Conflict of Interest
Conflict of Interest in the NHS and CCGs
A Conflict of Interest can be defined as a situation that arises when a person that has a private or personal interest significant enough to influence the way they make a decision.
Conflicts of Interest can arise in the work of CCGs in a variety of ways. For example, the CCG may wish to commission a service based at a GP surgery. This would be more convenient for patients and cheaper than treatment in hospital. At the same time, the GP practice would have a financial interest in becoming the provider of this service. So if members of the practice became involved in the process of deciding to commission or awarding the service, they would be potentially conflicted. It would not be clear that they favoured the decision because of the convenience of patients rather than their own financial gain.
Managing Conflict of Interest in Southwark CCG
Our Conflict of Interest policy is designed to ensure that such potential conflicts are identified and managed appropriately. All members of the CCG Governing Body and CCG staff must declare any interests they have that might conceivably conflict with their work in the CCG. These are recorded in the Register of Interests
for Members, a document that is updated regularly at meetings in public. The CCG Staff Register of Interests is maintained by the Governance team and is available on request.
If the CCG is considering a commissioning decision in which a member is conflicted then that member must play no part in that decision and would normally leave the room during the discussion of that agenda item. If more than two GPs on the Governing Body are conflicted on a commissioning issue then the Governing Body delegates that decision to an Evaluation Panel consisting of three members who are not GPs and not conflicted. Normally the panel consists of a Lay Member, the Chief Officer and the Director of Public Health.
One of the Lay Members of the CCG Governing Body, Richard Gibbs
, has been appointed 'Conflict of Interest Guardian' with specific responsibilities set out in the Conflict of Interest policy. He is responsible for providing impartial and unconflicted advice and judgement to the Governing Body in cases where it is not obvious whether a material conflict exists or how best to manage it. In such cases he defines a reasonable balance so as to avoid conflicts whilst enabling the CCG to harness the knowledge of clinicians and other staff for commissioning so as to improve care to patients and value for money to the taxpayer.