Clinical Commissioning Groups (CCGs) manage conflicts of interest as part of their day to day activities. Effective handling of such conflicts is crucial for the maintenance of public trust in the commissioning system. Importantly, it also serves to give confidence to patients, providers, Parliament and tax payers that CCG commissioning decisions are robust, fair, transparent and offer value for money.
NHS North Durham CCG has put in place, robust arrangements to develop and monitor its registers of interest in accordance with national policy, these arrangements have been revised as a result of the release of the NHS England Guidance:
The CCG has a STANDARDS OF BUSINESS CONDUCT AND DECLARATIONS OF INTEREST POLICY The policy includes guidance about declarations and conflicts of interest. Members of the CCG’s Council of Members, Governing Body and Committees who act on behalf of the CCG must declare conflicts of interest in accordance with the Standards of Business Conduct and Declarations of Interest Policy. They must ensure that they are not placed in a position that risks, or appears to risk, conflict between their private interests and their NHS duties and should:
- ensure that the interests of patients remain paramount at all times,
- be impartial and honest in the conduct of their official business,
- use the public funds entrusted to them to the best advantage of the service, always ensuring value for money,
- register with the CCG any interest outside the workplace which could be construed as affecting any part of their work within the CCG.
Conflict of Interest Guardian
The CCG has appointed a Conflict of Interest Guardian – John Whitehouse, Lay Member for Governance and Audit can contacted by email on email@example.com.
John is supported in his role by Amanda Million, Corporate Governance Officer who can also be contacted by email on firstname.lastname@example.org or by telephone on 0191 3898592 with any queries relating to conflicts of interest.
The Conflict of Interest Guardian will:
- act as the main point of contact for GP practice staff, members of the public and healthcare professionals who have any concerns relating to conflicts of interest,
- be a safe point of contact for employees or workers of the CCG to raise concerns in relation to conflicts of interest,
- provide independent advice and judgement where there is any doubt about how to apply the conflicts of interest policies and principles in an individual situation,
- provide advice on minimising the risks of conflicts of interest.
Also linked to the management of conflicts of interest is the management of a gifts and hospitality register, which is part of the CCG’s Conflicts of Interest Register and a Register of Procurement Decisions
The CCG has a clear policy and process in place for the management of breaches of the Standards of Business Conduct and Declarations of Interest Policy. The process for that is contained within the policy. The CCG has reported no breaches to date.
Declaration of Interest Register
The CCG’s Declaration of Interest Register is reviewed and updated regularly in line with the CCG’s Standards of Business Conduct and Declarations of Interest Policy. A historic register of interests is available on request from the CCG.