Conflicts of Interest
What is a conflict of interest?
A conflict of interest could be defined as any situation in which an individual’s personal interests or responsibilities may, or may appear to, influence their decision-making.
Why is it important to manage conflicts of interest?
Wakefield Clinical Commissioning Group (Wakefield CCG) is responsible for commissioning healthcare services to improve the health and wellbeing of people in the Wakefield District. It decides which services the people of Wakefield most need and pays local hospitals and other healthcare providers to provide these services. In addition, it holds the healthcare providers to account to ensure that they provide the services paid for.
Conflicts of interest are inevitable in commissioning and it is how we manage them that matters. As a membership organisation management of conflicts of interest is part of our day-to-day activities. By bringing more clinical leadership into commissioning and enabling more local decision making, CCGs are empowered and enabled to improve services locally for the benefit of patients and local communities
Therefore, it is important to manage conflicts of interest to:
· Protect the integrity of the CCG’s decision making processes and decisions;
· Avoid improper influence and prevent fraud
· Ensure decisions are legal and can be defended in the case of a legal challenge
· Fulfil its duty to look after public money
· Ensure honesty, fairness, transparency and equality in the way we spend money
· Ensure our patients receive the best possible care.
How does Wakefield CCG manage conflicts of interest?
Wakefield CCG takes its responsibility to manage conflicts of interest seriously and has a Conflict of Interest Policy.
What does the policy require individuals to do?
The Policy sets out how Wakefield CCG Governing Body members, officers, staff, members and clinical leads should behave in their role at Wakefield CCG. It also sets out the steps and measures that Wakefield CCG takes to manage conflicts of interest. An example of this is that the Policy requires those people referred to above to declare any and all interests which may be, or may lead to, a conflict of interest.
Common types of conflicts of interest
The most common types of conflicts of interest include:
· Financial interests;
· Non financial professional interests;
· Non-financial personal interests;
· Indirect interest
What happens when a conflict of interest is identified?
When a conflict of interest is identified it should always be disclosed, as openness and transparency allows for conflicts and potential conflicts of interest to be assessed and managed. This includes publishing all conflicts of interest on a Register of Interests.
In most instances the individual with a conflict of interest will be removed from decision making on that particular issue. In the rare instance that this is not possible, the CCG manages the risk of improper or undue influence carefully. This includes documenting how the conflict of interest has been assessed, controlled and managed.
CCG staff members are also required to tell their line manager and governance team about any conflict of interest they have or think they may have. To find out how the CCG manages conflicts of interest, please refer to the Conflicts of Interest Policy.
Raising concerns and investigating breaches
All suspected or known breaches should be reported to the Conflicts of Interest Guardian or Governance and Board Secretary in the first instance (via email at firstname.lastname@example.org). All such notifications will be treated with appropriate confidentiality at all times in accordance with the CCG’s policies and applicable laws.
Where can I find Wakefield CCG’s conflicts of interest information?
We are required to publish all conflicts of interests in our Register of Interests.
Gifts and hospitality
Any gift, item of hospitality or offer of sponsorship which is perceived to exceed £25 must be declared by the individual who received the offer for inclusion in the Gifts and Hospitality Register. All offers must be reported regardless of whether the item was accepted. This information will be recorded in the register which is available here. Register of Gifts
Procurement and tendering procedures
It’s important that the services which the CCG commissions are underpinned by robust, fair and transparent procurement exercises to ensure that the quality of those services are achieved and maintained in order to facilitate greater choice for our patient population and to secure best value for money with public resources.
Conflicts of interest can arise in many situations, environments and forms of commissioning, with an increased risk in primary care commissioning, out-of-hours commissioning and involvement with integrated care organisations. Conflicts of interest can arise throughout the whole commissioning cycle from needs assessment, to procurement exercises, to contract monitoring.
A register of procurement decisions is available here.
If you have any questions about procurement decisions, please contact the Head of Contracting and Performance by emailing wakccg.Contactus@nhs.net