Managing conflicts of interest
CCGs have a legal duty to effectively manage conflicts of interest.
What is a conflict of interest?
A conflict of interest occurs where a person’s ability to exercise judgement is seen to be impaired or otherwise influenced by his or her involvement in another role or relationship. In some circumstances, it could be reasonably considered that a conflict exists even when there is no actual conflict. In these cases it is important to still manage these perceived conflicts in order to maintain public trust.
Conflicts of interest can arise in many situations, environments and forms of commissioning, with an increased risk in primary care commissioning, GP out-of-hours commissioning and involvement with integrated care organisations, as clinical commissioners may here find themselves in a position of being both commissioner and provider of services. Conflicts of interest can arise throughout the whole commissioning cycle from needs assessment to procurement exercises and contract monitoring.
How do we manage conflicts of interest?
We describe the processes involved in managing conflicts of interest in our Standards of Business Conduct policy v2.3. An important part of this is asking our Board and committee members, staff and member practices to declare all relevant interests, whether they are financial, non-financial, direct, indirect, professional or personal. These are all entered onto a number of registers which can be accessed at the links below or are available for viewing at our Head Office in Hemel Hempstead (First Floor, The Forum, Marlowes, Hemel Hempstead HP1 1DN).
- Register of Interests - Herts Valleys STAFF members
- Register of Interests - GP practice members
- Register of interest TEMPLATE - form B
We will confirm on a six monthly basis that the registers of interest are accurate and up-to-date, including the requirement for employees, board members, members of committees and practice staff with involvement in CCG business to provide ‘nil returns’ where there are no changes to interests. This means that at the end of March 2017 we will issue a request in which we will ask individuals to confirm in writing that their declaration is up to date.
Additionally we publish a register of all of our procurement and other decisions in order to provide transparency about how we have managed any conflicts of interest.
- Register of - Decisions
- Register of - NHS 111 procurement declarations
- Register of - Hertfordshire Wheelchair Services Re-Procurement Project
- Register of - Integrated Diabetes Service provider pathway collaborative (MPPC) assurance process
- Register of - Enhanced Community MSK, Pain and Postural Stability procurement
We also publish declarations of hospitality, gifts and sponsorship offered by organisations who are current or prospective suppliers of the CCG.
Conflicts of Interest Guardian
CCGs are required to have a Conflicts of Interest Guardian in order to strengthen scrutiny and transparency of decision making processes. Our Conflicts of Interest Guardian is the Audit Committee Chair, Paul Smith, supported by the Head of Corporate Governance, Rod While who has responsibility for the day-to-day management of conflicts of interest matters and queries. Standards of Business Conduct V2.3.
The role of the Conflicts of Interest Guardian is to:
- Act as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns with regards to conflicts of interest.
- Be a safe point of contact for employees or workers of the CCG to raise any concerns in relation to conflicts of interest.
- Support the rigorous application of conflicts of interest principles and policy.
- Provide independent advice and judgment where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation.
- Provide advice on minimising the risks of conflicts of interest.
How does the CCG deal with conflicts of interest breaches?
It is the duty of every employee, Board member, committee, sub-committee or group member and GP practice member to speak up about genuine concerns in relation to the administration of our policy on conflicts of interest management and to report these concerns. These individuals should not ignore their suspicions or investigate themselves, but rather raise their concerns with the Conflicts of Interest Guardian, in line with the our whistleblowing policy.
Any potential breach of our policy on conflicts of interests will be investigated and actual breaches will be published on our website.