Question to the Department of Health and Social Care:

To ask Her Majesty’s Government what is their assessment of whether NHS England's audit of conflict of interest is sufficiently comprehensive to govern circumstances in which Clinical Commissioning Groups enter into contracts with companies in which one or more of their board members has a financial interest.

NHS England has commissioned an independent audit of conflicts of interest management in 10 primary care co-commissioning arrangements. The audit fieldwork commenced in September 2015, with the final report due to be shared in January 2016. It is therefore too early to make an assessment of their findings.

The audit has been asked to examine and evaluate:

- arrangements to manage conflicts of interest;

- audit compliance with the statutory guidance on managing conflicts of interest and identify any areas of the guidance which need to be strengthened;

- identify and share good practices in managing conflicts of interest;

- identify future improvement opportunities; and

- share learning with commissioners in support of their development.

Each audit includes 360 degree interviews with representatives from:

- the clinical commissioning group (including the Chair of the primary care commissioning committee, Audit Chair, Accountable Officer, Finance Director, Clinical Chair/GP member of the primary care commissioning committee);

- NHS England (including the Director of Commissioning Operations, Head of Primary care and a Primary care commissioning manager for the locality);

- local Healthwatch;

- local Medical Committees (LMCs);

- Local Authorities; and

- Local Pharmaceutical Committees (LPCs).

The audit also comprises a detailed review of key governance documentation including:

- registers of interest, declarations of interest and registers of procurement decisions;

- co-commissioning governance arrangements;

- commissioning contracts that were entered into since 1 April 2015;

- guidance for CCG employees on managing COIs;

- guidance on dealing with breaches and details of any breaches; and

- minutes of primary care commissioning committee meetings since 1 April 2015 etc.

Each audit site will receive an individual report, detailing the findings for their specific arrangement. In addition, NHS England will receive a consolidated report, highlighting key themes, examples of good practice and recommendations to assist in the management of conflicts of interest.

Key learning from the audit will be shared with commissioners in January 2016 in support of their development and the findings will help inform the refresh of the statutory guidance on managing conflicts of interest.