1) Make sure you have a clear conflicts of interest policy which is communicated and understood within the CCG.
2) Ensure you encourage a culture which supports declarations of conflicts of interest.
3) Consider governing body and wider GP training and stress that the rules are designed to protect the reputation and integrity of the individual as well as the organisation.
4) Keep your register of interests up to date and ensure participants at meetings are invited to declare conflicts at the beginning of meetings and when they arise during meetings.
5) Keep written records of conflicts of interest which are declared and detailed minutes of meetings to show how those conflicts were managed. This is your best defence if challenged later!
6) Consider securing clinical input from providers who don’t have the conflicts of interest – your constitution will often allow the CCG to co-opt members from health and wellbeing boards or neighbouring CCGs to vote in cases where conflicts of interest arise.
Oliver Pritchard is head of commercial health at Browne Jacobson LLP