Independent investigation into the governance arrangements at a London CCG

Independent investigation into the governance arrangements at a London CCG

The client

NHS England, Health sector


Governance Issues.

Leading up to full legal establishment on 1 April 2013, all clinical commissioning groups had to undergo an exhaustive authorisation process. This involved an audit of ‘fitness to trade’ under six separate domains: clinical focus, patient engagement, financial and operational planning, governance, commissioning intentions and leadership capability.

Verita was asked to examine the governance arrangements at one London CCG and review the submission for any potential negligence or misrepresentation.


The NHS Commissioning Board team assigned to one London CCG became concerned that the proposed governance arrangements were unconstitutional and open to potential malpractice. This undermined confidence in the entire authorisation submission, as senior officers appeared responsible for the proposals.

Verita’s experience with independent governance reviews in healthcare made us well suited to conducting this piece of work.


Working under significant time pressure, Verita undertook an initial desk-based review of the authorisation submission and the substantial supporting documentation underpinning it. Following this, our team then conducted a series of one-to-one interviews with both CCG staff and the recipient NHS Cluster team. This involved the construction of an agreed timeline of events, identification of the individuals active in decision making and a detailed triangulation of evidence. Central to the outcome was the separation of fact from hearsay and the ultimate determination of responsibility. The Verita team was led by partner Peter Killwick.


Our initial desk-based review revealed a number of areas of potential concern involving both current and former CCG personnel.

The investigation established that senior officers of the organisation had displayed significant lapses in judgement and undertaken actions outside any accepted public sector norm.


Our work allowed the NHS CB to initiate corrective actions prior to the authorisation deadline, avoiding legal or constitutional complications in an established body.