DECLARATION OF INTERESTS
Featuring LPFT, ICB, ULHT
COMMUNICATIONS (LINCOLNSHIRE PARTNERSHIP NHS FOUNDATION TRUST) <lpft.communications@nhs.net>
Wed 13/03/2024 02:19
Good morning,
Thank you for your email. We apologise that this information was not showing on the website, there appeared to be a technical issue that we have now resolved. You can now find the register of interests for our Board of Directors using the following link –
How can you have the CEO on the Board plus work as a specialist advisor for CQC or The Director of Operations (Chris Higgins) for LPFT also work as an Executive Reviewer for CQC???
BOARD OF DIRECTORS’ REGISTER OF INTERESTS AS AT 29 FEBRUARY 2024 NO. DATE OF ENTRY NAME NATURE OF DECLARATION DISCLOSED DATE OF DECLARATION 1 04/02/19 21/09/22
Sarah Connery 1) Specialist Advisor for the Care Quality Commission (CQC) 2) Partner member of the Lincolnshire Integrated Care Board (ICB) for mental health (wef 01/07/22) 31/01/19 21/09/22 2 21/09/22 04/12/23
Chris Higgins 1) Member of the Lincolnshire Integrated Care Board Finance Committee 2) Executive Reviewer for the Care Quality Commission (CQC) 20/09/22 29/11/23
Dear Ms Ellis
Of course they are conflicts.
Please see attached regarding the CQC
If the NHS purchase from Nemaura is a conflict.
From: ELLIS-FENWICK, Julie (NHS LINCOLNSHIRE ICB – 71E) <julieellis1@nhs.net>
Sent: 12 March 2024 08:54
To: susan bevis <susanb255@outlook.com>
Cc: BATES, Sarah (NHS LINCOLNSHIRE ICB – 71E) <s.bates@nhs.net>
Subject: RE: Conflict of Interest – ICB Board
Good morning
Thank you for your recent email.
As required by section 14Z30 of the NHS Act 2006 (as amended by the Health and Social Care Act 2022), the ICB has made arrangements to manage any actual and potential conflicts of interest to ensure that decisions made by the ICB will be taken and seen to be taken without being unduly influenced by external or private interest and do not (and do not risk appearing to) affect the integrity of the ICB’s decision-making processes.
The ICB has established a Standards of Business Conduct and Conflicts of Interest Policy, which was approved by the ICB Board at its first meeting held on the 1st July 2022. This policy sets out clear procedures to deal with situations where an officer/member has a conflict of interest and is included in the ICB Governance Handbook available here: http://www.lincolnshire.icb.nhs.uk
In accordance with section 14Z30(2) of the NHS Act 2006 registers of interest are recorded in the ICB Registers of Interests which is published on the ICB website. The Registers are regularly reviewed by the ICB’s Audit and Risk Committee for assurance purposes. They are also subject to a thorough review by the ICB appointed external auditors as part of the year-end audit process.
Further to the above, in accordance with section 14Z25(5) of, and paragraph 1 of Schedule 1B to, the 2006 Act the ICB must have a Constitution, which must comply with the requirements set out in that Schedule. The ICB is required to publish its Constitution (section 14Z29). The ICB Board adopted its Constitution at its first meeting held on the 1st July 2022 and this is published on the ICB website. This includes information on the Eligibility Criteria for Board Membership and the Disqualification Criteria. Neither of the interests declared by Dr Gerry McSorley and Mrs Julie Pomeroy preclude them from being an ICB Board Member.
I trust this responds to your queries but if you have any further concerns to raise, please do contact me.
Jules Ellis-Fenwick
NHS Lincolnshire ICB Board Secretary and
Head of Corporate Governance
Email: julieellis1@nhs.net
Please see below:
Current CQC advisors on trust boards may create conflicts of interest, making it difficult for the CQC to conduct fair and unbiased inspections and reviews. This raises questions about regulatory accuracy and fairness. Dual roles in healthcare regulatory bodies and provider organizations may also raise ethical concerns. People may lose trust in the healthcare system if conflicts of interest arise. It is important to determine if there are rules or guidelines to prevent conflicts of interest in different healthcare organizations.
Sources
According to NHS Providers (2023, 1), the Health and Care Act 2022 has introduced a new NHS landscape, allowing directors of NHS Foundation Trusts (FT) and Trusts (Trust) to have multiple roles. For instance, a director of an FT or Trust may also be a partner member of an Integrated Care Board (ICB). In most cases, the director’s duties to the FT or Trust align with those owed to the ICB, but in theory, these duties may conflict.
The CQC’s Declaration of Interest and Resolution of Conflicts policy, ratified in April 2015, requires all staff members to recognise and disclose activities that may lead to conflicts of interest or perceptions of conflicts and ensure proper management or avoidance to protect the credibility of the CQC’s work and its individuals. The policy applies to all levels of CQC staff, including employees, specialist advisors, contractors, temporary workers, experts by experience, second-opinion appointed doctors, and Mental Health Act reviewers. A parallel policy applies to CQC commissioners and independent members of CQC committees (CQC Board, 2015, 1).
Reference list
1. CQC Board (2015). Declaration of Interest and Resolution of Conflicts policy. [online] Available at: https://www.cqc.org.uk/sites/default/files/20180305_spa_declaration_of_interest.pdf %5BAccessed 8 Mar. 2024].
2. NHS Providers (2023). Commentary for NHS providers:conflicts of Interests for Foundation Trust and Nhs Trust Directors on Integrated Care Boards. [online] Available at: https://nhsproviders.org/media/695915/conflicts-of-interest-nhsp-advice-from-mwe-jun23.pdf %5BAccessed 8 Mar. 2024].
McSorley, Gerry (Board Member) Non-Executive Member and Deputy ICB Chair CQC
Julie Pomeroy also has connections to Nemaura Pharma Ltd.
Trust Board Members :: Lincolnshire Community Health Services NHS Trust
Sam Wilde – director of finance and business intelligence
Astra Zeneca.
Jim Connolly
Jim has a had a varied career in the NHS as a nurse, working in a range of clinical, managerial and executive roles. He worked as a Director of Nursing and was the National Director for Continuing Healthcare with NHS England. In addition he works with the Care Quality Commission as a specialist advisor on governance. Prior to joining LCHS he was a Non Executive Director at Lincolnshire Clinical Commissioning Group and is supporting the vaccination programme as a vaccinator at the Meres Clinic in Grantham.
Psychiatric Abuse UK 