“Isabelle is 15 years old with complex needs.” So begins one of the many ‘case studies’ in the Care and support statutory guidance. We learn that “when Isabelle leaves school at 19 it will not be appropriate for her to live with her parents and she will require substantial supported living support and a college placement. Due to the nature of Isabelle’s needs, she will need a lengthy transition in order to get used to new staff, a new environment and a new educational setting.” [1]

We don’t learn who Isabelle is. Who, or what, she loves. What makes her smile, laugh, rage, cry. What gifts she brings. What ambitions she has. What matters most to her.

We don’t even know what Isabelle’s “complex needs” actually are.

Isabelle is a teenager on the cusp of adulthood, but her present is described – and her future is defined – by those two little words. 

Complex needs.

The term ‘complex needs’ is one of those phrases we use with abandon in the world of social care, health, education and beyond. It shapes the way we think and the way we work. We structure our teams and services around complexity. “Complex Needs Team.” “Complex Adults Team.” “Complex Cases Team.” “Complex Lives Team.” First conversations aim “to ensure that complex needs are identified early and that people are signposted appropriately.” [2] “Professional staff… focus on more complex cases.” [3] Student placements offer opportunities for “working with people with complex needs” [4] and we recruit social workers to “work autonomously with highly complex needs” and with “service users with a range of complex needs”. [5]

But what does the term “complex needs” actually mean? And why does it matter?

Definition

There is no legal definition of ‘complex needs’. The phrase does not appear in the Care Act 2014, Mental Capacity Act 2025, Human Rights Act 1998 or the Equality Act 2010.

Given how ubiquitous the term is, there are very few actual definitions out there at all.

The National Institute for Health and Care Excellence offers the most explicit explanation in NICE Guideline NG216,‘Social work with adults experiencing complex needs’. Even then, the document doesn’t define ‘complex needs’ but says “adults with complex needs are defined as people aged 18 or over who need a high level of support with many aspects of their daily life, and relying on a range of health and social care services. This may be because of illness, disability, broader life circumstances or a combination of these. Complex needs may be present from birth or develop over the course of a person’s life, and may fluctuate.” [6] 

The Department for Work and Pensions also has a go, defining complex needs as “difficult personal circumstances and/or life events”, which “may be permanent or temporary in nature.” [7] 

But in general, the phrase is used without definition. Last year’s NHS 10 year Health Plan for England set “a new standard that, by 2027, 95% of people with complex needs will have an agreed care plan” and concludes that the plan will mean “better continuity of care for those with the most complex needs”. [8] However, in January 2026 when Lord Blunkett asked “His Majesty’s Government what is their definition of “complex needs” in the 10 Year Health Plan”, he was told by Baroness Merron that “work is currently underway to determine the definition of “complex needs” in the context of this target”. [9]

Maybe I’ve missed something, but I’m pretty sure we still don’t know.

And complex needs

I’m genuinely fascinated by the use and ubiquity of the phrase. It pops up all over the place, often to ‘explain’ the remit of organisations, who support people with “disabilities and complex needs”, “autism and complex needs”, “learning disabilities and complex needs”, “sensory impairment and complex needs”, “personality disorder and complex needs”, “dementia and complex needs”, “PMLD and complex needs”, “mental health and complex needs”, “challenging behaviours and complex needs”…

‘And complex needs’ has become a generic add-on. An additional (non-)descriptor tacked on to a diagnosis impairment condition assumption label judgement.

It also appears alongside other types of ‘need’, implying clarity yet offering absolutely none. “Serious and complex needs.” “Multiple and complex needs.” “Severe and complex needs.” “Unique and complex needs.” “Additional and complex needs.” “Physical and complex needs.” “Profound, severe and complex needs.” “Diverse and complex needs.” “High and complex needs.” “Higher level and complex needs”. “Highly specialised and complex needs”.

Clear?

Of course not.

How complex?

Even though we have absolutely no clarity or shared understanding about what the phrase ‘complex needs’ means, we’ve managed to introduce an element of competition. Ranking. Complexity top trumps.

Despite being one the phrases that most makes me go hmmm, it’s taken me a while to get round to writing this blog post. Every time I’ve been swimming of late, I’ve been thinking about it. I’m a relatively decent swimmer – but relatively is key here. I have an off-peak gym membership. Often the pool is quiet when I go, so I swim in the ‘fast’ lane, and occasionally even lap other swimmers in the same lane. If folk swimming super-speedy front crawl get in though, I’m quickly lapped, so I change lanes to ‘medium’. My lane, and pace, is defined by – and in relation to – other swimmers. Fastest. Faster. Similar. Same. Slower. Slowest. But if I happened to be alone in the pool, I’d still have the choice of the slow, medium or fast lanes. I’d define my pace. I’d be the fastest swimmer in the pool, and the slowest.

The Care Act guidance alone refers to “less complex needs”, “more complex needs”, “particularly complex needs”, and “the most complex needs”.

Less. More. Particularly. Most.

Compared to?

Why it matters

“The other phrase that we must never ever be drawn into is “complex needs”. It’s a shifter of responsibility, a justification for anything, a checkmate conversation killer, all rolled into one. Died a preventable death? Ah yes, but she had complex needs. Entering his 16th year in an ATU? Ah yes, but he has complex needs. LA won’t fund a home care package? Ah yes, we cannot find a provider that can manage his complex needs. It’s the get out clause of all get out clauses. It’s the king of multi disciplinary one-upmanship.” – Mark Neary [10]

I wrote in my previous blog post that “placement is one of my top ‘hmmm words’, because it sums up so much about what is wrong with our thinking and practice in social care.” [11] I feel the same about ‘complex needs’. The phrase exposes so much that needs to change.

The fact that we use it so ubiquitously but without definition illustrates an approach where we put classification before curiosity. Where we assume rather than ask. Where labels determine identity and dictate a response. 

It sure is, as Mark Neary writes, the “get out clause of all get out clauses”, as well as a ‘get in clause’ used to get a foot in the door, a tick in the box, a nod from the panel. Mark suggests it’s “a justification for anything”, and we see this repeatedly in restrictive options presented as if there is no choice. 

“For some individuals, residential care may be the most suitable option when their needs become too complex to manage at home.”

“There is a variety of support available for people so that they can stay in their own home but if this can’t be achieved (for example, someone’s needs are too complex), then a care home may be best to meet their needs.”

“These individuals are discharged to a care home because their needs are too complex to be managed at home or in a short-term setting.” 

As with all the words that blame, ‘complex needs’ implies the person is the problem. A recent Ofsted report acknowledges that there is “ambiguity around the term “complex needs… People often use it as an umbrella term for a variety of different needs or to refer to children who are “difficult to place”.” [12]

Yup, let’s be honest. ‘Complex needs’ equals difficult.

‘Complex needs’ suggests you don’t fit neatly into our boxes processes pathway services.

‘Complex needs’ means we don’t really know what to do with you.

Maybe there is a definition after all.

In her book, Diagnosis: Human, Elly Chapple writes, “we absolve ourselves of responsibility instead of seeking to understand the people around us. Calling someone “too complex” or “too challenging” might seem like an easy solution but it pushes us away. It enables us to stay at a distance rather than truly engage. It avoids the discomfort of self-examination and blocks the very connection we say we value. [13]

Elly also writes how her daughter Ella is “rooted in herself, moving in her own lane” and how “she invites people into her world, and something shifts.” 

“The labels of “complex” and “challenging” that might have run through [people’s] minds quickly fade away. What remains is a simple, human act of connection. They begin to recognise how much she is like them and that her needs are the same as theirs.” – Elly Chapple [14]

Her needs are the same as theirs. As all of ours. Air food water shelter safety love belonging connection meaning purpose. And yes, our needs may all be met in different ways and these ways may be tangled and messy – but that generally tells us more about the siloed, bureaucratic, transactional complexity of serviceland than about anyone we so casually attach the ‘complex needs’ label to.

Too often we force people down the narrow swim lanes of our systems, determining their lane and their direction through our screening tools, assessments and eligibility determinations. We leave people treading water until they’re drowning, then we haul them out from the side with our fraying safety nets.

Instead, we need to get into the water alongside people. Join their lane, swim at their pace, and help create the conditions for people to breathe again.

Human needs, not complex needs.

---

References

[1] Care and support statutory guidance, Department of Health and Social Care, GOV.UK, Updated 22 July 2025

[2] Care and support statutory guidance, Department of Health and Social Care, GOV.UK, Updated 22 July 2025

[3] Care and support statutory guidance, Department of Health and Social Care, GOV.UK, Updated 22 July 2025

[4] Professional language, Bryony Shannon, Rewriting social care, 28 October 2023

[5] Recruiting robots: the language of social work job adverts, Bryony Shannon, Rewriting Social Care, 24 July 2021

[6] Social work with adults experiencing complex needs, NICE guideline NG216, National Institute for Health and Care Excellence, 26 May 2022

[7] Chapter 6: Working with Participants with complex needs and /or additional support requirements, Department for Work and Pensions, GOV.UK, Updated 1 April 2026 

[8] 10 Year Health Plan for England: fit for the future, Department of Health and Social Care, Prime Minister’s Office, 10 Downing Street, The Rt Hon Sir Keir Starmer KCB KC MP and The Rt Hon Wes Streeting MP, GOV.UK, 3 July 2025

[9] Question for Department of Health and Social Care, UIN HL14044, tabled on 28 January 2026, UK Parliament

[10] A new conversation, Mark Neary, Love, Belief and Balls, 12 July 2017

[11] Words that make me go hmmm: Placement, Bryony Shannon, Rewriting social care, 18 July 2026

[12] How local authorities and children’s homes can achieve stability and permanence for children with complex needs, Ofsted, GOV.UK, 16 January 2024

[13] Diagnosis: Human, Elly Chapple, Flip the Narrative Publishing, 2026

[14] Diagnosis: Human, Elly Chapple, Flip the Narrative Publishing, 2026