Conflicts of Interest

GP Practices form the membership of the CCG and as they take responsibility for the statutory body they are managing real and perceived conflicts of interest.  The CCG needs to be aware of all situations where an individual acting in an official capacity for the CCG has private interests which have the potential to result in a conflict of interest.  All individuals must declare relevant and material interests to the CCG. 

These are recorded in the Register of Interests - February 2021.

What are conflicts of interest and why do they matter to clinical commissioners?
A conflict of interest occurs where an individual’s ability to exercise judgement or act in one role is or could be impaired or otherwise influenced by his or her involvement in another role or relationship. The individual does not need to exploit his or her position or obtain an actual benefit, financial or otherwise. A potential for competing interests and/or a perception of impaired judgement or undue influence can also be a conflict of interest.

Conflicts can arise from an indirect financial interest (eg, payment to a spouse) or a non-financial interest (eg, kudos or reputation). Conflicts of loyalty may arise (eg, in respect of an organisation of which the individual is a member or has an affiliation). Conflicts can arise from personal or professional relationships with others, eg, where the role or interest of a family member, friend or acquaintance may influence an individual’s judgement or actions or could be perceived to do so. These are all conflicts of interest.

For a GP or any other individual involved in commissioning, a conflict of interest may, therefore, arise when their own judgment as an NHS commissioner could be, or be perceived to be, influenced and impaired by their own concerns and obligations as a healthcare or related provider, as a member of a particular peer, professional or special interest group, or as a friend or family member.

Download our Conflicts of Interest Policy

Managing Conflicts of Interest and the Procurement Decisions Register

In adherence with requirements of the document "Managing Conflicts of Interest: Statutory Guidance for CCGs" published in December 2014 by NHS England, CCGs must maintain a register of procurement decisions taken, which includes the details of the decision, who was involved in making the decision and a summary of any conflicts of interest in relation to the decision and how this was managed by the CCG. This enables the CCG to demonstrate that it is acting fairly and transparently and in the best interest of its patients and local population.

A copy of the Procurement Decisions Register for Quarter 4 19/20 is availabe here. A hard copy of this register is available upon request for viewing at the CCG's office.

To further strengthen our management of conflicts of interest, we have appointed the Chair of Audit Committee as our Conflicts of Interest Guardian. This role includes:

·        Acting as a conduit for GP practice staff, Members of the Public, and healthcare professional and staff who have concerns with regards to how conflicts of interest are being managed by the CCG;

·        Provide independent advice where there is doubt on the application of Conflicts of Interest Policy

More details on this role are contained in the Conflicts of Interest Policy.

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