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Blackburn with Darwen Clinical Commissioning Group East Lancashire Clinical Commissioning Group BLACKBURN WITH DARWEN CLINICAL COMMISSIONING GROUP EAST LANCASHIRE CLINICAL COMMISSIONING GROUP BLACKBURN WITH DARWEN CCG GOVERNING BODY AND EAST LANCASHIRE CCG GOVERNING BODY MEETING IN COMMON Blackburn with Darwen CCG & East Lancashire Agenda Report Title: 4.5 CCG Corporate Registers No: Meeting Date: 18th March 2020 Summary of Report: The purpose of this briefing is to provide the Governing Body with an update on the CCG’s Corporate Registers and management of Conflicts of Interest. Report Recommendations: The Governing Body is requested to note the content of the report. Financial Implications: None Procurement Implications: None Report Category: Support and recommend/forward the report. Tick Approve the recommendations outlined in the report. Debate the content of the report. Receive the report for information. X Author: Mrs Anne Holden, Corporate Administration Officer Report supported & approved by your Senior Lead? Y Presented By: Mrs Kirsty Hollis, Chief Finance Officer Other Committees Consulted: Blackburn with Darwen CCG Audit Committee Has a PIA been completed in respect of this report? Privacy Impact Assessment N (PIA) If Yes, please attach If No, provide reason below. Has an EIA been completed in respect of this report? Equality Impact Analysis N (EIA) If Yes, please attach If No, provide reason below. Data Protection Impact Is a Data Protection Impact Assessment Required? N Assessment Have any risks been identified / assessed? N Risks: Conflict of Interest: Is there a conflict of interest associated with this report? N Has any clinical engagement/involvement taken place as part N Clinical Engagement: of the proposal being presented. Patient Engagement: Have patients been involved in the drafting of this report? N Privacy Status: Can the document be shared Y CCG Corporate Objectives: To commission the best quality and effective services to deliver optimal healthcare CO1 outcomes for our local population. Ensure the balance of our health investment reflects our population’s needs and keeps CO2 the population well. CO3 Deliver the 10 year strategy by engagement with the population we serve and ensure we commission services that meet local needs with a clear focus on population health management strategies. CO4 We will focus on population health outcomes through helping to deliver successful Integrated Care Partnerships and ensure decisions, provision and access to local services is based on the needs of our population. CO5 As local health leaders, we will focus on increasing life expectancy across Pennine Lancashire to be at, or about, the national average in the next 10 years. 1 BLACKBURN WITH DARWEN CLINICAL COMMISSIONING GROUP EAST LANCASHIRE CLINICAL COMMISSIONING GROUP Agenda Item No: 4.5 BLACKBURN WITH DARWEN CCG GOVERNING BODY AND EAST LANCASHIRE CCG GOVERNING BODY MEETING IN COMMON 18TH MARCH 2020 CORPORATE REGISTERS OF INTEREST REPORT 1. Background 1.1 The report outlines the processes in place for managing conflicts of interest within the organisation and presents the annual review and publication of the CCGs Registers of Interest. 2. Declaration of Interest 2.1 As part of Conflict of Interest Statutory guidance, declarations are required from all individuals at least annually to ensure the Register is accurate and up to date. East Lancashire CCG will prompt staff on a six-monthly basis. 2.2 Members of the CCG, the Governing Body, Committee members and all members of staff working for or on behalf of the CCG are expected to fully comply with the requirements of the CoI Policy by declaring any interests as required. This allows for all conflicts of interests to be managed accordingly, whether they relate to the individual themselves or their spouse/partner, close relative, close friend or business partner. 2.3 All relevant and material interests should be declared to the CCG in the following circumstances: . On appointment/election to the CCG; . Six monthly (a formal review with confirmation of no changes); . At every meeting before the agenda is discussed (and as part of the meeting as circumstances dictate); . On changing role or responsibility; . On any other change of circumstances; . On becoming aware that the CCG has entered into or proposed entering into a contract in which they or any person connected with them has any financial or other interest, either directly or indirectly. 2.4 There is also a requirement to notify, at any time, any change to a declaration within 28 days after the interest arises. 2.5 The CCG must publish Registers of Interest of decision making staff on an annual basis and make arrangements to ensure that members of the public have access to these registers on request. The CCG has determined Decision Making Staff as: . 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) 2 3. Registers of Interest 3.1 East Lancashire CCG The full Register of Interests is attached at Appendix A, noting that the published register will only include those individuals identified as decision making staff. 3.2 Blackburn with Darwen CCG A full review of the CCGs Corporate Registers are routinely presented to the CCGs Audit Committee on a quarterly basis to provide assurance. The Register of Interest was presented to the Audit Committee on 3 March 2020 and is attached at Appendix B. 4. Training 4.1 To further support CCGs to manage conflicts of interest, NHS England launched online Conflict of Interest training in 2018. The training package raises awareness of the risks of conflicts of interest and how to identify and manage them. Module 1 of the training covers what conflicts of interest are; how to declare and manage conflicts of interest, including individuals responsibilities; gifts and hospitality and how to report any concerns. Module 1 is mandatory for decision making staff and there was is an annual requirement for 90% of the relevant CCG staff to complete the mandatory online training by 31 January 2020. 4.2 Blackburn with Darwen CCG achieved 100% compliance and East Lancashire CCG achieved 92% compliance. 5. Register of Gifts, Hospitality & Commercial Sponsorship 5.1 The CCGs maintain a Register of Gifts, Hospitality & Commercial Sponsorship. 5.2 The overarching principles include the following: . CCG staff should not accept gifts or hospitality that may affect, or be seen to affect, their professional judgement; . Any personal gifts of cash or cash equivalents must always be declined; . Gifts from suppliers or contractors doing business with the CCG should be declined. Modest gifts under the value of £50 may be accepted from patients, families and service users and do not need to be declared; . Gifts valued at over £50 should be treated with caution and only accepted on behalf of an organisation and not in a personal capacity. These should be declared; . Hospitality must only be accepted when there is a legitimate business reason and is proportionate to the nature and purpose of the event; . Hospitality under the value of £25 may be accepted and need not be declared. Of a value between £25 and £75 may be accepted and must be declared. Of a value over £75 should be refused unless senior approval is given. A clear reason for accepting should be recorded on the Register; 5.3 The CCGs must publish their Register of Gifts, Hospitality & Commercial Sponsorship of decision making staff on an annual basis and make arrangements to ensure that members of the public have access to these registers on request. 5.4 East Lancashire CCG The 2019/20 Register of Gifts, Hospitality and Commercial Sponsorship is attached at Appendix C. 5.5 Blackburn with Darwen CCG A full review of the CCGs Corporate Registers are routinely presented to the CCGs Audit Committee on a quarterly basis to provide assurance. The Register of Gifts & Hospitality was presented to the Audit Committee on 3 March 2020 and published on the CCG website. 3 6. Procurement Register 6.1 The Register of Procurement decisions and contracts awarded is informed by colleagues in the Contracting Team at Midlands and Lancashire Commissioning Support Unit. 6.2 East Lancashire CCG The full Register of Procurement Decisions is attached at Appendix D. 6.3 Blackburn with Darwen CCG A full review of the CCGs Procurement Register is routinely presented to the CCGs Audit Committee on a quarterly basis to provide assurance. The Register of Procurement was presented to the Audit Committee on 3 March 2020 and published on the CCG website. 7. Quarterly Self-Certification 7.1 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 statutory guidance on managing conflicts of interest for CCGs. 7.2 The self-certification must be signed by the Accountable Officer and Audit Chair to confirm the information given in the quarterly and the annual self-certification is accurate. Both CCGs have submitted their Quarter 3 return for 2019/20, in line with national timescales outlining compliance in all areas. 8. Conclusion 8.1 The report provides an overview of the processes in place for managing conflicts of interest and to provide assurance to the Governing Bodies. Work is now underway to align reporting for both CCGs. 9. Recommendations 9.1 Members are asked to: . Receive the Register of
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