THE LENGTH OF time it takes for a death to be registered in Ireland could be reduced from three months to a matter of weeks under a proposal from the Department of Social Protection.

If the proposal is enacted, medical practitioners would have five days to complete a medical certification of cause of death. Once the deceased’s family receives that certificate, they would have five days to register the death.

The new system would quicken up a process that is handled much slower in Ireland than in other European countries and reduce lags in important data used for public health and a range of policy areas.

However, current wait times for an appointment at some civil registration offices can take up to several weeks.

The change would also reduce the amount of time given to grieving families to organise the administrative task during a difficult period.

Five days

Under law, a death in Ireland should be registered within three months at a civil registration office, though that requirement is not met in around one in five cases, according to data from the General Register Office.

An absence of any legal consequence for late registrations means that in practice, deaths can be registered after the three-month period. Lags can impact population statistics that support public health measures and research.

Back in January, Minister for Social Protection Heather Humphreys said that a working group tasked with revising the death registration process was due to finalise its consideration of proposals by the end of March. 

In a statement to The Journal, the department said that it is working with the Department of Health and HSE on the matter.

“Proposals are expected to follow in due course,” it said, without providing further detail.

The changes would require an amendment to the Civil Registration Act 2004, which legislates for the registration of marriages, births, adoptions, divorces, and deaths.

A public consultation last summer outlined a revised process that would include three stages.

Firstly, the registered medical practitioner who pronounces the death would notify the HSE electronically within 24 hours.

Next, the medical practitioner would complete the medical certification of cause of death (MCCD) and send it to the HSE within five calendar days.

Finally, the deceased person’s relative, or “qualified informant”, would receive the MCCD and have five working days to register the death.

Deaths that happen suddenly, in unexplained circumstances, or are suspected to be due to suicide or homicide would still be referred to a coroner first for further investigation.

The public consultation document outlined that “the State’s sole reliance on the process of death registration to provide information on death and its causes is inconsistent with the approach applied internationally”.

“Good quality, complete, and timely information on deaths is an essential contributor to public health management, disease prevention, diagnosis and treatments,” it said.

The timeframes for registering a death in other European countries Public Consultation on Revision of Death Registration Process Public Consultation on Revision of Death Registration Process

Waiting game

Wait times at civil registration offices to register a birth, marriage or death vary widely across the country.

Some offices operate a walk-in system while others require an appointment and some employ a mix of both. Many have little or no wait time at present for an appointment, but others can take up to two or three weeks.

The HSE’s community healthcare organisations (CHO) are responsible for overseeing civil registration offices.

In the Donegal, Leitrim and Sligo area, the local CHO told The Journal that the waiting time for an appointment was a “maximum of two weeks from telephone call to appointment date”.

It said that emergency appointments – for example, where a family has travelled from abroad and needs to return – are accommodated immediately.

Community Healthcare East, which is responsible for registrations in Dublin, Kildare and Wicklow, said: “The current average waiting time for an appointment to register a death in this area is between two and three weeks with a variance of a couple of days for appointments between the different offices in this registration area.”

Offices in Limerick city, Newcastlewest, and Ennis, reported a wait time of one week.

Under the Midlands-Louth-Meath CHO, which also oversees registration in Cavan and Monaghan, offices in Navan, Drogheda and Monaghan operate on a walk-in basis with no appointment required.

In the Dundalk and Cavan offices, which use an appointment system, the wait was one day in Cavan and slightly over a week in Dundalk at the time of enquiry.

The Portlaoise, Tullamore, Longford and Mullingar offices “can offer same-day appointments where available and the maximum waiting time for a death registration appointment is currently two weeks”.

No waiting time was reported for offices in Galway, Mayo, Roscommon, Cork, Kerry, Tipperary, Carlow, Waterford, Kilkenny and Wexford.

At present, the three-month period for registering a death means that while waiting more than a week for an appointment may be an inconvenience, it would not usually mean the difference between registering on time or not.

However, a reduced five-day timeframe with current waiting lists would make registering a death on time at some offices impossible.

There’s also a risk that sudden pressure on the system can cause additional backlog, which was seen in multiple offices last autumn and winter in the wake of the cyberattack on the HSE and the lapsing of Covid-19 legislation that allowed births and deaths to be notified online.

Registering a birth or death became “almost impossible” in some areas of the country, Social Democrats TD Jennifer Whitmore said in a statement at the time.

“I have spoken to people who have called offices up to 100 times before giving up. This is causing a huge amount of distress and anxiety – particularly when families are unable to register the birth of a newborn or the death of a loved one,” Whitmore described.

Labour Senator Marie Sherlock, who has previously highlighted issues with long wait times at civil registration offices, told The Journal that she is “very supportive of an overhaul of the civil registration service that is being proposed by the Department of Social Protection”.

“The starting point in all this, in particular for the registration of a death, it needs to be made as easy as possible,” Sherlock said.

If there has to be an appointment service and a delay, then that is unnecessarily distressing to the families concerned.”

She indicated that it should be highlighted that people are not required to attend the office closest to them.

“Most people assume its regionalised service, that if somebody died in Dublin, they have to go to the office in Dublin, and of course, they don’t, and this is the advice I ended up giving to people last year.”

Alongside the proposed measures, Sherlock said that a system should be implemented that allows families to notify a range of bodies, such as health or financial services, that the deceased person might have been using all at once, rather than having to make individual contact with each one.

In some other countries, when a death is registered, it “sets off a whole set of notifications to public services, to various state agencies that a person had been engaging with”, the senator said.

“Here in Ireland, you have to go and notify the Department of Social Protection, you have to notify the medical card, you have to notify banks – there are so many layers.

“Each individual service provider has to be notified and I think that concept of the one-stop shop is something that we very much need to look at and perhaps could be an extension of what the civil registration office is looking at at the moment.”

Additionally, there should be reform that allows families, if they wish, to register a miscarriage, she said.

“We’ve had a lot of families contact us to see can a provision be put in place, something like a certificate of life or something to recognise them,” Sherlock said.

It would give a “voluntary option to families to be able to opt-in, if they so wish, to have some sort of recognition for that child”.

By the numbers

“The delay in death registration and the reliance on death registration data for public health and public administration purposes has received little attention in recent years,” the Department of Social Protection’s public consultation document said.

“However, the manner in which deaths are registered has been highlighted in recent months, particularly with respect to the need for timely death data in supporting public health measures during the Covid-19 pandemic.”

It was. As the pandemic took hold in Ireland, it cost hundreds of people’s lives, but their deaths weren’t immediately reflected in official figures.

That type of lag has implications for public health policy, where decisions rely on accurate data, but it also opened a floodgate for disinformation about the impact of Covid-19.

In 2020, for instance, a table was published in September that listed that 717 deaths had been registered for July.

Because of the three-month rule, that didn’t mean that only 717 people died in July – it meant that 717 deaths which occurred in July had been registered up to that point. 

However, conspiracy theorists used the figure, which appeared at first glance to be a low number, to say it was proof that Covid-19 was less of a problem than public health officials were describing or that the virus didn’t exist at all – which were untrue assertions.

Currently, it is “not possible to give an exact count of the number of people who die in the State in a particular interval until a significant period has elapsed following death”, the consultation document outlined.

“This is because the official count of those who have died relies on the registration of the death,” it said.

The General Registry Office, which is based in Roscommon, collects information from civil registration offices and sends weekly files to the Central Statistics Office (CSO).

Gerard Doolan is a statistician at the CSO’s Vital Statistics section, which checks and publishes data on births, deaths and marriages.

Speaking to The Journal, Doolan outlined that a faster and digitised process for registering deaths would allow the CSO to publish more timely and precise data.

Currently, it’s preparing its provisional report on deaths in the final three months of 2021, the last of which could have been registered up to the end of March and received by the CSO at the start of April.

“Then it takes about six, seven weeks to process them all, check [them], maybe raise a few queries – there might be corrections or missing information regarding genders or names or dates of birth or dates of death,” Doolan said.

Then we tabulate it all and publish it in a standard quarterly release. There’s a suite of tables and aggregations and breakdowns that we publish every quarter. That’s the provisional stuff.

“Then when it comes to the final data, we publish final data usually in November of each year, so we will be publishing final 2020 data in November of 2022,” he said.

“The reason for that is certain categories of deaths in particular, be they suicides or suspicious deaths or homicides or anything of that nature, there’s a number of deaths that will go to an inquest or a coroner’s report.

“Those can take a while to process and work through the system, so we don’t publish final deaths for about 22 months after the reference period.”

The statistician said that a reduction in the three-month time period to register a death would allow the CSO to publish its reports more promptly.

“We are at the longer end of the scale in terms of EU comparisons with other countries,” Doolan said.

“The knock-on effect is that the shorter the timespan that people have to register a death, the more timely the data can be published and produced for either members of the public or experts who look at these statistics and trends and look at policy decisions using the information on the cause of deaths and maybe possible areas and ages,” he said.

But at the same time… there’s various iterations and cycles to go through once a death happens. You need the hospital doctor, the coroner, etc, to do their little bit of work on it, and then it moves on to the next of kin and then they’re required to go into the registry.

“Some go in straight away, some leave it a few weeks, everyone has their own [circumstances]. They’re going through a process, it’s a very tough time to deal with that.

“I would imagine when the original 90-day timeline was set, it was maybe more on compassionate grounds than on statistical grounds to give people sufficient time so that it wasn’t a pressing requirement.”

He said that digitising the system to allow official documents to be sent electronically would help not just the speed but the precision of the process.

“You’re looking at a big improvement in the level and the detail of the information that can be collected on a death certificate [if] you’re not limited to the space that’s on the paper only,” Doolan said.

“Some doctors and some coroners write down everything – which is fantastic, that’s what you want, you want every possible pre-existing medical condition, you want the person’s full medical history, in order to ensure that the various codings etc are done correctly. And then others put in maybe the main pre-existing health condition.

If you brought in the electronic certification process, then you would improve on the quality of the data, which ultimately would benefit everyone involved.

“It wouldn’t just speed up the process itself, but it would be much more insightful and useful in terms of evidence-based policymaking for the health sector and the HSE in particular.

“But it’s something that needs to be planned out and the required level of resources need to be sent to it.”

The Department of Social Protection did not specify when further details will be made public.