Fighting fraud is important for any organisation. In the public sector, there must be confidence that money from taxpayer-funded services isn’t diverted illegally for purposes other than for what it’s originally intended. Minimising the loss from fraud is a hugely important part of delivering value for money and ensuring that resources are used as efficiently as possible.
To support providers and commissioners of National Health Service (NHS) services in putting in place the right counter fraud arrangements, the NHS Counter Fraud Authority (NHSCFA) issues standards on work to prevent, identify and investigate fraud. This is part of the NHSCFA’s role in leading the fight against NHS fraud.
The NHS counter fraud standards have been in place for just over five years, and are updated on a yearly basis. The 2019-2020 standards include the following changes:
*The way in which the NHSCFA refers to its case management system has changed (to future-proof the documents the NHSCFA will no longer use the brand name of any system, but simply refer to the ‘case management system’)
*The NHSCFA has refined and clarified the responsibilities of an organisation’s executive Board with regard to counter fraud work
*System weaknesses should be recorded during the course of an investigation and not just as a result of the investigation itself
*Organisations’ approach to risk management and risk policy has been clarified
Meeting required standards
It’s the responsibility of the organisation as a whole to ensure that it meets the required standards. A range of departments are likely to be involved in helping the organisation to meet them, including finance, internal and external audit, risk, communications and HR. However, there are a number of key roles involved in ensuring robust counter fraud arrangements are in place and taking forward counter fraud work, including local counter fraud specialists, directors of finance and Audit Committee chairs.
For providers, the requirement to adhere to the counter fraud standards is founded on the NHS Standard Contract. This should be used by Clinical Commissioning Groups and NHS England when commissioning NHS-funded services including acute, ambulance, care home, community-based, high secure and mental health and learning disability services. The counter fraud requirements form part of Service Condition 24 of the contract.
Commissioners should review providers’ arrangements to make sure they meet the requirements under the contract. Commissioners also need to ensure that they have appropriate counter fraud arrangements in place themselves.
One key date for organisations this year will be 30 April when submission of the Self Review Tool will be required. This is an aid to help organisations build a picture of the state of their own counter fraud arrangements and it forms part of the NHSCFA’s quality assurance programme.