27
Accepted
On the basis that there was not a lot of cash to be earned from...
Conclusion
On the basis that there was not a lot of cash to be earned from this scheme by Greensill Capital, we asked what it was that the company was hoping to get out of this line of busines at the time. The National Audit Office has reported that Greensill Capital considered that a track record for Earnd with NHS employers would convince private sector employers to engage on a commercial basis. Greensill Capital also proposed other supply chain finance solutions to NHS trusts, but trusts surveyed by the National Audit Office reported that they had not taken this forward. The Department told us that the NHS logo and the NHS is a trademark owned by the Secretary of State and cannot be used without his permission. The Department stated that it intervenes when companies and others seek to do so and recognised the concern. The Department highlighted that people trying to access the NHS brand, which is a very powerful brand, was something it took direct interest in, with set measures in place to protect the NHS brand and also take action where misuse is identified.28 25 C&AG’s Report, para 23 26 C&AG’s Report, para 28 27 , Qq 142–147; C&AG’s Report, para 27 28 Qq 173–174; C&AG’s Report, paras 3.16–3.17, 16 The pharmacy early payment and salary advance schemes in the NHS Unregulated consumer lending
Government Response Summary
The government agrees with the committee's item and has implemented Procurement Policy Notice (PPN) 04/2021 to manage conflicts of interest, with CCS updating procurement processes and DHSC introducing a clear process for declarations throughout the contract lifecycle.
Government Response
Accepted
Government Response
Accepted
HM Government
Accepted
2.1 The government agrees with the Committee’s recommendation. Recommendation implemented 2.2 In 2020, the National Audit Office and the Boardman Review recommended that additional, practical guidance be made available for all in-scope organisations regarding the management of conflicts of interest in commercial environments. As a result, on 20 May 2021, the Cabinet Office published Procurement Policy Notice (PPN) 04/2021 covering the issue of conflicts of interest in awarding contracts and interpretation of the relevant exclusion provisions where contractors commit certain breaches. 2.3 The Crown Commercial Service (CCS) ensures that their framework procurement process considers conflicts of interest and has recently carried out checks to ensure that each stage of it fully complies with PPN 04/2021; this includes updating the templates it uses as part of the framework procurement evaluation process. This is to ensure contemporaneous confirmation is explicitly sought and captured that CCS teams and other interested parties in the procurement have considered and declared any perceived or actual conflicts of interest. 2.4 The Department of Health and Social Care (the department) has completed its implementation of the PPN 04/2021. It has introduced a clear process to ensure that conflicts of interest are considered at appropriate stages of the procurement lifecycle, which includes a review of the declaration forms in line with the PPN. 2.5 As part of the annual contract management assurance process for 2022-23, the department will ensure that all of its contract managers (officials) routinely complete a conflicts of interest declaration during their involvement in managing contracts. All contractors working for the department are required to complete the conflicts of interest form.
Source
Committee
Public Accounts Committee
Inquiry
NHS supply chain finance
Report
Thirty-Fifth Report - The pharmacy early payment and salary advance schemes in the NHS
04 Feb 2022
HC 745
Addressee Bodies
HM Treasury
Timeline
Recommendation age
4.5 yrs
Report published
04 Feb 2022