Rapid reporting of accurate statistics is essential for understanding the causes of deaths from covid-19 and identifying the best means of prevention.  However, in England, registering a death is delayed if the death is referred to a coroner. These delays can be substantial—weeks, months or years—if the coroner determines that an inquest is appropriate. Not even fact-of-death is typically registered with the Office for National Statistics (ONS) until the coroner has determined the cause of death. 
In contrast, these delays do not occur in Scotland, because fact-of-death must by law be registered with National Records of Scotland (NRS) within eight days of death being ascertained. At the time when a death is registered, the registrar informs the NRS if a doctor or the registrar has referred the death to the Procurator Fiscal. Referral to the Procurator Fiscal can also be made after a death is registered, but the NRS will not know about this.
On 13 May 2020, Scotland’s Lord Advocate issued new guidance on presumed covid-19 deaths.  Specifically, the Lord Advocate announced that the Crown Office and Procurator Fiscal Service will register and may investigate all covid-19 or presumed covid-19 deaths where the deceased “might have contracted the virus in the course of their employment or occupation” or “was resident in a care home when the virus was contracted.” The Lord Advocate’s decision is back-dated to apply equally to covid-19 deaths in those two categories that have already occurred.
According to data from the NRS, between 12 January and 24 May, out of 1,255 deaths referred to the Procurator Fiscal, which did not mention covid-19, and in people aged under 65 years with a declared occupation and not-retired, 109 of them were the deaths of healthcare or social care workers. By contrast, between 9 March and 24 May, for people aged under 65 years with a declared occupation and not-retired, out of 49 covid-related deaths referred to the Procurator Fiscal eight were the deaths of healthcare or social care workers.
Thus, the observed PF-referral-rate nearly doubled for covid-mention deaths of working-age health or social care workers during registrations to 24 May 2020 when compared to their PF-referral-rate for non-covid deaths since the start of 2020. Data for England are lacking on the number of covid-mention deaths of health and social care workers that have been referred to the coroner.  For this reason, we had appealed to National Records of Scotland for data that might shed light on this gap for England. Remember that, in Scotland, fact-of-death must be registered for all deaths within eight days. Based on data from Scotland, and assuming a similar referral practice in England, we believe that approximately 90 deaths of health and social care workers from covid-19 may have been referred to coroners in England and Wales. This is of concern if these deaths have not yet been registered with ONS, and therefore are not yet accounted for in official statistics.
During 9 March to 25 May 2020, ONS registered 540 health or social care workers with covid-19 mentioned as cause of death.  Some of these deaths may have been referred to coroners and their investigations completed: but only 32 so far. Hence, we surmise that there may be a substantial number of additional covid related deaths of health and social care workers in England and Wales that have been referred to the coroner but have yet to be registered with ONS. For some, inquest will be intended.
Information, including occupation, on covid-related deaths that are under investigation by coroners is urgently required from the Chief Coroner in England to draw clear occupational-risk inferences. Preparedness for a second wave of covid-19 should ensure that this coronial registration-gap is plugged and that at least some inquests conclude before the end of autumn. 
During a pandemic, an emergency system should be in place whereby the Office for National Statistics is informed immediately about any death referred to coroners so that fact-of-death is duly registered (as for all other deaths) even though the presumptive cause-of-death has yet to be confirmed.
Sheila M. Bird, formerly Programme Leader at MRC Biostatistics Unit, Cambridge and Honorary Professor, University of Edinburgh College of Medicine and Veterinary Medicine.
Neil Pearce, Professor of Epidemiology and Biostatistics, London School of Hygiene and Tropical Medicine, London
Martie Van Tongeren, Professor of Occupational and Environmental Health, Manchester University, Manchester
Conflict of interest: SMB leads for the Royal Statistical Society on the need for legislation to end the late registration of deaths in England, Wales and Northern Ireland.
- Pearce N, Vandenbroucke J, VanderWeele T, Greenland S. Accurate Statistics on COVID-19 are essential for Policy Guidance and Decisions. American Journal of Public Health 2020; 110: 949-951.
- Bird, S.M. (2013). Editorial: Counting the dead properly and promptly. Journal of the Royal Statistics Society Series A, 176, 815 – 817.
- Scotland’s Lord Advocate, see https://www.copfs.gov.uk/media-site-news-from-copfs/1883-revised-guidance-on-reporting-of-deaths-during-coronavirus-outbreak.
- Robertson JFR, Stewart M, Kendrick D, Sewell HF. Covid 19: Protect health and social care workers and refer their deaths to the coroner. It is imperative that there is no further delay in providing every healthcare worker with effective PPE. British Medical Journal (opinion) 2020; 21 April.
- Office for National Statistics. Coronavirus (COVID-19) related deaths by occupation, England and Wales: deaths registered between 9 March and 25 May2020. https://www.ons.gov.uk/peoplepopulationandcommunity/healthandsocialcare/causesofdeath/bulletins/coronaviruscovid19relateddeathsbyoccupationenglandandwales/deathsregisteredbetween9marchand25may2020
- Adebowale V, Alderson D, Burn W, Dixon J, Godlee F, Goddard A, Griffin M, Henderson K, Horton R, Marshall M, Martin J, Morris E, Nagpaul C, Rae M, Rafferty AM, Taylor J. Covid-19: call for a rapid forward looking review of the UK’s preparedness for a second wave – an open letter to the leaders of all the political parties. British medical Journal 2020; 369m2514/doi:10.1136/bmj.m2514.