Counter Fraud

What is fraud and how does it impact the NHS?

Fraud is committed when a person deliberately makes a dishonest representation in order to make a gain or to cause a loss to someone else. For example, if someone stated on their expenses claim that they had travelled 50 miles when really they had only travelled 10, this would be fraud. The person has made a false representation in order to make a gain.

Fraud comes in many different forms. The NHS Counter Fraud Authority (NHSCFA) has produced a reference guide which provides loads of different examples of how the NHS can be affected by fraud – you can find the full guide here. At the latest estimate, it is believed that the NHS loses over £1.2 billion a year to fraud. NHS fraud diverts public funds away from the services that we all pay for, and into the pockets of dishonest people.

The role of the Local Counter Fraud Specialist

North Lincolnshire Clinical Commissioning Group has a dedicated Local Counter Fraud Specialist (LCFS). The role of the LCFS has several strands, and is overseen by the Chief Finance Officer at a local level, and by the NHSCFA at a national level. Your LCFS will ensure your employer is meeting the standards set by the NHSCFA that policies and procedures are fraud proof, and that staff are encouraged and enabled to learn more about NHS fraud. The LCFS is also responsible for investigating allegations of fraud, bribery and corruption. Your LCFS is here to help. If you have concerns about fraud affecting the NHS, please do get in touch with them for advice.

Updated Counter Fraud Contact Numbers

Local Counter Fraud Specialist on 07872 988939 / email nikki.cooper1@nhs.net or Head of Anti-Crime Services on 07717 356707 / email steven.moss@nhs.net.

Reporting fraud

If you have concerns about fraud you can report it through the following channels:

Directly to your LCFS using their contact details listed above
Directly to the Chief Finance Officer, Emma Sayner
By contacting the NHS Counter Fraud Authority reporting line on 0800 028 4060
By completing an online report: https://reportfraud.cfa.nhs.uk/

All reports will be dealt with confidentially. Please note that the best route for reporting is to speak to your LCFS. If you would prefer to make an anonymous report via the NHSCFA hotline or web form, please provide as much detail as possible as the LCFS will not be able to get back in touch with you to ask for any further information or clarification about your concerns.

Examples of types of fraud

Patient Travel Expenses – a patient in receipt of qualifying benefits may claim travel expenses for secondary care appointments. If the person submits claims for additional journeys that they didn’t actually take, this would be fraud.
Mandate Fraud – a fraudster contacts an NHS finance team pretending to be a genuine supplier. They request that the suppliers’ bank details are updated, and the next payment made to the supplier is diverted into the fraudster’s bank account.
Working Whilst Sick – a person is signed off sick from their NHS role but then works elsewhere during their sick leave.

How to arrange a presentation/awareness session

One of the simplest ways you can help to counter fraud in the NHS is to organise a fraud awareness presentation for your team. We are always happy to speak to different teams across the NHS. We can tailor our presentations to cover the specific fraud risks you are most likely to encounter, and will fit around your team’s availability. If you would like to arrange a session, please contact Nikki using her contact details above.

A list of the training sessions we can offer

Fraud Awareness 30 minutes – suitable for all departments and staff groups
Fraud Awareness 60 minutes – a more in depth look at fraud in the NHS, suitable for all staff
Recruitment Fraud Awareness – for HR teams and recruiting managers
Procurement Fraud Awareness – Procurement/Finance Teams
Mandate Fraud and Phishing Refresher – suitable for all staff but most applicable to finance teams
We would be happy to deliver any other bespoke training for you, or to pop along to a team meeting for an informal chat. We are able to offer training remotely via Microsoft Teams. Please contact your LCFS to discuss any training needs and we would be happy to help

The role of the fraud champion and who the fraud champion is:

The role of the Fraud Champion is to raise awareness of fraud, to understand the risks posed by fraud, and to understand best practice in countering fraud. The Fraud Champion and the LCFS work closely to ensure that efforts are coordinated and effective. The Fraud Champion for NL CCG is:

Name: Louise Tilley, Deputy Chief Finance Officer
Contact email: louise.tilley1@nhs.net

Think FRAUD:

Counter fraud newsletters and alerts:

The Bribery Act Statement from the Accountable Officer

The Bribery Act 2010 came into force on 1 July 2011. The aim of the Act is to tackle bribery and corruption in both the private and public sector.

As an NHS organisation, we follow good NHS Business Practice and have robust controls in place to prevent bribery. However, as an organisation, we cannot afford to be complacent and it is important that all our employees, contractors and agents comply with CCG policies and procedures, particularly with regard to procurement and sponsorship.

It is essential that everyone working for, or on behalf of, the CCG is aware of the standards of behaviour expected of them. These standards are enshrined in the CCG Constitution and its policies – setting out the ethics, professional conduct and probity standards that are expected of all CCG employees in relation to their standards of business conduct. The CCG is working with its staff to raise awareness of the Act.

One of the six principles of the Act is that there is top level commitment in the organisation to the prevention of bribery. The Board of the CCG is committed to this and has agreed ways to communicate the importance of transparency and openness at all times. Our Lay Member for Governance has been identified as the lead person in the organisation for promoting the prevention of bribery.

On behalf of the CCG, I confirm our commitment to ensuring that all staff are aware of their responsibilities in relation to the prevention of Bribery.

Emma Latimer
Accountable Officer

National Fraud Initiative 2020/21

The CCG has a duty to protect the public funds it administers and as such participates in the National Fraud Initiative. This is an electronic data matching exercise conducted by the Cabinet Office, under statutory powers, for the purposes of preventing and detecting fraudulent and erroneous payments from the public purse. The exercise is run every two years.

The National Fraud Initiative has enabled participating organisations to prevent and detect £245 million fraud and error in the period 1st April 2018 to 4th April 2020. This brings cumulative outcomes since 1996 for NFI participants to £1.93 billion.

The types of frauds and errors previously identified by the NFI in the NHS include:

NHS employees with no right to work or reside in the UK
Employees working elsewhere whilst on sick leave
NHS workers fraudulently claiming housing and council tax benefits
Overpayment of invoices resulting from the payment of duplicate invoices and credit notes
Occupational pension payments paid to deceased pensioners several years after their death.

The Cabinet Office’s data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match. This is usually personal information. Computerised data matching allows potentially fraudulent claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency which requires further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.

Participation in the data matching exercise assists in the prevention and detection of fraud and involves the provision of particular sets of data to the Cabinet Office for matching for each exercise, and these are set out in the Cabinet Office’s guidance, which can be found here.

The use of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the General Data Protection Regulations 2018..

Data matching by the Cabinet Office is subject to a Code of Practice, which can be found here.

Details of the Cabinet Office’s data deletion schedule can be found here.

For further information on the Cabinet Office’s legal powers and the reasons why it matches particular information please click here.

The key contact for the CCG is Lesley McLean and if you have any queries regarding the exercise she can be contacted by e-mail: Lesley.mclean3@nhs.net