Conflicts of interest audit and training

Managing conflicts of interest: online training for CCGs

To further support CCGs to manage conflicts of interest, we have launched new online training. The training package has been developed in collaboration with NHS Clinical Commissioners and aims to raise awareness of the risks of conflicts of interest and how to identify and manage them.

Overview of the training

The training package contains three modules:

  • Module 1 covers what conflicts of interest are; how to declare and manage conflicts of interest, including individuals’ responsibilities; and how to report any concerns.
  • Module 2 provides further information on managing conflicts of interest throughout the whole commissioning cycle and in recruitment processes.
  • Module 3 provides advice on how chairs should manage conflicts of interest; an overview of the safeguards that should be applied in Primary Care Commissioning Committees; and how to identify and manage breaches of conflicts of interest rules, through a series of practical scenarios.

Each training module ends with a short assessment – individuals will need to achieve 80% in the assessment to pass each module.

Who should complete the training?

Following joint work with NHS Clinical Commissioners, we have agreed a more targeted approach. We are aware of the potential burden that additional mandatory training can add to CCGs’ workloads, so have focused on minimising any unnecessary requirements.  We have agreed that module 1 of the training will be mandatory for:

  • CCG Governing Body Members
  • Executive members of formal CCG committees and sub-committees
  • Primary Care Commissioning Committee members
  • Clinicians involved in commissioning or procurement decisions
  • CCG governance leads
  • Anyone involved or likely to be involved in taking a procurement decision(s)

CCGs may wish to invite other individuals to undertake module one of the training if they are involved in CCG business.

Modules two and three are optional but may be of interest to the following:

  • Module two: individuals in decision-making roles, including contract and performance managers, commissioning leads, primary care teams, strategy and planning teams, locality managers etc.
  • Module three: senior CCG staff with high exposure to conflicts of interest, such as governing body members, the senior management team, GP clinical leads, governance leads, Conflicts of Interest Guardian and procurement leads.

How to access the training

The training modules are now available in the Electronic Staff Record (ESR) system. To access them:

  1. Go to and log in.
  2. Go to ‘My Learning’.
  3. Type ‘conflicts of interest’ into the search field and press ‘Go’. The three modules will then be listed.
  4. Enrol on your chosen module by clicking ‘Choose or enrol in class’ (briefcase icon) and press ‘Apply’.
  5. You will then see the module listed in a blue table. Press ‘Play’ icon in the right column to start the module.

Tip: If you cannot see the whole page of the module, you can adjust the zoom in the top right corner of the screen.

Alternatively, the modules can be accessed at e-Learning for Healthcare Hub, which is hosted by Health Education England. Please follow the introductions on screen. For any technical queries, please contact

Those who are not CCG employees but are involved in CCG business can get free access to the e-LfH Hub by registering their NHS email address. CCGs can email to request access for those who do not have an NHS email address.

Word versions of the training modules, which are suitable for screen readers, can be made available upon request to

Next steps and reporting

It is expected that module one of the online training is completed by 31 May 2018 by those staff for whom module one is mandatory. We will ask CCGs to report completion rates via the CCG Improvement and Assessment Framework in 2018/19.

CCGs can extract reports on their completion rates from ESR and/or the e-LfH Hub. We encourage CCGs to direct their staff to complete training in only one of the two learning environments so that reports can be extracted easily from one source. Before doing so, all staff members should ensure their place of work is recorded correctly so that the reports capture all relevant staff.

With regards to ESR, records of all e-learning activity will be retained in the CCG’s local ESR system. CCGs using the e-LfH Hub should ensure their system administrators email to request reporting permissions. Once the right permissions for that location have been set up, the system administrator will see a new menu option of ‘Admin’, with a sub-menu of ‘Reports’ where they can run a report on those who have completed the training.

Conflicts of interest internal audit framework for CCGs

The revised statutory guidance on managing conflicts of interest for CCGs requires CCGs to undertake an annual internal audit of conflicts of interest management. To support CCGs to undertake the audit, NHS England has published a template audit framework.

Co-commissioning conflicts of interest audit

In 2015/16, NHS England commissioned an audit of conflicts of interest management in ten co-commissioning arrangements. The aim of the audit was to review how the safeguards set out in the 2014 statutory guidance on managing conflicts of interest were operating in practice; share learning and good practice; and identify any areas for improvement.  The findings of the audit have informed the development of the revised statutory guidance on managing conflicts of interest (published in June 2016).

Improvement and Assessment Framework: Conflicts of interest indicator

As part of the CCG Improvement and Assessment Framework, CCGs are required to submit quarterly and annual self-certification returns to demonstrate compliance with the requirements of the revised statutory guidance on managing conflicts of interest for CCGs.  View the self-certification proformas and guidance on the submission process.

Please note CCGs are not required to report completion levels for the online conflicts of interest training in the 2017/18 annual self-certification. This information will be collated in 2018/19, as set out in the guidance on the submission process.