Managing conflicts of interest

It is an essential feature of the NHS that Clinical Commissioning Groups (CCGs) should be able to commission a range of community-based services, including primary care services, to improve quality and outcomes for patients. Where the provider for these services might be a GP practice, CCGs will need to demonstrate that those services meet clear criteria including that the appropriate procurement approach is used. These services will be commissioned using the NHS standard contract.

CCGs could also make payments to GP practices for promoting improvements in the quality of primary medical care (e.g. reviewing referrals and prescribing); or carrying out designated duties as healthcare professionals in relation to areas such as safeguarding.

Consequently conflicts of interest will arise and it is how these conflicts are managed that will ensure public funds are spent appropriately and that confidence and trust between the public, patients and GPs is maintained.

At Warwickshire North CCG we will, as a minimum, manage conflicts of interest by having a Conflicts of Interest Policy, public declaration of interests through our Conflicts of Interest Register and  excluding anyone from decision-making where a conflict arises and engaging with a range of potential providers on service design. The declaration of interest form is used to capture declarations.

Download the CCG's Register of Interests as at April 2017.

Download the member practice declarations of interest as at January 2017.

Gifts and Hospitality

The CCG also has a Policy for the Acceptance of Gifts and Hospitality, which applies to all staff employed by the CCG and those carrying out work on behalf of, or at the request of the CCG. This includes members of the CCG Governing Body and its sub-committees. A Gifts and Hospitality Register is kept and routinely monitored by the CCG.

Commissioning from GP Practices

The Procurement Checklist template is also used when commissioning services from GP practices, including provider consortia or organisations in which GPs may have a financial interest. This additional safeguard should enable us to:

  • Maintain confidence and trust between our patients and their GPs
  • Demonstrate that the CCGs and GP practices are acting fairly and transparently and that members of CCGs will always put their duty to patients before any personal financial interest
  • Operate within the legal framework

Register of Procurement Decisions

  • CCGs are required to maintain a register of procurement decisions taken, either for the procurement of a new service or any extension or material variation of a current contract.  The register of procurement decisions must be updated whenever a procurement decision is taken. View the most up-to-date register of procurement decisions.

Conflicts of Interest Guardian

The CCG’s Lay Member for Audit and Governance undertakes the role of Conflicts of Interest Guardian. The Conflicts of Interest Guardian:

  • Acts as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns with regards to conflicts of interest;
  • Is a safe point of contact for employees or workers of the CCG to raise any concerns in relation to this policy;
  • Supports the rigorous application of conflict of interest principles and policies;
  • Provides independent advice and judgment where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation;
  • Provides advice on minimising the risks of conflicts of interest.

Raising Concerns

Any individual who has a genuine concern in relation to the administration of the CCG’s policy on conflicts of interest management should not ignore their suspicions or investigate themselves, but speak to the CCG’s Conflicts of Interest Guardian or the Head of Corporate Affairs in the first instance. 

Individuals wishing to discuss any concerns on a strictly confidential basis should initially make contact with the Head of Corporate Affairs by telephone on 02476 324326, Ext: 81559 or by email at warnoccg.coi@nhs.net and arrangements will be made to speak to either the Chief Operating Officer, Conflicts of Interest Guardian or the Head of Corporate Affairs, as per the individual’s requirements.

Breaches of the Policy

Anonymised details of breaches will be published on this website for the purpose of learning and development. To date the CCG has experienced no breaches of the policy.

 

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