It’s hard to find anyone with a positive view of the new architecture of the health service, but just as hard to find anyone who wants to go through the pain and distraction of yet another structural reorganisation. The default mode, then, must be to make the best of what we have. Part of that picture is to ensure that the governance of CCGs is as robust as possible while delivering business in a sensible manner.
That lies behind CIPFA’s new publication Practical Issues in the Governance of CCGs [pdf], which aims to chart a suitable course for pragmatic arrangements. Building on CIPFA’s pan-public sector involvement in governance issues, it takes account of the frequent possibility if conflicts of interest arising, given the dual role of doctors as commissioners and providers, and of the complicating factor of the Better Care Fund.
It incorporates a checklist of specific points to consider:
- Is there an understanding of the principles of corporate governance?
- Does the CCG’s constitution reflect the new CIPFA / IFAC International Framework?
- Have relevant roles been set out clearly to ensure understanding?
- Does the CCG have guidance on conflicts of interest which reflects the various sources of guidance available?
In particular:
- Are arrangements in place to identify potential conflicts of interest as early as possible in the decision making process? As a fallback safeguard, is there a standard item at the beginning of agendas to confirm if there are conflicts of interest?
- Has a view been taken in advance on the appropriate involvement of practices when typical conflicts arise?
- Is there action in place to monitor possible patterns indicative of conflicts of interest, such as assessing referral patterns, involvement of third parties and / or referral managements systems?
- Have decisions been structured to split decisions on ‘is this a good health care idea?’ from those on ‘how can it best be delivered’?
Have the relevant practical arrangements been made to set up governance and transactions to enable smooth and consensual operation of the Better Care Fund?
Have Better Care Fund risks been identified and mitigation put in place, both those shared by the CCG and council, and those arising as a consequence of collaborative action but the impact of which would fall on the CCG?