Re: Aylesbury Vale CCG Conflict of Interest
Thank you for our email dated Wednesday 8th January regarding your ongoing queries about our conflict of interest policy and behaviours.
In terms of the Companies House records for Vale Health, I have relayed your comments back to the Company Secretary so that he can contact you directly once the process of updating the annual return has been undertaken.
With reference to your concern about Vale Health Ltd, I write to confirm that Aylesbury Vale CCG is the lead contractor for the Out of Hours service and Minor Injuries & Illness Unit (MIIU) that is contracted through Bucks Urgent Care, of which Vale Health is a partner within a Joint Venture arrangement. It is important to note that the existing contract with Bucks Urgent Care was awarded by the Buckinghamshire Primary Care Trust (not the CCG, as it was before our time) and passed to us as a legacy contract.
In terms of wider commissioning processes, it is our intention to be as open and transparent throughout the whole commissioning cycle, as this gets the best results for our patients. We actively seek to engage our stakeholders in helping us describe what the ‘gold standard’ service looks like. This engagement will include not only our public and patients but also potential providers of those services, as this offers the greatest opportunity for developing innovative and high quality services.
As you state, strategic commissioning is a complicated process to determine the health needs, wants and preferences of our community. Within this large and multi modal process we aim to offer our public, patients and all stakeholders – including potential providers of services – the opportunity to influence not only the shape of our strategy but also how individual services should be commissioned.
For example, we need to take into account the views of local hospital Consultants and GPs when we describe services for patients, as they have significant intelligence about the clinical quality and safety of the services being shaped for procurement. Such discussions therefore include clinicians from several of our local hospital providers, who are arguably part of your ‘systemic’ network of interests, as their hospital could be intending to bid for the service.
Where commissioning and procurement decisions have to be made, our Conflict of Interest policy gives us clear guidance on how to handle actual or perceived conflicts. If our Executive team were conflicted to the point that there were not enough non-conflicted members to be quorate then the decision would be passed to the Governing Body.
We remain of the view that we cannot remove ourselves from the many perceived or actual network of interests across our health and social care commissioners and providers. However, we do not see this as a systemic problem, rather as an opportunity to embrace our stakeholders’ engagement in order to maximise innovation and high quality commissioning in the knowledge that we have a very clear process for handling commissioning decisions in the event of a perceived or actual conflict of interest.
Aylesbury Vale CCG
Here is my reply to her:
Thank you for your reply to my last email. Many thanks for ensuring that the Vale Health Secretary will alert me when the process of updating the annual return has been undertaken. Thank you also for the information about Vale Health and the legacy contract that the CCG inherited.
Of course, like you, I see the value in engaging with the widest possible set of people in developing your commissioning plans. However, I fail to understand how this justifies many members of your Executive Team having a personal financial interest in the outcomes of that commissioning process. It seems to me that the current arrangements mean that:
- Other commercial / non-commercial providers are not party to, in the same way, the deliberations of the CCG. In other words, by having such a predominant interest in one commercial provider, the CCG is supporting a non-level playing field for all potential bidders / providers. Is this fair?
- Aside from being transparent about what interests different parties hold (and I note that you have not addressed my concern about the absence of any accessible information on your website) and arrangements to ‘step outside the room’ when a critical decision is being taken, you seem relaxed about all other ways in which the interests of the Executive Team might influence the spending of public money. If this is never an issue, why do members of government have to place their investments in blind trusts?
Indeed you seem to embrace the advantages of having a majority of your Executive team being shareholders in a local commercial (for-profit) provider “as an opportunity to embrace our stakeholders’ engagement in order to maximise innovation and high quality commissioning”. I am really not sure that the general public would see it in this way. Have you consulted them on this aspect of the CCG? I, for one, see this as a very slippery slope which holds the potential of the NHS being run for financial rather than health interests. It is very simple to solve the potential problem now.
Finally, please will you address the point that I have raised twice about the absence of any performance links working on your website. I am sure you wish the public to support your approach to commissioning as one that is yielding positive health outcomes for the people of Aylesbury Vale. At the moment, the public have little idea as to what is being achieved with our money as your website is providing no easy access to performance data.
Thank you, as before, for your attention to these matters.