Conflicts of Interest

GPs as Providers & Commissioners of NHS Services

It is an essential feature of the NHS that Clinical Commissioning Groups (CCGs) should be able to commission a range of community-based services, including primary care services, to improve quality and outcomes for patients. Where the provider for these services might be a GP practice, CCGs will need to demonstrate that those services meet clear criteria including that the appropriate procurement approach is used. These services will be commissioned using the NHS standard contract.

CCGs could also make payments to GP practices for promoting improvements in the quality of primary medical care (e.g. reviewing referrals and prescribing); or carrying out designated duties as healthcare professionals in relation to areas such as safeguarding.

Consequently conflicts of interest will arise and it is how these conflicts are managed that will ensure public funds are spent appropriately and that confidence and trust between the public, patients and GPs is maintained.

In Stafford and Surrounds and Cannock Chase CCGs we will, as a minimum, manage conflicts of interest by having a Conflicts of Interest Policy, a public declaration of interests through our Conflicts of Interest Register, by excluding anyone from decision-making where a conflict arises and engaging with a range of potential providers on service design. A copy of the conflicts of interest declartion form can be found here.

The CCG also has a policy for the acceptance of 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 Code of Conduct provides more specific safeguards that we have in place when commissioning services that could potentially be provided by GP practices. These additional safeguards should enable us to:

In both Stafford and Surrounds and Cannock Chase CCGs we have taken further steps by making our Audit Committee entirely independent of GPs and Practice Leads and by appointing our Lay Member for Governance as our Conflicts of Interest Officer.