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Set Medical Provision

If you’re arranging medical cover for a film set, TV production or live event in England, it’s important to understand what types of healthcare provision may be subject to regulation by the Care Quality Commission (CQC).

The information below will help you assess whether the type of medical support you plan to provide – and to whom it’s being provided – may fall within the current scope of CQC registration / regulation requirements, and when proposed legal changes take effect.

Key Information

In the UK, healthcare professionals don’t just need to be qualified and registered with their professional body to practise, they (or their organisation) may also need to be registered with the Care Quality Commission (CQC).

The key principle is that it’s the activity (the nature of the treatment being provided) that triggers the requirement for registration, not the qualification level of the person providing it.

For example, Treatment of Disease, Disorder or Injury (TDDI) is a Regulated Activity. It doesn’t matter whether the treatment is given by a doctor, nurse, or paramedic: the moment the service involves diagnosis or treatment beyond what counts as first aid then it’s a Regulated Activity. The provider (the legal entity responsible for the service) must be registered with CQC.

Qualifications (like FREC levels) aren’t connected to / determine the need for CQC registration: FREC levels are a qualification framework, not a regulatory threshold.

Registration with the CQC does not require a particular FREC grade or other medical qualification, conversely having a FREC 6 or any other medical qualification automatically entitle someone to carry on a Regulated Activity – unless they are part of, or supervised within, a registered provider’s governance structure.

Why This Matters

Some types of treatments provided on productions or at events that are currently exempt from CQC oversight will soon come into scope.

Under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, certain types of care are defined as Regulated Activities – regulated by the CQC – including:

TREATMENT OF DISEASE, DISORDER OR INJURY
Anything beyond basic first aid
TDDI

This regulated activity applies to the treatment of disease, disorder or injury in any setting, not just hospitals, clinics, hospices, ambulances, GP and dental surgeries, community services, and care homes.

DIAGNOSTIC OR SCEENING PROCEDURES
Including blood pressure checks, pulse oximetry, or assessments
Diagnostics / Screening

Covers a wide range of procedures related to diagnostics, screening and physiological measurement including taking or analysing samples and physiological measurements where the information is needed to plan and deliver care or treatment.

TRANSPORT / TRIAGE / REMOTE ADVICE
Including hospital conveyance or video consultations
Transport & Triage

Transporting someone who requires treatment in a vehicle designed for the primary purpose of transporting people who need treatment – so ambulances etc are in scope, cars aren’t.

What’s Changing?

It’s been the case for many years that many different healthcare activities are subject to regulation and inspection by the CQC. For example,  treatment of disease, disorder or injury, diagnostic and screening procedures and transporting people in ambulances are the main activities that can impact productions and events, but there are many more.

First Aid and Occupational Health have always been (and remain) out of scope of CQC registration requirements but these are very tightly defined and it’s easy to cross the line between ‘first aid’ and diagnosis or treatment (there’s more on First Aid and Occupational Health below).

Until now there have also been exemptions for temporary healthcare at sporting or ‘cultural’ events, and treatment provided in sports grounds or gyms, but these exemptions are being removed later this year.

This follows safety concerns and recommendations from the second report from the Manchester Arena Inquiry. We await the full text of the enabling legislation, but this means it is very likely that even basic care provided to audiences or members of the public will soon require a CQC-registered provider.

Film and TV productions with crew and cast only (even with some extras or contributors) remain out of scope because these would still be classed primarily as workplaces, not events with public access or participation.

What This Means In Practice

The government is removing the exemption under Schedule 1, paragraph 4(3)(f) and (g) of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 which previously excluded temporary healthcare at sporting and cultural events, and care provided at sports grounds or gymnasiums from CQC scope.

So does this mean all first aid is now in scope? Not necessarily. The CQC and government have not redefined basic first aid itself as a Regulated Activity. However, the removal of the exemption for events will mean changes.

Scenario CQC Scope (after exemption removed)
Event employee gives a plaster to a crew member Out of scope
Contracted paramedic reassures a fainting audience member Likely in scope
On-site provider uses a pulse oximeter at a music festival In scope
Medical tent at sports match gives over-the-counter pain relief In scope
Volunteer gives water and calls 999 Out of scope

So, the type of care might look like ‘first aid’, but currently if it’s provided at an event to members of the public by a healthcare provider, and doesn’t cross a slightly fuzzy line into treatment, diagnosis or triage, it’s out of scope for regulation / registration with the CQC by the provider.

But when the changes come in to law, it will require registration – even if similar care at a private workplace might not.

What about a TV show with an invited audience?

If the invitees are spectators (e.g. for a comedy show, talent show, talk show) and there is first aid provision for the audience (not just cast/crew) then that starts to loook awfully like a ‘cultural event’ under the legislation. This will likely bring it within CQC scope under the amended interpretation – so a medic or paramedic on-site would need CQC registration.

But what about other situations? Use our lookup below, and there are more resources further down the page.

‘Duty of Care’ Dilemma

The Health and Safety Executive (HSE) duty of care applies to everyone on a production – it’s the legal requirement to ensure people’s health, safety and welfare through risk assessment, competent staff, and safe systems of work. It covers everything from stunts to catering, and includes the provision of first aid.

By contrast, CQC registration applies only when an organisation or individual carries on a regulated healthcare activity, such as diagnosing, treating, or prescribing for illness or injury. It’s not about general safety or workplace risk, but about clinical governance and patient care standards.

In short, the HSE duty of care protects everyone on set, while CQC registration governs the delivery of clinical treatment. Productions must comply with both: HSE for overall safety, and CQC wherever healthcare moves beyond first aid.

Yes, this can be a very confusing area but help is at hand. The tool below will help you assess:
  • Whether your production or event might fall within scope of CQC regulation
  • Whether the care you intend to offer - and who it’s for - could trigger a legal requirement for your provider to be registered
  • If you need to ask your chosen provider for proof of CQC registration

You just need to answer what kind of event or setting you're working in, who the care might be offered to and what kind of care may be delivered. Based on your answers, it will provide steer to help you make an informed choice or to seek futher information.
Please note this complex area is very context-dependent. While there is a safety element to this as identified in the Manchester Arena Inquiry (MAI) Volume 2 report, this is primarily a legal question and you should seek expert counsel or ask the CQC if you are in doubt.
Yes, this can be a very confusing area but help is at hand. The tool below will help you assess:
  • Whether your production or event might fall within scope of CQC regulation
  • Whether the care you intend to offer - and who it’s for - could trigger a legal requirement for your provider to be registered
  • If you need to ask your chosen provider for proof of CQC registration

You just need to answer what kind of event or setting you're working in, who the care might be offered to and what kind of care may be delivered. Based on your answers, it will provide steer to help you make an informed choice or to seek futher information.
Please note this complex area is very context-dependent. While there is a safety element to this as identified in the Manchester Arena Inquiry (MAI) Volume 2 report, this is primarily a legal question and you should seek expert counsel or ask the CQC if you are in doubt.

Some activities are clearly regulated or clearly not. But many fall into a grey area — their status depends on who is being treated, where, and how. Here are some common examples where context affects whether CQC registration is required.

Scenario Out of Scope If… In Scope If…
Basic first aid (plasters, ice packs, reassurance) Delivered to cast/crew in a workplace only Delivered to audience or public at an event
Applying dressings Minor wounds, no clinical judgement With clinical judgement (e.g. assessing wound severity)
Taking blood pressure or other vitals For comfort/welfare, no clinical assessment  With intent to assess, diagnose, or decide on care
Calling 999 No care delivered beyond call Accompanied by triage or assessment
Mental health support General wellbeing checks or de-escalation only Clinical decision-making, diagnosis, or safeguarding
Giving oxygen For comfort in known condition (e.g. asthma, under supervision) As part of unsupervised triage or broader treatment
Using pulse oximeter or thermometer For curiosity or non-clinical use Used to inform care or treatment decisions
Triaging a person to continue or leave Welfare-based, no clinical input Clinical judgement made by a healthcare professional
Pain relief OTC painkillers offered informally Analgesics administered with monitoring or prescription advice
On-site care at public event  None provided or basic welfare only Any treatment, assessment, or intervention offered to audience/public

This is an important distinction because it is far too easy to inadvertantly cross the threshold from First Aid to Regulated Activity. The CQC are very prescriptice about this and take a dim view of people identifying as ‘first aiders’ as a means to evade the quite onerous task of CQC registration.

It’s important that productions have a scope of work in place for first aid providers – if they don’t, and the provider carries out a Regulated Activity, the production could face legal jeopardy too.

Essentially, it doesn’t matter what you call it, it’s the activity that counts. This is how the CQC defines First Aid:

First aid is the initial response to a sudden illness, condition or injury or exacerbation of an existing illness, restricted to the aim of either alleviating it immediately through simple procedures and/or preventing it from worsening until professional medical help is available.

First Aiders are limited to only assessing the need for onward referral for treatment, and the CQC also says health care professionals cannot use “other specialist skills that reflect their professional training“, only those skills from their first aid training.

For more detailed information, please refer to the CQC website.

Template First Aid Scope of Work

This will help you define the scope of first aid provision to help ensure it doesn’t slip into Regulated Activities.

This is premium content. To read further, take a look at our Retainer Client packages.

According to the CQC, medical or dental service occupational health schemes that:

  • Do not involve treatment requiring admission to hospital;
  • Are organised through an employer;
  • Were these are for the benefit of the employee only;

…are exempt from the need for registration. But anyone treating a mix of people at events or productions should not rely on the occupational health exemption as a blanket justification for avoiding CQC registration.

Let’s break down what the CQC actually says:

Requirement Explanation
Organised through an employer  The healthcare is arranged as a formal occupational health scheme by the employer – not ad hoc, not outsourced without structure.
For the benefit of the employee only Only employees of the organisation can access the service. Care for freelancers, contractors, contributors or the public is outside scope.
Structured Scheme  The care forms part of a structured health programme (e.g. screening, ongoing assessments), not reactive emergency or walk-up care.
No treatment requiring hospital admission  Any service that includes treatment escalating to hospital care is no longer considered exempt occupational health.

So if set medics are making clinical judgements (such as return-to-work decisions, wound assessment etc), if they’re treating contributors, freelancers, or audience members, if medication is administered, if equipment like pulse oximeters or ECGs are used – and there’s no formal occupational health provider involved, it’s not occupational health.

Argument Flaw
“We’re only here for the crew” Without a structured OH contract this is just workplace first aid or ad hoc triage, not occupational health.
“We’re acting in a preventative role” Unless this is part of a formal, employer-run health programme, it’s reactive care, not prevention.
“We don’t treat the public” Even treating contributors, freelancers, or anyone outside direct employment invalidates the exemption.
“We’re only providing first aid” If clinical judgement, diagnostics, or medicines are involved, it crosses into regulated activity under TDDI.
“The employer pays us” Payment by an employer doesn’t make it an occupational health scheme. The structure and scope of care matter more than who is paying.

You may think an invitation-only corporate event would be out of scope, but that’s not always the case. Even if your guest list is curated and the venue is private, the CQC may still require registration if non-staff (such as clients, press, members of the public) receive healthcare including basic first aid.

With the proposed removal of exemptions for temporary healthcare at cultural events, corporate functions involving audiences or guests will increasingly fall within scope, particularly when the healthcare provided involves triage, diagnostics, or clinical judgement.

Event Type Who Might Receive Care Example Care Provided Current Scope After Legislative Changes
Product launch (e.g. in gallery, event space or cinema) Clients, press, public, non-staff guests Medics on-site, basic triage or treatment offered to attendees Borderline (depends on care level) In scope: public attendees + temporary care = Regulated Activity
Drinks reception or corporate showcase Non-staff such as sponsors, stakeholders, invited press Support for fainting, anxiety, injuries, or oxygen use Likely out of scope if first aid only A ‘works event’ would likely be in scope if non-employees might receive first aid or treament
Film screening or premiere General public, press, VIPs First aid with monitoring, triage, or medication Borderline In scope — falls under cultural event care
Invitation-only brand experience (e.g. immersive exhibition) Members of the public via RSVP, influencers, media Clinical assessment of participant wellbeing, use of diagnostic devices Borderline to in scope In scope
Internal corporate event (staff only) Employees, contractors Basic first aid only Out of scope Still out of scope

If you’re filming news, current affairs or documentary content you may assume that healthcare regulation doesn’t apply, especially if the primary purpose is observation or journalism. However, this is not the case under CQC regulations.

If your production provides or arranges healthcare – even in the context of filming a real event or capturing a news story – you may still be within the scope of CQC regulation.

What matters is not the editorial intent behind the filming, but the nature of the care provided, who receives it, and whether it goes beyond first aid.

This is particularly important for documentaries or investigative projects that:

  • Involve vulnerable contributors
  • Provide on-site clinicians or mobile healthcare
  • Offer screening, triage, or treatment
  • Film at events with public attendees and offer care to them

Even if the filming is incidental or reactive the delivery of any healthcare – not the filming – triggers the regulatory requirement.

Below is a summary of when CQC registration may be required:

Scenario Likely CQC Implications
Filming a public event (e.g. protest, festival, sports) and providing on-site medics for crew only Out of scope, assuming basic first aid only
Filming a public event where medics treat audience or members of the public In scope or soon to be, especially under new rules removing the exemption for temporary event healthcare
Filming vulnerable people (e.g. in care homes, street outreach, or conflict zones) and providing any kind of treatment or triage Very likely in scope, particularly if healthcare goes beyond informal support
Documentary crew brings clinicians to perform outreach, screening or interventions (e.g. mobile units, medical aid) Almost certainly in scope, requires CQC registration or must be delivered by a registered provider

Immersive or Interactive Experiences

Examples: interactive theatre, escape rooms, live-action roleplay (LARP), immersive documentaries.

Risk: if participants are also receiving triage, treatment or medical oversight (e.g. heat exhaustion, anxiety interventions), this may be within scope, especially when the public is involved.

Medical Content and Reality TV

Examples: medical documentaries, shows with health interventions (e.g. weight loss, cosmetic surgery, therapy), reality TV with wellness checks.

Risk: often clearly in scope, especially if there’s clinical assessment, mental health screening, or medical decision-making. Even temporary or remote care could be regulated.

Residential Filming or Extended Production Bubbles

Examples: shows filmed over multiple days with contestants or contributors staying on location.

Risk: long-term welfare often includes medical support, physiotherapy, mental health triage etc. If this care exceeds basic first aid, it’s likely within scope.

The Care Quality Commission regulates activities carried on in England under the Health and Social Care Act 2008.

It does not regulate work delivered outside England,  even if the provider is England-based – Wales, Scotland, and Northern Ireland have their own regulators (HIW, HIS, RQIA). Outside the UK, no CQC jurisdiction applies at all.

If a UK provider sends medics overseas, the provider’s CQC registration applies only to activities carried on in England. When their staff work abroad, they operate outside that regulatory framework. The CQC registration doesn’t ‘travel’ with them and they can’t claim to be delivering CQC-regulated care while overseas – but their own governance, clinical protocols, and insurance still apply.

Wales: Healthcare Inspectorate Wales (HIW)

Regulator under the Care Standards Act 2000 and Health and Social Care (Community Health and Standards) Act 2003.

Oversees NHS and independent healthcare providers in Wales. It has no direct equivalent to CQC registration, but independent clinics and private medical providers must register with HIW. Event medical providers in Wales may fall under HIW if they offer treatment, though the framework is less prescriptive than the CQC’s.

Scotland: Healthcare Improvement Scotland (HIS)

Established under the Public Services Reform (Scotland) Act 2010.

HIS regulates independent healthcare services, including clinics and hospitals, in Scotland. NHS Scotland services are inspected but not ‘registered’. Event or production medical providers offering treatment may require registration as an independent clinic.

Northern Ireland: Regulation and Quality Improvement Authority (RQIA)

Established under the Health and Personal Social Services (Quality, Improvement and Regulation) Order 2003.

RQIA regulates independent health and social care services in Northern Ireland. Providers offering medical treatment, diagnostics, or similar activities must be registered with RQIA.

Outside the UK

Productions must still ensure competent medical provision under HSE principles (as far as reasonably practicable) and local law where filming occurs. Always check local regulations: some countries restrict who can provide medical treatment or require local registration, especially for prescription drugs or emergency care.

Best practice:

  • Use registered providers to assure governance framework.
  • Confirm insurance covers overseas work.
  • Ensure local compliance where treatment is delivered.
  • Treat the service as unregulated under UK law, but still bound by UK duty of care and ethical standards.

Key Information

The key principle is that it’s the activity (the nature of the treatment being provided) that triggers the requirement for registration, not the qualification level of the person providing it.

For example, Treatment of Disease, Disorder or Injury (TDDI) is a Regulated Activity. It doesn’t matter whether the treatment is given by a doctor, nurse, or paramedic: the moment the service involves diagnosis or treatment beyond what counts as first aid then it’s a Regulated Activity. The provider (the legal entity responsible for the service) must be registered with CQC.

Qualifications (like FREC levels) aren’t connected to / determine the need for CQC registration: FREC levels are a qualification framework, not a regulatory threshold.

Registration with the CQC does not require a particular FREC grade or other medical qualification, conversely having a FREC 6 or any other medical qualification automatically entitle someone to carry on a Regulated Activity – unless they are part of, or supervised within, a registered provider’s governance structure.

Advice to Productions

Golden Rule: it’s the activity that’s regulated not the qualification.

If care beyond basic first aid is provided, by the end of 2025 CQC registration will almost certainly be required, and the traditional exemptions for event medical cover (sporting, cultural, production settings) are going. Soon.

Check Provider Status

  • Ask for their CQC registration number, or confirm that their work is limited to first aid only (and have this defined in a written contract so if a provider crosses the line into a Regulated Activity the liability rests with them).
  • If they are providing a Regulated Activity make sure their registration covers the activity they’re being contracted for. Remember that FREC levels / other medical qualifications are not related to regulation requirements.
  • Duty of care is not the same as CQC scope. The HSE governs safety and competence, CQC governs clinical care. You need to cover both.

What productions should do:

  • Prepare for the new rules now.
  • Audit medical providers and confirm CQC status.
    – Ask for their registration number and scope of regulated activity.
  • Define scope of service in contracts with providers.
    – Clarify whether the provider is delivering first aid or regulated treatment – if they are contracted to provide first aid only but veer into regulated territory, this will help protect you.
  • Verify clinical governance arrangements are in place.
    – You don’t need to assess them, but ensure the provider can evidence governance through CQC registration.

External Resources

Set Medical Provision | International Advice

Specialist: Ben Teden

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Ben is a health and safety consultant with a background in front line ambulance operations as a Paramedic. With hands-on experience as a medic and COVID supervisor on a range of film and TV productions, he brings practical, production-focused insight to every project.

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Article last updated on Oct 14th, 2025

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