Managing Conflicts of Interest

The NHS Coventry and Rugby CCG is committed to the principles of transparent and open decision making. As a Clinical Commissioning Group (CCG), it is imperative that we are 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, we 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 amongst the public, patients and GPs are maintained.

At Coventry and Rugby CCG, we have therefore established a Managing Conflicts of Interest Policy to manage conflicts and potential conflicts of interest to ensure that decisions made by the CCG will be taken and seen to be taken without any possibility of the influence of external or private interests. The declaration of interest form is used to capture declarations.

Download the CCG's Register of Interests as at March 2019.

Download the member practice declarations of interest as at January 2019

Gifts and Hospitality

The CCG also has a Gifts and Hospitality Policy, 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 and  Commercial Sponsorship Register are kept and routinely monitored by the CCG. The registers are available below:

Commissioning from GP Practices

The Procurement Checklist template is also used when commissioning services from GP practices, including provider consortia or organisations in which GPs may have a financial interest. This additional safeguard 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
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.
Conflicts of Interest Guardian

The CCG’s Governing Body member, Chris Stainforth, undertakes the role of Conflicts of Interest Guardian. The Conflicts of Interest Guardian:

  • 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.
Raising Concerns

Any individual who has a genuine concern in relation to the administration of the CCG’s policy on conflicts of interest management should speak to the CCG’s Conflicts of Interest Guardian or the Deputy Director of Corporate Affairs for CRCCG in the first instance. 

Individuals wishing to discuss any concerns on a strictly confidential basis should initially make contact with the Deputy Director of Corporate Affairs by telephone on 02476 246114 or by email at contactus@coventryrugbyccg.nhs.uk and arrangements will be made to speak to either the Chief Operating Officer, Conflicts of Interest Guardian or the Deputy Director of Corporate Affairs, as per the individual’s requirements.

Breaches of the Policy

Anonymised details of breaches will be published on this website for the purpose of learning and development. Please see Coventry and Rugby CCG Register of Breaches as at April 2019.

Please Note: All Coventry and Rugby CCG Policies are currently being reviewed and aligned with those of Warwickshire North CCG. In the interim, policies have been checked for references to the Data Protection Act 1998. For these policies, the statement below applies:

DATA PROTECTION

In applying this policy, the Organisation will have due regard for the Data Protection Act 2018 and the requirement to process personal data fairly and lawfully and in accordance with the data protection principles. Data Subject Rights and freedoms will be respected and measures will be in place to enable employees to exercise those rights. Appropriate technical and organisational measures will be designed and implemented to ensure an appropriate level of security is applied to the processing of personal information. Employees will have access to a Data Protection Officer for advice in relation to the processing of their personal information and data protection issues.

 

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