How we manage conflicts of interest (COI)

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 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. 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.  

You can view interest and declarations of gifts and hospitalities here. As a member of the public you will be able to view declarations of interest for key decision makers in line with NHS England guidance on openness and transparency.
 

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.  

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 Committee. Anonymised details of breaches are published for the purpose of learning and development.

To further strengthen scrutiny and transparency of CCG’s decision making processes, the CCG has a Conflicts of Interest Guardian. The Conflicts of Interest Guardian is normally the Lay Member who has qualifications, expertise or experience to enable them to lead on finance and audit matters. 

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.