We recently responded to a Care Quality Commission (CQC) public consultation on proposals to improve how it assesses health and care services, makes judgements, and awards ratings.
The CQC's Better regulation, better care consultation sets out a number of changes, including reintroducing clear rating characteristics, developing sector specific assessment frameworks, simplifying content, and strengthening the role of professional judgement. It also sought views on trust level ratings for NHS trusts.
In our response to the consultation, we welcomed the opportunity to make it clear that research should be seen as a normal and important part of good care, not separate from it.
Research is integral to, and a hallmark of, high-quality patient care and associated with improved patient experience and therefore there is value in this being clearly and consistently reflected in CQC assessment frameworks, rather than remaining implicit.
Clearer expectations in CQC assessments will make it easier for services to support research well and for the public to see how research improves care and patient experience. Recognition of inclusive, well-run research across different care settings, with clearer expectations around research governance, organisational culture, staff engagement in research, and meaningful patient and public involvement, can help build trust and ensure that the benefits of research are shared more fairly.
We welcomed the consultation’s focus on equality and human rights, noting that equitable access to research is central to addressing health inequalities and a core objective of the HRA’s strategy. We emphasised that assessments of research should consider whether organisations actively promote inclusive participation and ensure that research benefits all communities.
We also welcomed CQC’s commitment to collaboration and co-production. Building on previous joint work, we reiterated our willingness to support the CQC in defining clear research standards and assessment questions, and in embedding research as a visible and valued component of high-quality care across all sectors.
Our response to the CQC’s consultation reflects our commitment to a health and care system that recognises research as a core component and driver of high-quality care. By ensuring that research is visible and valued within assessment frameworks, we can support a system where research is embedded throughout the NHS, trusted by patients and the public and effective in improving care for everyone. This is central to our vision of high-quality health and social care research today, which improves everyone’s health and wellbeing tomorrow.
Read our response
The HRA's full response to the CQC Better Regulation, Better Care consultation (submitted 11/12/2025)
Describing our expectations of quality for all our rating levels
We propose to re-introduce rating characteristics as part of our assessment frameworks.
Question 1: To what extent do you agree that we should publish clear rating characteristics of what care looks like for each rating as part of our new assessment frameworks
HRA response: strongly agree
Providing a clearer view of quality and safety for the sectors that we regulate
We propose to re-introduce assessment frameworks that are specific to each sector, which more clearly reflect and articulate the context of those health and care sectors.
Question 2: To what extent do you agree with our proposed approach to developing assessment frameworks that are specific to each sector?
(optional)
HRA response: strongly agree
Question 2a: Do you have any comments or suggestions on how we should develop the sector-specific assessment frameworks?
(optional)
Research findings help to improve care wherever it is provided. It helps us better understand ill-health so that we can act to prevent it and to stay well longer. It is an essential part of high-quality healthcare and as such, should be embedded throughout the NHS.
The HRA would welcome the reintroduction of rating characteristics as part of assessment frameworks to provide a clear structure to the assessment approach. In this change of approach, the HRA would strongly encourage continued recognition of ‘clinical research activity in the NHS as a key component of best patient care’. We would advocate this not only to be carried forward but strengthened to ensure the importance of incorporating research as a core standard for all health and care providers is clear.
In line with the UK Government’s 10 Year Health Plan for England expectation that hospitals make research business-as-usual activity, not a ‘nice to have’, the HRA would welcome additional measurements. These would include measurements that assess research-related activity and capability, including, but not limited to, participation in clinical trials, research funding and patient participation in research. Embedding research throughout the NHS will support the government to achieve its commitments to turbocharge medical research and enable millions to take part in clinical trials.
Current references to research under the ‘Well-led’ framework should be emphasised and expanded upon. Where research practice consideration could be implied in other areas, such as ‘Effective Care’, it should be more explicitly named as research. We are happy to assist in collaboratively formulating measures that appropriately capture this.
The HRA is supportive of the proposed approach to develop sector specific frameworks to allow for differences across settings. We are reassured that there is an intention to maintain a high degree of consistency. Again, we would expect explicit indicators for research to be included in each framework in relation to participation and governance whilst ensuring it is clear that research is a core standard for all health and care providers. We believe this change in approach allows for indications of good research approach, practice and infrastructure to be assessed in a manner appropriate to each setting. For example-
- In hyper acute settings is research effectively embedded within clinical pathways to make research possible in emergency situations
- In community settings where there is less infrastructure and knowledge of research is there adequate communication and engagement around research
Whilst also being clear that some markers are relevant across sectors, for example-
- is there appropriate access to relevant personnel equipment and space to support research
- is there infrastructure to allow for compliance with and commitment to research transparency requirements and or best practice.
The HRA can support in highlighting sector specific considerations relevant to research.
Making our assessment frameworks simpler and clearer
We propose to improve our assessment frameworks by removing content that could duplicate or overlap across the different key questions and simplify the language to make them easier to understand.
Question 3: To what extent do you agree with our proposed approach to making our assessment frameworks clearer and removing areas of potential duplication?
(optional)
HRA response: agree
Question 3a: Do you have any comments on the content of our current single assessment framework, or suggestions for how we should make our assessment frameworks simpler and clearer?
HRA response: No
Simplifying our rating approach and strengthening the role of professional judgement
To reflect the quality of services clearly and simply, we propose to no longer award separate scores underneath our key question ratings, and for rating characteristics and professional judgement to have a key role in making judgements.
Question 4: To what extent do you agree that we should award ratings directly at key question level with reference to rating characteristics
HRA response: agree
Question 5: Do you have any comments or suggestions for how we should support our inspection teams to deliver expert inspections, impactful reports and strong relationships with providers?
HRA response: Professional judgement, supported by clear rating characteristics, is appropriate, as long as indicators relating to research are well embedded. We acknowledge this approach aims to provide clarity in the awards given to provide confidence to the public and providers to understand CQC judgements with regards to the quality and safety of an institution. The HRA would ask that in a rounded assessment approach it is clear to the public, providers and assessors that research activity is an integral component in assessing the expectations of quality and safety.
Reviewing and clarifying our approach to following up assessments and updating rating judgements
When updating ratings for a service we aim to ensure that our judgements are not affected by evidence or other ratings that are significantly out of date. We will consider the length of time since the last assessment and evidence of improved quality.
Question 6: To what extent do you agree with the approach to following up assessments and the principles for updating rating judgements?
HRA response: agree
Potential changes to our approach to rating NHS trusts and independent hospitals
We are asking for feedback on whether we should re-introduce an overall quality rating for NHS trusts, and a supporting structure of trust-level ratings of all 5 key questions, and remove location-level aggregated ratings for NHS acute trusts and independent hospitals.
Question 7a: To what extent would you support CQC in re-introducing an overall quality rating for NHS trusts and trust-level ratings of all 5 key questions?
HRA response: fully support
Question 7b: To what extent would you support CQC in no longer aggregating key question ratings to produce an overall rating for an individual hospital location?
Question 7c: Do you have any comments to support your views, or suggestions for how we should award ratings for NHS trusts and independent hospitals?
HRA response: It is important that assessment frameworks include explicit consideration of research, as this is a core expectation for NHS trusts. We support appropriate transparency to incentivise NHS Trusts to meet research expectations. Making it easy to see how well each trust is performing specifically in supporting research would be an important lever to drive improvement and accountability. Ratings should incorporate research performance explicitly and this information presented in a way that is accessible and meaningful to patients, staff, and the public.
Measuring the impact on equality
Question 8: We'd like to hear what you think about the opportunities and risks to improving equality and human rights in our proposals. Do you think our proposals will affect some groups of people more than others (for example, those with a protected equality characteristic such as disabled people, older people, or people from different ethnic backgrounds). Please tell us if the impact on people would be positive or negative, and how we could reduce any negative effects?
HRA response: The HRA are encouraged by the equality and human rights impact assessment considerations and action plan as laid out in the consultation in establishing a new approach to assessing providers. In addition to this proactive approach we see there is opportunity for the proposals to have a positive impact on equality if research inclusion is considered in assessments.
Research plays a critical role in addressing health inequalities with greater access enabling us to use research findings to improve outcomes for the whole population. Our HRA strategy advocates for health and social care research to be done with and for everyone to help reduce health inequalities.
Providers should be assessed on their efforts to embed inclusive research practices into their services along with any specific efforts to include underrepresented groups in research. We recommend incorporating measurements on inclusive research practices within the equality framework, such as ‘evidence of equitable access to research opportunities for patients’. The HRA can provide support in drafting measurements of inclusive research.
Question 9: Do you have any other comments on our work, things we should consider, or suggestions for how we could improve?
HRA response: Thank you for the opportunity to respond to the Care Quality Commission’s (CQC) consultation on improving assessment frameworks and rating methodologies. As a regulatory body responsible for promoting and protecting the interests of people in health and social care research, the Health Research Authority recognises the importance of robust assessment frameworks that ensure safety, transparency, and public trust (see “Who we are” at end of this section)
Our mission is to make it easier to do research that people can trust that can improve everyone’s health and wellbeing. Key to achieving this is ensuring that the NHS is able to support high quality health and social care research.
We would like to offer the following observations and recommendations.
Recognition of research
As research is key to the provision of high-quality patient care and is linked to improved patient experience (see: A qualitative systematic review and thematic synthesis exploring the impacts of clinical academic activity by healthcare professionals outside medicine we want to ensure research is appropriately reflected in CQC assessments.
As such we recommend that research activity continues to be a marker of best care rating characteristics under ‘Well-led’. We would like to see this strengthened to include more direct mentions of expectations surrounding research governance structures, research engagement and culture, and levels of patient involvement in research. We note there are other areas / key questions where research could inform assessments, for example under ‘Effective Care’, but at present the expectation for research is implied rather than explicit. We would encourage that steps are made to be clearer and more specific in these areas to support judgements to properly consider research across all relevant rating characteristics.
Similarly, we agree with proposals to simplify the ratings approach by strengthening professional judgement in decisions. We would however recommend guidance includes consideration and clarity of what “good” and “outstanding” are in relation to research activity, culture, and infrastructure. There are existing targets and expectations within the sector that could be referenced within CQC assessments to help benchmark research related performance for example 150 day clinical trial set up target.
We support the move to sector-specific frameworks, if consistency of rating can be achieved. We recommend that these frameworks include measurement of an organisation’s commitment to and culture around research. Using sector-specific framework should allow for markers for outstanding practice to be identified in each setting.
Equality and inclusion
The HRA were encouraged by the commitment to ensuring the consultation recognises the need to ensure any changes consider the impact on equality and human rights. The HRA is clear that equitable access to research has a key role in addressing health inequalities and as such isa central part of our HRA strategy. Markers for assessment that consider research should ensure that measurement takes into account whether research practices allow for and actively promote inclusive and equitable access to research participation and evidence-based care.
Collaboration and co-production
The HRA welcomes the CQC’s commitment to co-production and stakeholder engagement through this consultation and other initiatives, having been previously involved in discussions that led to the incorporation of clinical research in the Well Led Framework in 2018. We would be pleased to collaborate with the CQC in further in defining research standards and underscoring the role of research in providing high-quality care. In particular, we believe we can provide meaningful support in helping to clarify the questions that relate to the assessment of an institution’s support, integration and facilitation of research within the different health and care sectors that CQC regulate.
Who we are
The Health Research Authority (HRA) (www.hra.nhs.uk) is part of the health and social care research sector that is focused on improving everyone’s health and wellbeing. Our vision is for high quality health and social care research today, which improves everyone’s health and wellbeing tomorrow.
The HRA was established in 2011 with a core purpose to protect and promote the interests of patients and the public in health and social care research. It is responsible for coordinating and standardising health and social care research regulation, overseeing Research Ethics Committees (RECs), managing approvals for confidential patient information, and making it easy to do safe, ethical, and transparent research that people can trust.
We work in partnership with the devolved administrations in Scotland, Wales and Northern Ireland so that people taking part in research anywhere in the UK have the same experience. Together we work with other public bodies to create a connected regulatory system that is easy for researchers to find out what they need to do and earn approvals that people can trust.
To make it easy to do research that people can trust, the HRA:
- works with people to understand what you want research to look like and acts on this so that you can trust research
- makes sure that people taking part in research in the UK are treated ethically and fairly, by reviewing and approving health and social care research studies that involve people, their tissue or their data before they can start as part of a UK-wide regulatory service
- champions research transparency, so that you can always see when research is taking place, or the results of that research if it has finished
- works with other organisations across the UK to reduce the burden, cost and time to set up research, meaning that wherever you are, research studies can be set up smoothly and are always subject to the same scrutiny before they start. This includes running digital services and a UK-wide partnership to help plan, approve, set up, manage and complete research in the UK
- is one of the gatekeepers of patient data, making sure that your information is only used in ways that you can trust