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.
We will, as a minimum, manage conflicts of interest by having a Conflicts of Interest Policy 2017. All Governing Body members, Membership Board members and our staff are asked to complete a Conflicts of Interest Form to identify any potential conflicts of interests which are added to these regularly maintained documents:
- Conflicts of Interest Register - Governing Body
- Conflicts of Interest Register - Membership Board
- Conflicts of Interest Register - staff
Governing Body members are also asked to declare any conflict of interest with regard to agenda items at each Public Governing Body meeting. In addition to the Governing Body, the CCG receives assurance in a number of different ways, including Internal Audit, External Audit and our Anti-Fraud and Corruption Team.
Conflicts of Interest Guardian
The Conflicts of Interest Guardian for Stafford and Surrounds CCG is Harry Ireland. The Guardian should, in collaboration with the CCG’s governance lead:
- 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 this policy;
- Support the rigorous application of conflict of interest principles and policies;
- 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.
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.
External companies, including pharmaceutical companies,may sometimes make contributions to Protected Learning Time sessions they attend with GP practices. A register is kept of any contributions made.
Commissioning from GP Practices
The Code of Conduct template is also used when commissioning services from GP practices, including provider consortia or organisations in which GPs may have a financial interest. These additional safeguards 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
- Build on existing guidance, in particular the Procurement Guide for Commissioners of NHS Funded Services and Principles and Rules of Co-operation and Competition.
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.