Recommendation F167: Approved Practice Settings
From Report of the Mid Staffordshire NHS Foundation Trust Public Inquiry, published 6 February 2013.
Recommendation
The Department of Health and the General Medical Council should review the powers available to the General Medical Council in support of assessment and monitoring of approved practice settings establishments with a view to ensuring that the General Medical Council (or if considered to be more appropriate, the healthcare systems regulator) has the power to inspect establishments, either itself or by an appointed entity on its behalf, and to require the production of relevant information.
In brief (written by this site)
In commentary from September 2024, published in February 2026, the Department of Health and Social Care and NHS England reported that the recommendation was partially implemented and closed, stating that the General Medical Council embedded approved practice settings within the Responsible Officer Regulations in June 2014 (DHSC and NHS England, Feb 2026). The Thirlwall Inquiry legal team noted in May 2024 that the government accepted the proposal in principle, reviewing the 2014 changes alongside the Care Quality Commission's existing powers to inspect premises (The Thirlwall Inquiry legal team, May 2024).
AI-generated summary of the record on this page, checked by a second model and automatic checks, 26 Sep 2026. The record below is the sources' own words.
Government response
Accepted in principle.
The General Medical Council has undertaken a fundamental review of Approved Practice Settings. This review considered Approved Practice Settings in the context of the General Medical Council’s functions and how they promote assurance and patient safety. Since Approved Practice Settings was introduced in 2007, the General Medical Council has acquired significant powers relating to quality assuring medical training environments the Responsible Officer regulations have come into force and revalidation has begun. Revalidation is the process by which licensed doctors are required to demonstrate on a regular basis that they are up to date and fit to practise. It represents a major step forward in the quality assurance of practising doctors.
The General Medical Council review has found that these new powers have superseded Approved Practice Settings as a source of regulatory assurance and has recommended that the legal provisions that deal with Approved Practice Settings should be reviewed as part of the Law Commission review of the regulation of health and social care professionals. This will however take time, and in the meantime there is an opportunity to align the Approved Practice Settings requirements with those in the Responsible Officer Regulations. In effect, this would mean that newly registered doctors or doctors recently restored to the register must, while in the UK, practise in circumstances where they have a connection to a designated body, which is an organisation that will provide regular appraisal and help with revalidation.
How this response relates to the recommendation
Site note: This is volume two of "Hard Truths: The Journey to Putting Patients First" (Cm 8777-II), the government's response to the Inquiry's 290 recommendations, published by the Department of Health on GOV.UK on 19 November 2013 and dated to that day here. The PDF the row links to is the accessible edition, whose title page reads "January 2014". The Department of Health has been the Department of Health and Social Care since January 2018. The volume says it includes accounts from each of the national organisations the recommendations name, but it does not mark which passage each organisation wrote, so every row is filed under the Department that published it.
Blanket government agreement does not establish acceptance or delivery by each addressee. Some response passages cover groups of recommendations.
Scope of the government response
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.
Delivery
DHSC and NHS England say partially delivered (27 February 2026)
Following the recommendations made about approved practice settings in the Report, the GMC committed to undertaking a fundamental review of the scheme in 2013.
The review concluded that the GMC should embed the approved practice settings arrangements within the wider statutory framework of the Responsible Officer Regulations. In effect, this prevents doctors who are newly registered or recently restored to the register from practising if they do not have a prescribed connection to a designated body and Responsible Officer (RO) under the regulations. A prescribed connection ensures that a doctor is working for an organisation that has established clinical governance and oversight including monitoring clinical effectiveness and quality assurance of its services. All doctors in postgraduate training are placed in providers that are designated bodies and themselves have a prescribed connection to an RO within the relevant Deanery. The new arrangements were introduced in June 2014.
Site note: DHSC and NHS England's own account of progress, supplied to the Thirlwall Inquiry in September 2024 and printed in the Inquiry legal team's Review of Implementation of Recommendations from Previous Inquiries into Healthcare Issues (version dated April 2025, published 27 February 2026). It is not a finding of the Inquiry. Their reviewed extent of implementation reads “Partially implemented - Closed”. Table row: section 18.2 No. 167, PDF page 505.
Department of Health and Social Care says in progress (11 February 2015)
Following the General Medical Council’s fundamental review of Approved Practice Settings (APS), new APS requirements were introduced in June 2014. These align the APS regime with the Responsible Officer Regulations. Doctors subject to APS requirements must now hold a prescribed connection to a designated body in order to practice in the UK. Designated bodies are, for the most part, organisations that employ or contract with licensed doctors. Designated bodies are under a statutory duty to have systems in place to support the continuous evaluation of all doctors with a connection to their organisation. They must have an appraisal system in place for these doctors and support them with their revalidation.
This ensures that these doctors are subject to the clinical governance arrangements required for revalidation, such as regular appraisals based on the General Medical Council’s core guidance for doctors, and are no longer restricted to practising in a specific physical setting and should be clearer for doctors and the organisations that they employ or contract with them.
The Care Quality Commission has a key responsibility in the overall assurance of levels of safety and quality of health and adult social care services. The Care Quality Commission already has powers to enter and inspect premises under the Health and Social Care Act 2008, section 62(2), which states ‘A person authorised by the Commission may enter and inspect any premises which are, or which the person reasonably believes to be, regulated premises’. This will normally be a health or care home setting.
The Law Commission’s report and draft Bill were published on 2 April 2014. The Law Commission made 125 recommendations intended to simplify and modernise the UK law relating to the regulation of health care professionals and, in England only, the regulation of social workers. The Government responded to this report on January 29th 2015 and legislation will be brought forward when Parliamentary time allows.
Site note: This is the supporting annex published on 11 February 2015 with "Culture change in the NHS: applying the lessons of the Francis Inquiries" (Cm 9009), attached to the GOV.UK page as "Culture change in the NHS supporting annex". The annex has no title page; that title is GOV.UK's and the PDF's own. Its table has four columns (No., Recommendation, Hard Truths Government response, Progress update), and the row carries the Progress update cell. No column says which organisation wrote an update, so the row is filed under the Department of Health (now the Department of Health and Social Care), which published it.
Site note: The Inquiry addressed this recommendation to the General Medical Council, not to the Department of Health. The annex gives this update in the Department's publication and does not say who wrote it, so the row is the Department's report of the progress made on it.
What other bodies have found
In their own words. These do not change the delivery statement above.
Thirlwall Inquiry legal team (15 May 2024)
Accepted by the Government in principle.
The General Medical Council undertook a review of the Approved Practice Setting scheme in 2013. The review concluded that it should be replaced by a new scheme which was aligned with the existing statutory duties for healthcare organisations, namely the Responsible officer Regulations. This prevented newly registered or recently restored doctors from practicing in circumstances where they did not have a ‘prescribed connection to a designated body’. The new Approved Practice Setting requirements were introduced in June 2014.
In the February 2015 Culture Change report, the Government referred to the role of the Care Quality Commission in the overall assurance of levels of safety and quality of healthcare services, it already having powers to enter and inspect premises.
Site note: The Thirlwall Inquiry legal team's own notes on implementation, from its Review of Implementation of Recommendations from Previous Inquiries into Healthcare Issues (version of 15 May 2024). The review does not colour its Extent of Implementation cell for this recommendation green; it leaves the cell uncoloured where a recommendation was rejected, where evidence of implementation was insufficient, or where steps had been taken but implementation was not yet complete. Table row: section 16.2 No. 167, PDF page 472.
Source
Responsible bodies
Themes and tags
Who has spoken
- Department of Health and Social Care
Response, delivery statement - DHSC and NHS England
Delivery statement - Thirlwall Inquiry legal team
Finding