Using ESR to Record Conflict of Interest
NHS Arden and Greater East Midlands Commissioning Support Unit is one of the largest Commissioning Support Units (CSUs) in the country with a variety of customers ranging from Clinical Commissioning Groups (CCGs) to local authorities, through to a range of care providers. As the CSU is an NHS organisation, it is entrusted with taxpayers’ money and this money must be spent well and free from undue influence. Due to the collaborative nature of delivering health and social care, there is a potential risk of conflicts of interest. In 2017, NHS England produced guidance for the management of conflicts of interest in the NHS; highlighting the importance of these interests being declared.
In March 2020, as part of Release 45, using the terminology defined by NHS England, ESR introduced the functionality to enable employees to declare conflict of interest details, in turn allowing organisations to report and share this information. This was a timely addition into ESR for the CSU who had undergone an IT upgrade to Office 365 in late 2019 which led to the bespoke system on which we historically recorded conflict of interests to be no longer supported.
As an interim solution, between the bespoke system no longer working and the ESR capability being released, the CSU reverted back to using paper to record our conflict of interest declarations. However, during this period, Jane Ibbett, the CSU’s Senior Integrated Compliance Consultant, completed research to understand what recording conflict of Interest in ESR would entail and how it would work. Jane piloted using ESR for the recording of conflict of interest within the Compliance team, whereby 15 staff members completed their declarations in ESR. The pilot was a success, with the employees highlighting how easy using ESR was so the CSU moved to roll out the recording of conflict of interest in ESR to the rest of the organisation in August 2020.
The CSU found many positives came about from using this piece of ESR functionality. Our compliance prior to using ESR was 70% of conflict of interest declarations completed whereas the move to ESR saw this increase to an impressive 93% (the policy at the CSU states that all staff are to make a declaration, nil or otherwise, annually). The CSU is on track to have all of their staff compliant by August 2021.
Not only did our compliance increase but we also found that monthly reporting is far simpler and quicker when using ESR Business Intelligence (BI). Reports that used to take three hours now take five minutes, which is a huge time saving for Jane and her team and, because ESR is the master workforce system, additional information can be used within these reports that otherwise would have taken a significant amount of time to add in, such as directorate and cost-centre, making Jane’s reports more meaningful.
We wanted a way in which we could remind our staff to complete their declarations, so we gave all staff a local competence requirement that expires yearly. Until the staff complete their declarations, they remain red for the conflict of interest competency, which encourages them to complete them and serves as an excellent reminder for staff to renew them again, in a years’ time. This process further supports Jane and her team to report the organisational compliance for declarations as they can easily see the number of staff with the competency and those yet to gain it, through ESR BI. This set up does require some manual input whereby the competence has to be updated for the employees once the employees have completed their declarations by the team, but this works for us and the extra time taken to add this information in is outweighed by the speed in which reports can be produced.
For Jane and the wider CSU there is a recognition that the implementation of the conflict of interest functionality has been overwhelmingly positive and we are looking forward to further enhancements to the functionality that, subject to testing, will be included in Release 50 (July 2021). This includes applicants being given access to record any conflicts they may need to declare prior to starting (using the applicant dashboard) and improved notifications for managers when employees have made a declaration.
For further information or to ask any questions about the implementation of the conflict of interest functionality at NHS AGEM CSU, please contact Jane Ibbett, Senior Integrated Compliance Consultant for NHS Arden and Greater East Midlands Commissioning Support Unit at firstname.lastname@example.org