Conflicts of interest
All Clinical Commissioning Groups manage conflicts of interest as part of their day-to-day activities. Effective handling of conflicts of interest is crucial to give confidence to patients, tax payers, healthcare providers and Parliament that CCG commissioning decisions are robust, fair, transparent and offer value for money.
It is essential in order to protect healthcare professionals and maintain public trust in the NHS. Failure to manage conflicts of interest could lead to legal challenge and even criminal action in the event of fraud, bribery and corruption.
Conflicts of interest are inevitable within commissioning. As such, it is not always possible or desirable to completely eliminate the risk of conflicts. Instead, it may be preferable to recognise the associated risks and put measures in place to manage the conflicts appropriately when they do arise. It is how they are managed that matters.
NHS Herefordshire and Worcestershire CCG has a Conflicts of Interest Policy in place, a publicly available Register of Interests for Governing Body Members and Countywide Register for Employees and staff delivering services on behalf of the CCG and Register of Procurement Decisions.
We also have a Register of Conflicts declared during a meeting.
The CCG also has a Code of Conduct Policy in place including 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.
The CCG also holds a record of any Conflicts of Interests Breaches.