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Greater Glasgow NHS – Register of Interests

5 June 2013
Greater Glasgow NHS

Dear Mr Gordon
Thank you for your request for information received on 8 May 2013 by NHS Greater Glasgow and Clyde relating to register of payments from pharmaceutical companies to staff as described in your email below.

We are treating your request under our procedures for responding to requests for information under the Freedom of Information (Scotland) Act 2002.

I can confirm that NHS Greater Glasgow & Clyde holds information as described by you.

As a general principle where decisions are being taken about medicines that could be influenced by a personal or non-personal interest then declarations of interest are made and appropriate action taken in terms of non-participation or actual participation in the discussions, however, the information is not necessarily routinely collated. Individual staff members are expected to record such information in the on-line register.

The medicines advisory structures tend to have a more formal collation of interests from members:

  • Members of the medicines advisory structures complete a standard declaration of interest proforma.
  • At each meeting those attending are required to declare interests when relevant to agenda items.
  • Participants in Clinical Guideline Development Groups make a declaration of interest, noted on the documentation, but not routinely collated.
  • Applicants and panel members for each Individual Patient Treatment Request make declaration of interest.

I am able to provide the information you have requested and the following is attached:-

  • Icon 1  – Extract from NHSGGC Code of Conduct for Staff on-line register
  • Icon 2 –  Sample of declaration of interest proforma
  • Icon 3 – Area Drugs and Therapeutics Committee and Associated Sub
  • Committees [Some declarations have still to be received]
  • Icon 4 – Pharmacy and Prescribing Support Unit Executive Group
  • Icon 5 – FOI requirement for review
  • Icon 6 – Review Form.

Yours sincerely
Elizabeth Watt

Secretariat Department
J B Russell House
Gartnavel Royal Hospital

Full communication with Greater Glasgow NHS is here (including attached Excel spreadsheets): https://www.whatdotheyknow.com/request/register_of_payments_from_pharma_157#incoming-396416

Summary spreadsheet of all FOI returns here (due to the heterogeneity of the returns this is a rough guide at best): https://docs.google.com/spreadsheet/ccc?key=0ApF86-MCSbZzdGlVd2ZPYWhyN1ZUbkliNlFpTGxtMFE&pli=1#gid=0

Alex Neil, Cabinet Secretary for Health and Wellbeing considers this matter:

Alex-Neil-on-Reg-of-Interes

NHS Lanarkshire – Register of Interests

6 June 2013
NHS Lanarkshire

All members of NHS Lanarkshire staff are provided with a copy of our Standards of Business policy, which requires staff to declare any interests to their line manager.This information is held by individual department managers and is not centrally recorded. To find this information would require each individual manager to manually check their records to identify whether a member of their staff has submitted a register of interest. This information gathering would exceed the charging threshold prescribed in the Regulations made by the Scottish Ministers which constitutes a ground of exemption in terms of Section 12 of the Freedom of Information (Scotland) Act 2002.

However, I can provide the following information, which I hope you will find useful.

NHS Lanarkshire Board
All members of NHS Lanarkshire Board complete a declaration of interest form. Currently, none of the declarations forms from Board members include any association with a pharmaceutical company. The declaration of interests for 2012 is available on the NHS Lanarkshire website at the following link: http://www.nhslanarkshire.org.uk/About/B…. The forms for 2013 will be submitted to the Board later in June.

NHS Lanarkshire Drugs and Therapeutics Committee
All members of our NHS Lanarkshire Drugs and Therapeutics Committee are also required to complete a register of declaration of interest form. This form is required at all meetings where medicines are being contracted for or where decisions are being made regarding which drugs to include in the NHS Lanarkshire formulary. I have attached a copy of the declaration of interest forms for the Area Drug and Therapeutics Committee for the year 2011/12, adjusted to exclude anything which would constitute personal data in respect of which the first condition referred to in Section 38 of the Act is satisfied. The details edited from the document are the signatures of the members of staff.

Hairmyres Hospital
All members of NHS Lanarkshire staff are provided with a copy ofour Standards of Business policy, which requires staff to declare any interests to their line manager. I have attached a copy of the centrally recorded hospitality register for staff at Hairmyres Hospital. There may also be declarations of interests made to individual line managers. To find this information would require each manager to manually check their records and this would be exempt under Section 12 of FOISA as detailed above.

Wishaw General Hospital
All members of NHS Lanarkshire staff are provided with a copy of our Standards of Business policy, which requires staff to declare any interests to their line manager. There are currently no entries in the centrally recorded register for staff at Wishaw General Hospital There may also be declarations of interests made to individual line managers. To find this information would require each manager to manually check their records and this would be exempt under Section 12 of FOISA as detailed above.

Monklands Hospital
All members of NHS Lanarkshire staff are provided with a copy of our Standards of Business policy, which requires staff to declare any interests to their line manager. There are currently no entries in the centrally recorded register for staff at Monklands Hospital. There may also be declarations of interests made to individual line managers. To find this information would require each manager to manually check their records and this would be exempt under Section 12 of FOISA as detailed above.

North Lanarkshire Community Health Partnership
There are currently no entries in the centrally recorded register for staff in North Lanarkshire Community Health Partnership. There may also be declarations of interests made to individual line managers. To find this information would require each manager to manually check their records and this would be exempt under Section 12 of FOISA as detailed above.

South Lanarkshire Community Health Partnership
Declarations of interest for South Lanarkshire Community Health Partnership are recorded in the minutes at each Operating Management Committee meeting. There are currently no entries for staff in South Lanarkshire Community Health Partnership

Yours sincerely
Linda Brownlie
Freedom of Information Officer
NHS Lanarkshire

From: Peter J Gordon
6 June 2013

Dear Fiona Snedden,,
Thank you for your reply under FOI.

I note that NHS Lanarkshire have circulated NHS Lanarkshire ‘Standards of Business policy’

I also note only three submissions to NHS Lanarkshire Hospitality Register (S. Miller – on 2 occasions) (N . Mathias – on 1 occasion). I note on neither occasion was this valued in financial terms.

I would worry, on behalf of the public, and transparency, that the Hospitality Register of NHS Lanarkshire falls short of the Scottish Government position, as stated in: A Common Understanding 2012 – Working Together For Patients. published 2 Nov 2012:http://www.scotland.gov.uk/Publications/&#8230;

Would NHS Lanarkshire agree with such concern? FOI enquiries from Scottish NHS Boards on ‘Hospitality Registers’ have been variable but no other Board has so far met (under FOI requests) Scottish Government Guidance. I thought it important to share this evidence.

Yours sincerely,
Peter J Gordon

Note: NHS Lanarkshire has no central register. NHS Lanarkshire repeatedly cites excemption under Section 12 of FOISA.

Full correspondence with NHS Lanarkshire is here:
https://www.whatdotheyknow.com/request/register_of_payments_from_pharma_159#outgoing-279071

Alex Neil, Secretary for Health and Wellbeing considers this matter here:

Alex-Neil-on-Reg-of-Interes

NHS Fife – Register of Interests

11 February 2013
Subject: RE: FOI Request 2126 – Hospitality register

Dear NHS Fife
I am so grateful for your help and for providing the various  spreadsheets for NHS Fife submissions to its Hospitality Register.

At first view I cannot find any mention of honoraria for lectures  given on behalf of any party outwith the NHS. It may be there have  been none. Could you perhaps confirm this?

Kind wishes,
Peter Gordon

15 February 2014
RE: FOI Request 2126 – Hospitality register

Dear Dr Gordon
It is each member of staff’s responsibility to record any items of hospitality or areas of interest. This is outlined in the Code of Corporate Governance. If they have not provided that information to us then we would not be able to register it. I suppose the answer is that our registers contain all declared details and to our knowledge no member of staff has received an honoraria for lectures given on behalf of any part outwith the NHS.

Yours sincerely
FOI Lead Officer,
NHS Fife

—————

It should be noted that NHS Fife can provide a Register for only ONE year: 2012-13. Yet as Alex Neil, Cabinet Secretary for Health and Wellbeing confirms, it was TEN years ago, in 2003 that HDL (2003) 62made it clear that all Health Boards should establish a Register of Interests fr all NHS employees ..”

The four separate registers for 2012-2013 can be accessed here (one covers Board members only)http://www.nhsfife.org/nhs/index.cfm?fuseaction=nhs.pagedisplay&p2sid=71B12675-9C8C-A40F-C98B59DDC8C9C917&themeid=3B984BF2-65BF-00F7-D42941481355468F (scroll to bottom of the page)

The full communication with NHS Fife can be accessed here: https://www.whatdotheyknow.com/request/register_of_payments_from_pharma_165#outgoing-277750

Note:
Only one payment disclosed: “CHP Annual Conference received a total of £2,400 contribution towards hospitality and exhibition space from 7 Pharmaceutical Companies”

Alex-Neil-on-Reg-of-Interes

Dumfries and Galloway NHS – Register of Interests

Dumfries and Galloway NHS

31 May 2013

“Attached are a redacted Gifts and Hospital Register and Pharmaceutical Interests for 2008, 2009, 2011 and 2012. There is no pharmaceutical interests register for 2010”

Chief Executive’s Office
Freedom of Information
Mid North Crichton Hall
Bankend Road
Dumfries
DG1 4TG

After some further communication, Dumfries and Galloway NHS, supplied on the 28 June 2013 the above registers free of redacted names of employees.

Dumfries and Galloway NHS Registers and all communications with Dumfries and Galloway NHS can be accessed here: https://www.whatdotheyknow.com/request/register_of_payments_from_pharma_155#outgoing-283202

Note: NHS Dumfies & Galloway Register for 2008 is unspecified: “Lilly. Astra Zeneca, Lundbeck, Janssen-Cilag, BMS, Pfizer, Wyeth and Servier – Sponsorship for various meetings” and “Lilly, Astra Zeneca Cilag- occasional honoraria for lecturing, meetings, consultancy and sponsorship to educational events/meetings”

NHS Dumfies & Galloway Register for 2009 is unspecified: 19 departments listed and multiple Pharmaceutical Companies involved

For summary of Registers (due to the heterogeneity of the returns from across Scotland) this is a rough guide at best:: https://docs.google.com/spreadsheet/ccc?key=0ApF86-MCSbZzdGlVd2ZPYWhyN1ZUbkliNlFpTGxtMFE&pli=1#gid=0