Does the programme maintain a declaration of interests (DOI) register?
As you would expect, we follow legal and best practice guidance in this regard.
All decision-makers have to declare any interests and we keep an up to date DOI register. Under our programme governance, decision-making rests entirely with the CCGs – either the individual CCG Governing Bodies or, where appropriate, with a Joint Committee of CCGs.
For example, a Joint Committee of CCGs (chaired by a lay person) is currently managing primary care co-commissioning in south west London. The Committee is made up of local health commissioners – representatives from each of the 6 CCGs (including lay reps) and NHS England. ( A number of other people attend Joint Committee meetings – local Health and Wellbeing Board representatives, programme staff and local Healthwatch organisations. These people are invited to help with the running of the meeting and to provide information as needed to the Committee. As non-voting members, they are listed as ‘in attendance’.) A DOI register for members of the Joint Committee of CCGs is available on our website at https://www.swlccgs.nhs.uk/documents/joint-committee-of-ccgs-primary-care-declaration-of-interest-register/
Staff who work for the six CCGs part of South West London Commissioning Collaborative (SWLCC) are ‘hosted’ for administrative purposes by Wandsworth CCG (and funded jointly through the six CCGs). This is because SWLCC is not an organisation – it is the umbrella name of the partnership between the six CCGs and NHS England. All SWLCC employees are therefore employed by Wandsworth CCG on behalf of the CCGs and support SWLCC in delivering its objectives. None of the SWLCC staff make recommendations or decisions about health services – they are there to support the CCGs by enabling the programme to run smoothly.
However, in the interests of transparency, we are publishing a register of interests for senior staff who are responsible for reporting directly to the CCGs.
Wandsworth CCG maintains a register of interests for all employees, including SWLCC staff. The CCG will report publicly any conflicts of interest and how they have addressed them. This approach is common to other CCGs and NHS England.