This chapter sets out the top tips from trusts that have undertaken a fit and proper persons investigation.

A number of trusts have already investigated allegations or concerns raised about their directors, either passed on by CQC or directly raised to the board through other channels, and while each individual case is different, it is important to capture and share some of the learning.


Top tips

1. Establish robust employment processes and procedures, and regularly review them, as this saves time and money further down the line.
2. Be committed to openness and transparency in all FPPR related processes and throughout an investigation.
3. Seek expert legal, HR and other relevant advice as appropriate.
4. Consult with CQC and NHS Improvement counterparts as much as possible throughout the investigation process.
5. Agree the terms of reference and timescales of the investigation at the outset.
6. Consider how the wider organisation should be involved in the investigation, including non-executive directors and, in foundation trusts, governors.
7. During the investigation, engage with everyone involved in the concerns, including those who raised concerns or may have an issue with the outcome, and make sure they all have a voice.
8. Communicate the progress made by the investigation well so that all parties feel involved.
9. Consider how to manage the outcome before it is made public.
10. Be really clear about the outcome of the investigation, the reasoning behind it and any necessary action.