Managing Conflicts of Interest: Internal Audit Framework for CCGs

NHS England | Published online: 30 September 2016

Image source: NHS England
  1. In June 2016, NHS England published revised statutory guidance on managing conflicts of interest for CCGs. The guidance has been strengthened to further support CCGs to identify and manage conflicts of interest.
  2. One of the requirements of the revised guidance is that CCGs undertake an annual audit of conflicts of interest management as part of their internal audit plans (see paragraphs 127-130 of the guidance). This will be an important mechanism for CCGs to confirm and obtain assurance that the safeguards set out in the revised statutory guidance have been embedded. The outcome of the audit will need to be reported in the CCG’s annual governance statement, and discussed as part of the annual end-of-year governance meeting with NHS England regional teams.
  3. This document provides a framework to support CCGs to undertake an internal audit of conflicts of interest management, including the scope and approach. This framework has been developed in collaboration with the CCG Audit Chairs Forum and other key stakeholders.
  4. It is strongly recommended that CCGs adopt this framework for their 2016/17 conflicts of interest audit. CCGs should also consider any additional areas of risk, which should be included in the audit. In subsequent years, CCGs may wish to tailor their approach to take account of the findings from previous audit work, and to adopt a risk-based approach to determine the appropriate scope of the work.
  5. In the financial year 2016/17, we recommend that CCGs complete the audit in quarter three or four to give sufficient time for the safeguards set out in the revised guidance to be embedded prior to the audit taking place. In future years, CCGs should decide upon the best time to conduct the audit, although consideration should be given to the fact that completion will need to be reported as part of the CCG’s annual governance statement.

Read the full document here


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