F65 Response Accepted

Quality of care as a pre-condition for foundation trust applications

Recommendation

The NHS Trust Development Authority should develop a clear policy requiring proof of fitness for purpose in delivering the appropriate quality of care as a pre-condition to consideration for support for a foundation trust application.

Published Evidence Summary
The following publicly available evidence relates to this recommendation:
- The NHS Trust Development Authority, established in 2012, oversaw NHS trusts that had not achieved foundation trust status. The TDA merged into NHS Improvement on 1 April 2016 (NHS Trust Development Authority, GOV.UK).
- The foundation trust application pipeline was effectively closed by 2014, with most applications paused or deferred. The TDA's focus shifted from supporting foundation trust applications to performance oversight of NHS trusts.
- The Fit and Proper Person Requirement (Regulation 5 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014) came into force in November 2014, requiring providers to ensure directors meet fitness requirements. This applies to all registered providers, not specifically to foundation trust applicants (SI 2014/2936, Regulation 5).
- From 1 April 2023, all NHS trusts are required to hold a provider licence, including Condition FT4 (Governance) which requires systems and processes for escalating and resolving quality issues. Annual self-certification against this condition is required (NHS provider licence conditions, NHS England).
- No published evidence has been identified that the NTDA developed a specific policy requiring "proof of fitness for purpose in delivering the appropriate quality of care" as a pre-condition for foundation trust applications, as distinct from the general quality oversight framework it applied to all NHS trusts.
How was this evidence gathered?
Evidence searched by Claude (Anthropic) on 10 Apr 2026
Checked data held on this site (government responses, progress updates, independent evidence)
Jurisdiction
England
Response
Accepted
Accepted Department of Health and Social Care
19 Nov 2013

The government published "Hard Truths: the Journey to Putting Patients First" (Cm 8777) on 19 November 2013, responding to all 290 recommendations of the Francis Report. This followed an initial response "Patients First and Foremost" in March 2013. Key reforms included a new Chief Inspector of Hospitals, strengthened Care Quality Commission inspection regime, a statutory duty of candour, and the fit and proper person test for NHS directors. Volume 2 (Cm 8754) contains the government's detailed responses to each of the 290 recommendations. See: https://assets.publishing.service.gov.uk/media/5a7cd486ed915d63cc65d167/34658_Cm_8777_Vol_1_accessible.pdf

Read Full Response
Note: Government responded via "Hard Truths: The Journey to Putting Patients First" (2014), a single document covering all 290 recommendations with a blanket acceptance. Individual recommendation responses were not broken out.
Published Evidence

Published assessments of progress from inspectorates, select committees, official progress reports, and other sources. Source type badge indicates whether each assessment is independent or government self-reported.

Reasonable Progress
30 Sep 2023
UK Government - Kark Review of FPPT

Tom Kark QC reviewed the Fit and Proper Person Test in 2019 and found it essentially "does not ensure directors are fit for the post they hold, and does not stop the unfit from moving around the system." NHS England published updated FPPT Framework effective 30 September 2023 requiring standardised board-level assessments.

NHS England Fit and Proper Person Test Framework View Source
Reasonable Progress
06 Feb 2023
Academic Review - Ten Years After Francis

Research published 2023 marking ten years since the Francis Report found mixed results. Structural and legislative changes largely delivered (duty of candour, FPPR, CQC overhaul, revalidation, Freedom to Speak Up Guardians). However, cultural change not fully embedded; understaffing, fear of speaking up, and poor complaint handling persist in parts of the NHS.

University of Birmingham: Ten years after Francis View Source
Confirmed Completed
01 Apr 2016
Legislation - Health and Social Care Act 2012 (Monitor reformed)

Monitor merged with the Trust Development Authority to form NHS Improvement from 1 April 2016. NHS Improvement then merged with NHS England from 1 July 2022 under Health and Care Act 2022. Francis recommended incremental merger of system regulatory functions between Monitor and CQC; this was partially achieved through structural reorganisation.

Health and Care Act 2022 View Source
Good Progress
11 Feb 2015
UK Government - Culture Change in the NHS

Government published "Culture Change in the NHS" (Cm 9009) reporting progress on all 290 recommendations. Key achievements: 19 hospitals placed in special measures; those trusts recruited 109 additional doctors and 1,805 additional nurses; 129 board-level changes made; excess avoidable deaths fell by 450 in less than a year.

Confirmed Completed
27 Nov 2014
Legislation - Fit and Proper Person Requirement

Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 5: Fit and Proper Person Requirement came into force November 2014. Requires providers to ensure directors meet fitness requirements including good character, qualifications, competence. CQC can require removal of directors.

Health and Social Care Act 2008 (Regulated Activi… View Source
Good Progress
19 Nov 2013
UK Government - Hard Truths Vol 1 & 2

Government published "Hard Truths: The Journey to Putting Patients First" (Cm 8777) in two volumes. Vol 1 set out new actions; Vol 2 provided detailed response to each of the 290 recommendations. Approximately 204 of 290 recommendations were fully accepted.

Source
Report Report of the Mid Staffordshire NHS Foundation Trust Public Inquiry 06 Feb 2013
Recommendation age 13.3 yrs
Last formal update 4576 days ago