Response to Initial Draft of the NSQHS Standards (Third Edition) Consultation

This submission responds to the consultation on the initial draft of the National Safety and Quality Health Service (NSQHS) Standards (third edition), which consolidate the eight second-edition standards into three: Clinical Governance, Person-Centred Practice and Safe Clinical Systems. Research Australia supports the consolidation and the more explicit recognition of clinical research and the National Clinical Trials Governance Framework, but cautions that consolidation must not dilute research expectations or add administrative burden, and that accreditation alone cannot embed research in health care. Drawing on its forthcoming policy discussion paper, Making Research Routine: Embedding Research into Australia’s Health System, and a September 2026 member workshop, it recommends a setting-neutral definition of research rather than “all research conducted in clinical settings”; clearer boundaries between quality improvement, clinical quality registries and research; board and executive accountability for research capability, culture and outcomes, with adequate resourcing; mutual recognition of existing governance evidence and risk-proportionate oversight; and recognition of protected research time, career pathways and multidisciplinary participation. It also recommends stronger data capability that makes under-counted populations visible, recognition of national and international networks, especially for the more than 7,000 rare diseases, meaningful consumer involvement and equity by design for First Nations, regional, rural and remote and other under-represented groups, governance of artificial intelligence and unapproved medicines as well as devices, and testing of the research provisions in the 2027 pilot. It asks that research participation be reflected in funding and accountability arrangements, including the National Health Reform Agreement.