaced CCGs with integrated care boards, and CCGs were abolished on 1 July 2022, so a policy written today names the local integrated care board where the guidance says CCG.

Unacceptable practice, insurance and complaints

Paragraph 25 says “Governing bodies should ensure that the school's policy is explicit about what practice is not acceptable.” The advice then lists what is “not generally acceptable practice”, while leaving staff to judge each case against the child's IHP. It is not generally acceptable to:

• prevent children from easily accessing their inhalers and medication and taking them when and where necessary;
• assume every child with the same condition needs the same treatment;
• ignore the views of the child or their parents, or ignore medical evidence or opinion (although it may be challenged);
• send children home frequently for reasons associated with their condition, or stop them staying for normal activities including lunch, unless their IHP says so;
• send an ill child to the office or medical room unaccompanied or with someone unsuitable;
• penalise children for their attendance record when absences relate to their condition, such as hospital appointments (short-term illness is a separate matter: see the school sickness policy);
• prevent pupils from eating, drinking or taking toilet or other breaks when they need to manage their condition (see the intimate care policy for toileting support);
• “require parents, or otherwise make them feel obliged, to attend school to administer medication or provide medical support to their child, including with toileting issues. No parent should have to give up working because the school is failing to support their child's medical needs”;
• prevent children taking part in any aspect of school life, including trips, or create unnecessary barriers, for example by requiring parents to go with them.

Insurance (paragraph 26). Governing bodies of maintained schools and PRU management committees should ensure “the appropriate level of insurance is in place and appropriately reflects the level of risk”, and “Proprietors of academies should ensure that either the appropriate level of insurance is in place or that the academy is a member of the Department for Education's Risk Protection Arrangement (RPA).” The advice says the policy should set out the insurance arrangements that cover staff supporting pupils, that the insurance policies should be accessible to those staff, and that individual cover may be needed for healthcare procedures, so ask the insurer or check the RPA's terms.

Complaints (paragraph 27). The policy should set out “how complaints concerning the support provided to pupils with medical conditions may be made and will be handled”. The advice describes the route: raise it with the school, then the school's complaints procedure; a complaint to the DfE only where it falls within section 496 or section 497 of the Education Act 1996 and other attempts have been exhausted; for an academy, whether it has breached its funding agreement.

The 2015 guidance also reminds governing bodies that some children with medical conditions may be disabled under the Equality Act 2010, in which case they “must comply with their duties under that Act”, and that for children with special educational needs it should be read with the SEND code of practice.

The allergy safety policy, review and what the DfE has proposed

Section 100A of the Children and Families Act 2014 has been fully in force since 1 September 2026 (in force on 29 April 2026 for specified purposes). It defines an allergy safety policy as “a policy for the management of allergies affecting pupils at the school (including the management of pupils at risk of anaphylaxis)” and makes it part of the section 100 arrangements, with duties the medical conditions policy does not carry:

• Annual review: the appropriate authority “must, at least once every year, review the school's allergy safety policy” and make any changes it considers appropriate after the review.
• Publicity: it must make the policy “generally known within the school and to parents of pupils at the school”, and at least once a year take steps to bring it to the attention of all pupils, parents and everyone who works at the school, paid or not.
• Website: it must publish the policy on the school's website.
• Guidance: it “must have particular regard” to the DfE's allergy guidance, a stronger formula than section 100's “have regard”.

That guidance, Allergy safety in schools, was published on 6 July 2026 and sits alongside the 2015 guidance. It says “Schools, colleges and early years settings should have a dedicated allergy safety policy. A named senior leader should be responsible for the policy, which should be reviewed at least annually and published.” The policy should set out how the school identifies pupils with allergy and minimises their exposure to known allergens, including food allergy; how staff are trained in allergy awareness and emergency response; access to prescribed and “spare” adrenaline devices; trips and visits; how IHPs capture the arrangements; how pupils' wellbeing and inclusion are promoted; and how serious incidents and near misses are recorded, reported and responded to. The DfE publishes a template allergy safety policy with it.

On who is responsible, the guidance says “While schools do not need to have a named governor overseeing allergy safety, some schools do so as a matter of good practice”, and “In the case of academy trusts and similar groups of schools or settings, the trust is responsible for the allergy safety policy in its capacity as the governing body”, with a named allergy safety lead in each academy. It says “The Government intends to introduce a statutory duty for schools to have a named senior leader responsible for allergy safety through forthcoming Regulations”; none had been made under section 100B by 3 November 2026, so until they are, the named senior leader is guidance, not law. The guidance was written before commencement and also describes the annual review and website publication as intended; section 100A already requires both. It adds that “Inspectors will consider medical conditions and allergy safety policies and how well they are implemented as part of the inspection process.”

Reviewing the medical conditions policy. No law sets a frequency. Paragraph 9 of the 2015 guidance and both governance guides say the policy should be “reviewed regularly” and “readily accessible to parents and school staff”. The governance guides' lists of policies, which include support for pupils with medical conditions, go further: “It is recommended that governing bodies review these policies annually” (maintained schools), and “We recommend that trust boards review policies related to the statutory guidance and other resources referred to above annually” (academy trusts). Annual review is the DfE's recommendation rather than a legal duty, and reviewing it with the allergy safety policy keeps the two in step. The DfE table of statutory policies that some lists still quote was withdrawn on 7 March 2024; see statutory policies for schools.

What the DfE has proposed but not brought in. The DfE consulted from 5 March to 15 May 2026 on support for pupils with medical conditions at school, including “requiring every setting to have a published medical conditions policy”, strengthening IHPs, and “strengthening recording, reporting and learning from serious incidents and ‘near misses’”. Its outcome, added on 6 July 2026, says the 2015 guidance “remains in force and we will update it in due course”. The government response says it will “remove the requirement for a named lead governor but retain the requirement for a named senior leader”, and will seek forthcoming legislation to extend the section 100 duty “to FE colleges and post-16 institutions, non-maintained special schools and independent schools” – for colleges and other post-16 providers, only in respect of students on DfE-funded 16 to 19 provision. None of this is in force yet; a policy written now follows the 2015 guidance and section 100A.

Where ComplyChat fits, and where it does not

The policy's notification procedure assumes the school is told in an orderly way. Often it is not. A parent messages the class teacher on a Sunday evening to say the consultant has changed the emergency plan. A new diagnosis arrives as a text to the SENCo's own phone. The 2015 advice asks that, for a new diagnosis, every effort be made to put arrangements in place within two weeks, and none of that can start until the message reaches the person who updates the IHP; if the support is later questioned, the school needs to show when it knew.

Start with what ComplyChat is not. It is not an IHP system, a medicines record or a MAR, it does not hold the policy, and it is not a substitute for the procedure the policy describes. If the school already has a system for healthcare plans and medicines that works, keep it.

What it does is give staff, and on paid plans parents, a channel the school runs instead of personal phones. A mobile number verified by SMS is an identity, so a parent needs no account on the school's systems; everyone added to a channel is told it is on the record and can object or leave; and messages are recorded on the server as they are sent. On paid plans, once the school's Microsoft 365 tenant is connected, conversations are kept under the retention schedules within its own Microsoft 365 subscription, so the message that changed a plan stays with the school's records rather than on one person's phone. ComplyChat holds neither Cyber Essentials nor ISO 27001 certification yet.

A question for the next governing board meeting: when a parent tells a member of staff by message that their child's condition or plan has changed, how does that reach the named person, and could the school show the date it arrived?

Questions people ask

Is a supporting pupils with medical conditions policy a legal requirement?

Section 100 of the Children and Families Act 2014 requires maintained schools, academies and PRUs in England to make arrangements for supporting pupils with medical conditions and to have regard to the DfE's statutory guidance, which says those arrangements include a policy that is developed and implemented (paragraphs 9 and 16). Since 1 September 2026, section 100A has also required the arrangements to include an allergy safety policy.

What should a supporting pupils with medical conditions policy include?

The DfE's 2015 statutory guidance says the policy should cover a named person responsible for implementation, the procedure when the school is told a pupil has a medical condition, individual healthcare plans, roles and responsibilities, staff training, pupils managing their own medicines, managing medicines, record keeping, emergencies, trips and sport, unacceptable practice, insurance and complaints (paragraphs 10 to 27). The arrangements must also include an allergy safety policy under section 100A.

How often should the medical conditions policy be reviewed?

No law sets a frequency. The 2015 guidance and the DfE's governance guides for maintained schools (7.8.3) and academy trusts (7.10.3) say the policy should be “reviewed regularly”, and both governance guides recommend that the policies they list, this one included, are reviewed annually. The allergy safety policy is different: section 100A requires it to be reviewed at least once every year, and individual healthcare plans should be reviewed at least annually.

Does the medical conditions policy have to be on the school website?

The 2015 guidance requires the policy to be “readily accessible to parents and school staff”, not published online. The allergy safety policy must be published on the school's website under section 100A(5)(c), and the DfE has proposed, but not yet required, a published medical conditions policy for every setting.

What are the proposals for supporting pupils with medical conditions at school in 2026?

The DfE consulted from 5 March to 15 May 2026 on requiring every setting to have a published medical conditions policy, strengthening individual healthcare plans, recording and learning from serious incidents and near misses, and a separate published allergy safety policy. Its July 2026 outcome says the 2015 guidance remains in force and will be updated in due course; only the allergy safety guidance has been published so far.

Is there a supporting pupils with medical conditions policy template?

The DfE does not publish a model medical conditions policy: its templates for the 2015 guidance cover the individual healthcare plan, parental agreement for medicines, records of medicines given and of staff training, contacting emergency services, and a letter inviting parents to contribute to the plan. It does publish a template allergy safety policy with Allergy safety in schools. Any model policy should be checked against paragraphs 9 to 27 of the 2015 guidance and section 100A.

Official guidance and your next step

The law is section 100 and section 100A of the Children and Families Act 2014. The guidance is Supporting pupils at school with medical conditions with its templates, and Allergy safety in schools with its allergy safety policy template. Governors' duties are summarised in the maintained schools governance guide (7.8.3) and the academy trust governance guide (7.10.3). The 2026 proposals are on the consultation page. Quotations are from those pages as published on 3 November 2026.

This guide summarises law and guidance for schools in England; Wales, Scotland and Northern Ireland have their own rules. It is not legal or medical advice: a pupil's treatment is for their healthcare professionals.

Then do one thing: open your current policy beside paragraphs 9 to 27 of the 2015 guidance and tick each point it covers. Check that it names the person responsible for implementation, says what happens when a parent tells a member of staff about a new condition, and sits with a dedicated allergy safety policy that is on the website and reviewed this year.