The CCG’s conflicts of interest policy ensures that the CCG meets the revised NHS England Managing Conflicts of Interest Statutory Guidance published in June 2016. This policy applies to all CCG employees, Governing Body members and members of Committees, as well as member practices of the CCG including GP partners and practice staff. The Policy forms part of the CCG’s Constitution.
Managing conflicts of interest
The conflicts of interest policy enables the CCG to demonstrate that it is acting fairly and transparently and in the best interest of our patients and local population. It is drafted to ensure that the CCG operates within the legal framework, but without being bound by over-prescriptive rules that stifle innovation. The policy aims to:
- Safeguard clinically-led commissioning, whilst ensuring objective investment decisions.
- Enable the CCG to demonstrate that it is acting fairly and transparently and in the best interest of our patients and local population.
- Uphold confidence and trust in the NHS.
- Support the CCG to understand when conflicts (whether actual or potential) may arise and how to manage them if they do.
- Ensure that the CCG operates within the legal framework.
Finally, it will uphold confidence and trust between patients and GPs, in recognition that individual commissioners want to behave ethically but may need support and training to understand when conflicts (whether actual, potential or perceived) may arise and how to manage them if they do.
All CCG members and employees are required to declare any relevant and material personal or business interests and any relevant and material personal or business interest of their spouse; civil partner; co-habitee, family member or close friend which may influence or may be perceived to influence their judgement. Further detail is provided in the policy and declarations are included in the CCG’s Registers of Interest.
Decision making in meetings
Where certain members of a decision-making group or meeting have a material interest, they will either be excluded from relevant parts of meetings, or join in the discussion but not participate in the decision-making itself (ie not have a vote). The chair of the meeting has responsibility for deciding whether there is a conflict of interest and the appropriate course of corresponding action. All decisions, and details of how any conflict of interest issue has been managed, should be recorded in the minutes of the meeting and published in the registers. The meeting will need to decide in advance who will take the chair’s role for discussions and decision-making in the event that the chair of a meeting is conflicted, or how that will be decided at a meeting where that situation arises.
Register of procurement decisions
The CCG’s register of procurement decisions also lists all the Governing Body’s procurement decisions and how any potential conflicts of interest are managed. This is refreshed regularly.
Hospitality and commercial sponsorship
In line with the CCG’s Standards of Business Conduct and Commercial Sponsorship Policy, the CCG also maintains a Register of Gifts, Hospitality and Commercial Sponsorship. This complements the Conflicts of Interest Policy.
Breaches to the Policy
The CCG further maintains a Register of Breaches which sets out details of any breach, how it has been investigated and notification of the breach to NHS England. All breaches are reported to the CCG’s Audit and Assurance Committee. Anonymised details of breaches are published for the purpose of learning and development.
Further information and advice
Further information and advice is available through the CCG’s Conflicts of Interest Guardian who:
- 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.
The CCG’s Guardian is supported by the Director of Corporate Governance. In the first instance, please contact Emily Dwyer if you have any queries or want to seek advice on the conflicts of interest policy or any concerns that you may have.