PUBLICATION/ Feb 2021

Declare interests. Manage conflicts. Protect the NHS.

This report looks at how changes to the NHS in England over the past decade have created greater risks of abuses of power, and how reforms to local commissioning are exacerbating them. Since 2012, membership organisations made up of General Practitioners (GPs), called Clinical Commissioning Groups (CCGs), have managed most of the NHS’ budget in England. They are responsible for purchasing £78 billion of healthcare services on behalf of the NHS. At the same time, these same GPs are independent contractors to the NHS and are in receipt of around £8.5 billion of NHS funding each year.


Because CCG governing boards comprise commissioners and contractors of health services, obvious conflicts of interest can arise. If not managed properly, this can result in the misuse of public money for private benefit at the expense of patients and taxpayers. As with any public body, these organisations should have measures in place to protect against the risks of impropriety. Specifically, they should have:

  • transparent and effective management of any potential conflicts of interest held by senior officials
  • clear governance arrangements

These core protective measures aim to prevent abuses of power for private gain and to ensure that decisions about healthcare services are taken in the best interests of patients and taxpayers.


This report looks at the potential scale of conflicts of interest within local NHS commissioning organisations in England, and how these organisations protect against their abuse. It covers CCGs and their emerging successor bodies that are taking over the co-ordination of local NHS services – Sustainability and Transformation Partnerships (STPs) and Integrated Care Systems (ICSs).

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Declare interests. Manage conflicts. Protect the NHS.

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