Conflicts of interest management

On 16 June 2017, NHS England published revised statutory guidance on managing conflicts of interest for CCGs. This replaces the 2016 version of the guidance.

The guidance has been updated to ensure it is fully aligned with the recently published cross system conflicts of interest guidance – Managing conflicts of interest in the NHS: Guidance for staff and organisations. A small number of changes have been made including:

• Registers of interest: We have updated the CCG guidance to require that CCGs have systems in place to satisfy themselves as a minimum on an annual basis that their registers of interest are accurate and up-to-date, and to require that only decision-making staff are included on the published register.
• Gifts from suppliers or contractors: In line with the NHS-wide guidance, gifts of low value (up to £6), such as promotional items, can now be accepted.
• Gifts from other sources: We have amended the thresholds so that gifts of under £50 (rather than £10) can be accepted from non-suppliers and non-contractors, and do not need to be declared. Gifts with a value of over £50 can now be accepted on behalf of an organisation, but not in a personal capacity.
• Hospitality – meals and refreshments: We have amended the thresholds so that hospitality under £25 does not need to be declared. Hospitality between £25 and £75 can be accepted, but must be declared, and hospitality over £75 should be refused unless senior approval is given.
• New care models: We have included a new annex to provide further advice on identifying, declaring and managing conflicts of interest in the commissioning of new care models: Annex K: Conflicts of interest and New Models of Care.

Conflicts of interest templates

To support with implementation of the statutory guidance, we have published a series of templates and toolkits. These templates are intended to be a helpful resource and can be adapted to individual CCG’s needs:

• Annex A: Template Declaration of interests for CCG members and employees
• Annex B: Template Register of interests for CCGs
• Annex C: Template Declarations of gifts and hospitality
• Annex D: Template Registers of gifts and hospitality
• Annex E: Template Declarations of interest checklist
• Annex F: Template for recording minutes
• Annex G: Procurement checklist
• Annex H: Template Register of procurement decisions and contracts awarded
• Annex I: Template Declaration of interests for bidders/ contractors
• Annex J: Conflicts of interest policy checklist
• Annex K: Conflicts of interest and New Models of Care

Conflicts of interest summary guides

We have developed a series of two-page summary guides to the revised statutory guidance on managing conflicts of interest for CCGs. The guides are role-specific and draw out the essentials different professional groups need to know about the revised guidance, including:

• GPs in commissioning roles
• Conflicts of interest guardians
• CCG governance leads
• CCG lay members
• CCG admin teams
• Healthwatch representatives on primary care commissioning committees

Conflict of interest case studies

We have developed a series of case studies to accompany the revised statutory guidance on managing conflicts of interest for CCGs.

The case studies are intended to raise awareness of the different types of conflicts of interest that could arise in CCGs and to support CCGs to robustly and effectively identify and manage them. We have included a new case study on managing conflicts of interest in the commissioning of new care models.

If you have any scenarios or examples you would like to share, please email: england.co-commissioning@nhs.net.