Commitment to manage conflicts of interests
The CCGs, as commissioners of healthcare services, is committed to managing conflicts of interest in a way that demonstrates transparency, probity and accountability. This is particularly important when commissioning services that might be delivered by member practices as providers – ensuring that the approach taken does not affect or appear to affect the integrity of the organisations’ decision making.
Providing best value for taxpayers and ensuring that decisions are taken transparently and clearly, are both key principles in the NHS Constitution. The CCGs are committed to maximising our resources for the benefit of the whole community. As organisations and as individuals, we all have a duty to ensure that all our dealings are conducted to the highest standards of integrity and that NHS monies are used wisely so that we are using our finite resources in the best interests of patients.
It is important to manage conflicts of interest for the following reasons:
- To give confidence that commissioning decisions are robust, fair and offer value for money
- To maintain public trust in the CCGs and the NHS
- To protect healthcare professionals
- Failure to manage conflicts of interest could lead to legal challenge and criminal action
The CCGs' arrangements for managing conflicts of interest
pdf Halton CCG's Constitution and pdf Warrington CCG's Constitution set out the pdf CCGs' arrangements for managing conflicts of interest throughout their decision making and commissioning processes. They also set out the expectations that apply to their Governing Body members, staff, CCG members, clinical leads and others involved in the work of the CCGs. The arrangements described in the policy are in-line with relevant legislation and statutory guidance concerning the management of conflicts of interest.
What are conflicts of interest?
A ‘conflict of interest’ is “A set of circumstances by which a reasonable person would consider that an individual’s ability to apply judgement or act, in the context of delivering, commissioning, or assuring taxpayer funded health and care services is, or could be, impaired or influenced by another interest they hold.”
A ‘conflict of interest’ may be:
- Actual - there is a material conflict between one or more interests
- Potential – there is a possibility of a material conflict between one or more interests in the future
Staff may hold interests for which they cannot see potential conflict. However, caution is always advisable because others may see it differently and perceived conflicts of interest can be damaging. All interests should be declared where there is a risk of perceived improper conduct.
Interests fall into the following categories:
- Financial interests - Where an individual may get direct financial benefit from the consequences of a decision they are involved in making.
- Non-financial professional interests - Where an individual may obtain a non-financial professional benefit from the consequences of a decision, they are involved in making, such as increasing their professional reputation or promoting their professional career.
- Non-financial personal interests - Where an individual may benefit personally in ways which are not directly linked to their professional career and do not give rise to a direct financial benefit, because of decisions they are involved in making in their professional career.
- Indirect interests - Where an individual has a close association with another individual who has a financial interest, a non-financial professional interest or a non-financial personal interest and could stand to benefit from a decision they are involved in making.
Offers of gifts, hospitality and/or commercial sponsorship can also give rise to real or perceived conflicts of interest or undue influence. Consequently, those involved in the work of the CCG are also required to declare any offers of gifts, hospitality and/or commercial sponsorship that fall within the thresholds set out by the CCGs.
Registers of Interest and Gifts, Hospitality and Commercial Sponsorship
The CCGs are required to publish registers of interest relating to Governing Body members, decision making staff and CCG members. When a declaration is made, the relevant register is updated as well as being reviewed at set quarterly intervals.
The current registers can be found here:
- folder Halton CCG Registers of Interest and Gifts, Hospitality and Commercial Sponsorship
- folder Warrington CCG Registers of Interest and Gifts, Hospitality and Commercial Sponsorship
If you have any concerns regarding information published on any of the CCGs' registers, please refer to the guidance on raising a concern with the CCGs below.
Raising a concern with the CCG
The Chair of our Audit Committee has a lead role as the Conflicts of Interest Guardian. Their role involves ensuring that the Governing Body and staff in the wider CCGs behave with the utmost probity at all times.
Supported by our Head of Governance and Corporate Secretary, they act as a confidential point of contact for anyone who has concerns about conflicts of interest at the CCGs, supports the rigorous application of conflicts of interest principles and policies and provides advice and judgement concerning conflicts of interest and their management.
If you have a concern regarding information published on any of the CCGs' registers, in particular if you believe that public disclosure of information might give rise to a real risk of harm or is prohibited by law or that substantial damage or distress may be caused to you or somebody else by the publication of information, you are entitled to request that the information is not published. Such requests must be made in writing to the Conflicts of Interest Guardian for the CCG or the Chief of Information, Technology and Estates in their role as Data Protection Officer. Their contact details are provided above. Further information about the data held on the CCGs' registers and how to raise a concern is available in the CCGs' Privacy Notice.
Breaches of the CCGs' Standards of Business Conduct including Conflicts of Interest Policy
Anonymised breaches of the CCGs' Standards of Business Conduct including pdf Conflicts of Interest Policy .
The CCGs' Register of Procurement Decisions
Actual and potential conflicts of interest are managed throughout the CCGs' commissioning cycle with potential conflicts being identified at the outset and revisited throughout.Details of the CCGs' arrangements for the management of conflicts of interest during commissioning exercises are set out in the CCG’s Policy