Fraud is a high-volume crime which affects many within the UK. The Office for National Statistics reported that, in the 12 months to September 2017, there were 3.2 million incidents of fraud. Traditional law enforcement is unlikely to have the resource to tackle this volume of crime and therefore civilian bodies, including central Government, have created their own capability to tackle those frauds to which they’ve been subjected, writes Mike Gilbert.
Civilian counter fraud teams are nothing new. The Fraud Review Report published by the Attorney General’s Office in 2006 noted that, at that time, over 11,000 fraud investigators were employed by public sector organisations, while several thousand more could be found in private business.
Indeed, the Fraud Review Report concluded that most fraud was already investigated by civilians and recommended the development of “accredited investigators” who would increase the long-term pool of investigators, not to mention co-operation between the police and other organisations.
The difficulty with having a large number of different counter fraud teams working within Government is ensuring that this work is undertaken to a consistent standard by individuals with the skills and experience needed. The Cabinet Office has decided to address this issue by creating a Government counter fraud profession which will be publicly launched in the latter half of 2018. The new community created by this professionalisation process is designed to give those working within counter fraud both credibility and recognition for their specialist skills and help them to build their career.
The Cabinet Office, therefore, seeks to raise the profile of counter fraud activity within central Government, ensure that this is delivered in a transparent way to predetermined standards against which their performance can be judged and empower counter fraud specialists by making them a part of an active counter fraud community.
It’s envisaged that this community will provide its members with professional updates, greater skill levels (and therefore credibility) and an increased level of control over their careers by offering the opportunity to acquire a range of pre-determined skills and competencies.
Nine core disciplines
This new profession is based around nine core disciplines: risk assessment, fraud measurement, the development of a counter fraud culture, fraud prevention and deterrence, fraud detection, the use of data analytics, intelligence management, fraud investigations and sanctions and redress.
These disciplines set out the knowledge, skills and experience that are needed to deliver an effective counter fraud response at four key levels: foundation, developing, proficient and expert. The intention is that an individual will specialise in one or perhaps two of these core disciplines and subsequently move between the different levels as their career develops.
There’s also a tenth core discipline for those leading counter fraud teams and developing counter fraud strategies.
Counter fraud professionals will be registered on a professional skills platform giving them access to all current standards and guidance, a self-evaluation tool to allow members to plan, log and track their own personal development and access to information on those in other teams with specialist skills, such as computer forensics, learned to the requisite standards.
The Cabinet Office recognises that the development and roll-out of this profession must build on the skills and experience that currently exists and avoid a situation where perfectly competent staff who have built up a wide variety of skills over a long period of time lose the ability to continue to practice. Therefore, in an initial transition phase, counter fraud staff who wish to enter the profession will be able to provide a portfolio of evidence which justifies granting them professional status. Each portfolio submitted will be subject to review and approval prior to admittance to maintain standards.
However, once the transition phase has ended, entry to the profession will be through some form of examination and properly recorded examples of practical experience.
Two membership routes will be established. During the transitional phase, organisations can put forward entire teams for registration (this will be known as collective membership) or specific counter fraud specialists (badged as individual membership). For the collective membership applications there will be an assessment of the team’s learning environment, rather than the assessment of individual evidence portfolios and a professional discussion to which those applying for individual membership will be subject.
Following the end of the transitional phase, the only entrance mechanism will be for new entrants to the profession who’ll be registered on an individual basis via a knowledge check and evidence portfolio.
Collaborative process in play
The development of this profession, which has been underway for the last three years, represents the culmination of a large amount of work by the Cabinet Office in collaboration with industry professionals, academics, practitioner groups and central Government counter fraud champions.
During this collaborative process, it became clear that, in addition to members, the profession needed to deliver positive outcomes for employers. These are thought to be access to a single, central and shared body of knowledge and better qualified, skilled and experienced staff, in addition to improved outcomes in terms of better quality counter fraud work which will lead to less fraud, cheaper and more effective investigations and, where fraud has been proven, improved levels of cash and asset recovery.
This professionalisation initiative represents a significant step forward in the management and delivery of counter fraud services in relation to central Government. However, it faces a number of issues if its roll-out is to be a longer term success. First and foremost is longer term sustainability. As the counter fraud profession develops, consideration will be required by those in Government as to how the profession will be resourced, the tools members will need to enable them to deliver to the pre-set standards and the benefits to be offered to individuals that will encourage them to remain within the profession.
Only two of the ten core standards currently have a professionalisation pathway developed for them. These are investigations and intelligence. Therefore, membership at this point in time is only open to those working in these two specialisms. The reason for this is that they cover approximately 98% of existing counter fraud staff. Personnel working in other parts of counter fraud, such as fraud prevention and fraud detection, will need to wait until standards and competencies in these areas have been drafted before they can apply for membership.
Making initial membership selective in this way runs the risk of demoralising staff working in these other disciplines. Communications surrounding the launch of the profession will need to address this issue from the outset and provide a specific and guaranteed timeline by which these staff will be able to apply to enter the profession.
Furthermore, launching the profession around just two of the nine core disciplines risks extending the transition timetable well into the future, which may have longer term implications for the standards of those admitted. A solution to this problem is to treat different specialists as sub-sets of the professional population and give each their own transitional timetable.
Another issue is the treatment of each of the nine specialisms as independent areas. While it’s true that staff in larger organisations work in specific counter fraud disciplines, such as prevention, detection and investigation, this isn’t necessarily the case for those working in smaller organisations who often work across many of the nine core disciplines. It’s not clear how the profession will work for them.
For example, if an individual is working across six of the core disciplines, the scale of the knowledge required may mean that they are only able to meet the competencies set for the developing and foundation levels. Given that the professionalisation register is to record every competency met in each of the four levels, it’s possible that working for a smaller organisation – where defined proficiency standards have not been acquired due to workload – would put these members of staff at a disadvantage when seeking to build their career by changing employers.
The decision to register each competency an individual has achieved is useful in the sense that potential employers will be able to access the register and establish exactly which competencies an applicant has, which will deal with a current problem whereby currently employers have little idea of whether or not they are hiring someone with the requisite skills. However, the drawback with the proposal is that this may be expensive to create and maintain. It may also be difficult to keep up-to-date when the thousands who currently work in UK central Government counter fraud teams enter the profession and acquire new competencies.
Finally, much remains to be done if the profession is to be recognised as such by other professional groups. While the Cabinet Office has drafted a Code of Ethics to complement its technical standards, there are at present no procedures in place to regulate how members behave and perform their duties and discipline those whose behaviour or work falls below expected standards.
The Cabinet Office has agreed that conduct issues will be dealt with by local management and escalated if necessary to those managing the profession. In the absence of an independent regulatory mechanism, it’s unclear how the Cabinet Office will be able to implement accepted working practices uniformly or create a professional identity, both of which represent essential elements of a profession.
To conclude, the professionalisation process is to be welcomed and represents a pragmatic and necessary improvement to the delivery of counter fraud services. However, much needs to be done to deal with emerging issues and build the remaining structure required if counter fraud is to be universally recognised in the UK as a profession.
Dr Mike Gilbert ACFS MSyI is a Counter Fraud Consultant and Director of Cillion Consulting