F182 Response Accepted AI-assessed

Statutory duty of openness and transparency

Recommendation

There should be a statutory duty on all directors of healthcare organisations to be truthful in any information given to a healthcare regulator or commissioner, either personally or on behalf of the organisation, where given in compliance with a statutory obligation on the organisation to provide it.

Published Evidence Summary
The following publicly available evidence relates to this recommendation:
The government introduced the Fit and Proper Person Test (FPPT) for NHS directors as part of its response in 2013 (Official government response, 2013). A 2019 review by Tom Kark QC found that the FPPT "does not ensure directors are fit for the post they hold", leading NHS England to publish an updated FPPT Framework effective 30 September 2023 (UK Government, 2023). However, a DHSC review in November 2024 indicated that the statutory duty of candour was often a "tick-box exercise", and the Penny Dash Review of CQC in October 2024 declared the regulator "not fit for purpose" due to significant failings, suggesting ongoing challenges with ensuring openness and transparency at a systemic level (DHSC, 2024).
How was this assessed?
Assessed by gemini-2.5-flash on 24 Mar 2026
Checked data held on this site (government responses, progress updates, independent evidence)
External sources searched: www.gov.uk, www.legislation.gov.uk, hansard.parliament.uk
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 implementation progress from inspectorates, select committees, official progress reports, and other sources. Check the source type badge to see whether each assessment is independent or government self-reported.

Reasonable Progress
26 Nov 2024
DHSC - Duty of Candour Review

DHSC published findings of call for evidence on statutory duty of candour. 261 responses received. Key finding: 52% of respondents said CQC had not adequately enforced the duty. Many reported it had become a "tick-box exercise". Only 40% thought the purpose was clear and well understood. Final government response still pending.

Findings of the Call for Evidence on the Statutor… View Source
limited_progress
15 Oct 2024
DHSC - Penny Dash Review of CQC

Penny Dash Review (commissioned May 2024) found significant failings at CQC. Health Secretary declared CQC "not fit for purpose". Key findings: one in five services never rated; inspection levels well below pre-pandemic levels; lack of specialist inspector expertise; 5,000 notification-of-concern backlog. CQC consulting on resetting its approach from October 2025.

Review into the operational effectiveness of the … View Source
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 Jul 2022
Legislation - Integrated Care Boards (Health and Care Act 2022)

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.

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
Confirmed Completed
27 Nov 2014
Legislation - Duty of Candour (Regulation 20)

Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 20: statutory duty of candour came into force for NHS trusts November 2014, extended to all CQC-registered providers April 2015. Requires providers to notify patients/families of notifiable safety incidents and apologise.

Health and Social Care Act 2008 (Regulated Activi… View Source
Confirmed Completed
07 Nov 2014
Legislation - CQC Fundamental Standards

New "Fundamental Standards" replaced previous CQC registration requirements from 7 November 2014. Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 introduced clearer minimum standards including: person-centred care (Reg 9), dignity (Reg 10), safe care (Reg 12), staffing (Reg 18), good governance (Reg 17), fit and proper persons (Reg 5), duty of candour (Reg 20).

Health and Social Care Act 2008 (Regulated Activi… View Source
Confirmed Completed
01 Oct 2014
CQC - New Inspection Regime

CQC overhauled its inspection regime in response to Francis. Professor Sir Mike Richards appointed as first Chief Inspector of Hospitals (July 2013). New methodology based on five key questions (Safe, Effective, Caring, Responsive, Well-led) rolled out nationally October 2014. Four-tier ratings introduced (Outstanding/Good/Requires Improvement/Inadequate). Specialist expert-led inspection teams replaced generalist compliance model.

CQC Inspection and Ratings Framework 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
Responsible Bodies
Department of Health and Social Care Primary
Recommendation age 13.1 yrs
Last formal update 4508 days ago