HAS Certification and Qualiopi: a Hospital That Trains Falls Under Both, Separately

It is a frequent confusion, and an expensive one when noticed late: HAS certification does not assess a health-care establishment’s training activity. It assesses the quality and safety of care. A hospital that trains — health professionals, its own staff, paying external participants — falls, for that activity, under an entirely separate framework.

The subject is not theoretical. Many French health-care establishments deliver training: nursing and allied-health schools, continuing-professional-development offerings, training aimed at other organisations, healthcare simulation sold to third parties. Each of these has its own obligations.

Two objects, two codes, two logics

The starting point is legal, and it is clear-cut.

	HAS certification	Qualiopi certification
Legal basis	Article L.6113-3 of the public-health code	Article L.6316-1 of the labour code
Object	Quality and safety of care	Quality of services contributing to skills development
Assessor	Expert visitors appointed by the HAS	Accredited or authorised certification bodies
Scope	The establishment and its care activities	The activity as a training provider
Nature	Mandatory for every health-care establishment	Conditions access to public and pooled funds

Two different codes, two different authorities, two frameworks with no intersection. Nothing in HAS certification counts as Qualiopi evidence, and vice versa.

What HAS certification looks at

HAS certification is a mandatory external assessment, carried out by expert visitors appointed by the Haute Autorité de santé, against a framework structured into three chapters — the patient, the care teams, the establishment. It ends in a decision on four levels and a public report, with a four-year cycle for favourable decisions.

It concerns care pathways, risk management, team coordination, and the patient’s place in decisions that affect them. The detail is set out in our article on the HAS 2025 framework.

It never asks how a learner was assessed before a course, nor how a trainer’s own skills are kept current.

What Qualiopi looks at

Qualiopi certifies the quality of the process implemented by providers of services contributing to skills development. It conditions access to public and pooled funding. It rests on a national quality framework whose requirements cover public information, needs analysis, adaptation of services, teaching resources, the qualifications of those delivering, the collection of feedback and the handling of complaints.

A hand-hygiene course delivered internally by a hospital does not fall within HAS certification as a training course. If that same hospital sells the course to neighbouring establishments with pooled funding, the Qualiopi question arises — independently of anything its HAS certification report says.

And continuing professional development?

This is the third layer, and the one that muddles things most.

An establishment offering continuing-professional-development actions (développement professionnel continu, DPC) to health professionals falls under a specific registration with its own requirements. That framework replaces neither HAS certification nor Qualiopi: it is additional, depending on the audiences targeted and the funding drawn on. We devoted a full article to this articulation: DPC or Qualiopi, which framework for training health professionals.

Upstream of all this sits the question of the training-provider activity declaration (déclaration d’activité), an administrative prerequisite in its own right — and often the first thing overlooked by establishments that start invoicing training to third parties.

The classic error: believing that quality “covers” quality

The intuition is understandable. An establishment that has just obtained a favourable HAS certification has demonstrated a solid quality culture, functioning governance bodies and controlled document management. It is tempting to conclude that training activity is covered by ricochet.

It is not, and the Qualiopi audit shows it quickly. The expected evidence concerns objects HAS certification does not produce: a learner’s entry assessment, the adaptation of a service to an identified need, the follow-up of feedback collected, monitoring of developments in the occupational field the training targets.

This non-transferability of quality schemes between sectors is a general finding of research on such devices. The systematic review by Greenfield and Braithwaite, published in 2008 in the International Journal for Quality in Health Care from sixty-six empirical studies, highlights how varied accreditation effects are across contexts and frameworks — and is a reminder that an external assessment scheme produces what its framework measures, and no more (see the study).

What genuinely can be shared

Not everything is siloed. Three things are worth sharing:

Quality governance. One body steering the schemes, a common calendar, a named owner: there is no reason to run two parallel organisations that ignore each other.

The culture of evidence. An establishment used to documenting, dating and tracing for HAS certification applies the same reflex to its training activity. That is a real gain, even though the documents differ.

The calendar. Letting a Qualiopi audit coincide with the months of preparation for a certification visit is an avoidable organisational error. Both mobilise partly overlapping teams — the quality department first of all.

What cannot be shared, on the other hand, is the evidence itself. Each framework demands its own.

Take action

If your establishment delivers training, ask yourself three questions in this order: to whom do we sell or offer training, with what funding, and under what administrative status? The answers determine whether Qualiopi, registration for continuing professional development, or both, sit on top of your HAS certification obligation. For HAS certification itself — legal obligation, framework, visit methods, decision levels — see our guide to HAS certification of health-care establishments; for the other side, our guide to Qualiopi certification.