NHS England guidance on managing conflicts of interest
NHS England has just published new guidance on managing conflicts of interest which comes into effect from 1 June 2017.
The guidance aims to:
- Introduce common principles and rules for managing conflicts of interest.
- Provide simple advice to staff and organisations about what to do in common situations.
- Support good judgement about how interests should be approached and managed.
Further information about the guidance is available from NHS England. The full document can be found here but the main elements of the new guidance are:
On gifts staff should:
- Decline anything that may affect their professional judgement
- Decline gifts from suppliers or contractors, save for low cost promotional items up to £6 in value
- Not ask for gifts and decline all offers of cash (or cash vouchers)
- Only accepts gifts with a value over £50 on behalf of their organisation and declare these. The same applies to multiple gifts from the same source with a cumulative value of over £50.
On hospitality staff should:
- Decline anything that may affect their professional judgement
- Accept without declaration hospitality up to £25, declare hospitality between £25 and £75 and refuse hospitality over £75 (unless exceptional senior approval is given)
- Declare modest offers of travel and accommodation and refuse offers which go beyond modest unless senior approval is given. These must also be declared.
On outside employment staff should:
- Declare any outside employment (where, when and what)
- Where contracts permit, seek prior permission from their organisation to engage in outside employment
On shareholdings staff should:
- Declare any shareholdings and ownership interests in companies or organisations which might do business with their organisation
- Not declare shares or securities held in collective investment or pension funds or units of authorised unit trusts
On patents staff should:
- Declare patents and intellectual property rights they hold which are or could be procured by their organisation
- Seek prior permission before entering into agreement with bodies to develop products or other work that impacts on organisational time, equipment or resources
On loyalty interests staff should:
- Declare positions of authority in other organisations that could be seen to influence decisions they take in their NHS role
- Declare when they sit on advisory groups or similar forums
- Declare involvement in recruiting people they know
- Declare when people they know do business with their organisation
On donations staff should:
- Seek prior organisational approval to engage in fundraising as part of their professional role
- Not routinely accept donations from suppliers
- Not solicit charitable donations unless this is a part of their role
- Ensure donations are made to a charitable fund, not an individual
On sponsored events staff should:
- Declare involvement with a sponsored event
- Not supply information which would allow a sponsor to gain commercial advantage
- Ensure that sponsors do not have a dominant influence over events and make their involvement transparent
On sponsored research staff should:
- Declare involvement with sponsored research to their organisation
- Ensure appropriate approvals are received
On sponsored posts staff should:
- Seek prior approval before undertaking a sponsored post
- Not promote or favour sponsor’s products or be unduly influenced
On clinical private practice staff should:
- Seek prior organisational approval.
- Declare any clinical private practice (where, when and what)
- Ensure NHS commitments take precedence
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