Preserving corporate memory
The NHS Commissioning Board and local commissioners should develop and oversee a code of practice for managing organisational transitions, to ensure the information conveyed is both candid and comprehensive. This code should cover both transitions between commissioners, for example as new clinical commissioning groups are formed, and guidance for commissioners on what they should expect to see in any organisational transitions amongst their providers.
- DHSC and NHS England stated in April 2025 that 'readiness to operate statements' were signed by ICB CEOs and NHS England Regional Directors in June 2022 to provide assurance of organisational transition (DHSC/NHS England implementation update to the Thirlwall Inquiry, April 2025).
- DHSC and NHS England reported in 2025 that due diligence checklists were used during the 2022 transition to ensure the transfer of staff records and information on quality, safety, and finance to new ICBs (DHSC/NHS England implementation update to the Thirlwall Inquiry, April 2025).
- An academic review in February 2023 found that while structural and legislative changes regarding commissioning had been delivered, cultural change was not yet fully embedded across the NHS (Ten Years After Francis, Academic Review, February 2023).
How was this evidence gathered?
Response
Accepted
Response
AcceptedThe 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
Progress Timeline
DHSC and NHS England implementation update provided to the Thirlwall Inquiry (April 2025). This is the government's own account of progress, submitted to the inquiry. Reviewed extent of implementation: Implemented - Ongoing. NHS England provided guidance and support to Clinical Commissioning Groups (CCGs) on CCG mergers and on the preparations for Integrated Care Board (ICB) establishment and facilitated learning and spread of best practice from previous organisational changes. Similarly, for ICB establishment, a comprehensive suite of guidance and additional support was provided by NHS England to help CCGs prepare for ICBs to be legally established. 'Readiness to operate statements' were signed off jointly by designate ICB CEOs and NHS England Regional Directors in June 2022, to provide assurance of robust arrangements for organisational transition. The readiness to operate statements were based on a comprehensive 'ROS' assessment checklist. The ROS assessment included use of extensive staff and property due diligence checklists, signed off by CCG Accountable Officers. The due diligence checklists were designed to ensure that there was no loss of corporate memory at the point of transition, and that key information, for example, staff records and information on quality, safety, finance and any other risks, was safely transferred to the new ICBs. The quality and safety information assets covered open incidents and complaints and learning from previous incidents and complaints. For the calendar year prior to transition, there was significant dialogue between NHS England regional teams and ICBs, ensuring that the ROS checklist and due diligence checklists were not treated as a 'tick box' exercise, but were completed on the basis of a deep and shared understanding of the necessary elements to ensure safe and effective organisational transitions. All statutory transactions are reportable, regardless of their size. Once reported, NHS England will consider whether the proposed transaction is the right solution to the issues it is attempting to address and that the intended benefits will be delivered. NHS England will look at the proposal in detail, using a risk framework to determine its risk rating based on four domains: strategy, transaction execution, quality and finance. The Health and Care Act 2022 granted the requirement for the Secretary of State for Health and Social Care to approve all transactions. NHS England will only grant an application for a merger, acquisition, dissolution or separation where they are satisfied that NHS providers have taken the necessary steps to prepare for the transaction, and where the grant is approved by the Secretary of State.
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.
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.
Clinical Commissioning Groups replaced by 42 Integrated Care Boards from 1 July 2022 under Health and Care Act 2022. ICBs have broader responsibilities for population health, bringing together NHS organisations, local authorities and partners. Implements some Francis recommendations on commissioning integration.
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.
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.