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The Counter Fraud Standard

Published on 29 July 2022

The NHS Scotland Counter Fraud Standard is a quality assurance approach adopted across much of the public sector.

The Standard contains twelve components, against which organisations can assess how effectively they tackle fraud, bribery and corruption.

Component 1 - Accountable Individual and Roles

Each NHS Scotland health board has an accountable individual. Usually this is the Director of Finance.

Their role is to:

  • Assure the executive board of the quality and effectiveness of counter fraud work
  • Provide CFS with details of the Fraud Liaison Officer, the Counter Fraud Champion and the Audit and Risk Committee Chair
  • Ensure that the health board has sufficient management and controls in place to counter fraud, bribery and corruption
  • Ensure that fraud, bribery and corruption awareness is promoted within the health board

Component 2 - The Counter Fraud, Bribery and Corruption Strategy

The current NHS Scotland Counter Fraud Strategy was launched in 2008. It provides a broad outline of our approach to tackling fraud. From April 2023, a new strategy will state how we intend to use our resources over the next three years to fight fraud, bribery and corruption. The strategy will then be refreshed every three years.

The counter fraud strategy is endorsed every three years through the Partnership Agreement between CFS and each health board. This agreement defines the services CFS provides to support health boards in countering fraud, bribery and corruption.

Component 3 - The Fraud, Bribery and Corruption Risk Assessment

Health Boards should assess risks within the organisation. These are routine ongoing processes, not standalone exercises. To do this, CFS will undertake fraud, bribery and corruption risk assessments.

There are three types of risk assessment:

  • High level risk assessment - that gives an overview of the main risks and challenges facing the Board.
  • Intermediate risk assessment - within areas of functions, programmes or spend.
  • Detailed risk assessments - covering individual business units, projects or programmes.

Component 4 - The Fraud Policy and Response Plan

Many health boards have a specific fraud policy and a response plan that aligns to the NHS Scotland Counter Fraud Strategy.

If the health board does not have a policy or response plan, the Partnership Agreement contains a protocol. This protocol is a model policy for employees to refer to.

Component 5 - The Fraud Annual Action Plan

The fraud annual action plan contains the health board’s objectives and service delivery goals. It will also lay out the resources committed to participate in fraud, bribery and corruption risk assessments.

The health board audit committee should agree the plan.

Component 6 - Outcome Based Metrics

All outcomes from the work undertaken to counter fraud, bribery and corruption are measured and included in the annual fraud standard statement. These include, but are not limited to:

  • The incidence of fraud and the number of allegations reported
  • The value of identified loss to fraud and error
  • The value of all recoveries and fraud that has been prevented
  • The number of criminal and disciplinary sanctions.
  • Staff engagement with regards to fraud awareness, training

National benchmarking data is available to allow each health board to set realistic targets for the following year. These are included in the fraud annual action plan.

Component 7 - Reporting Routes

Each health board should have well established reporting routes for employees, contractors or members of the public to report fraud, bribery and corruption. CFS is responsible for recording allegations of fraud in the NHS Scotland fraud case management system.

There are three ways to report fraud:

  • Employees or contractors can contact the health board's Fraud Liaison Officer (FLO). The FLO acts as a Laison between CFS and the health board. Their contact details can be found on the intranet site and should be widely advertised.
  • Anyone can report fraud by calling the fraud hotline (08000 15 16 28)
  • The fraud reporting route via the CFS website.

The fraud hotline and reporting route via the website are hosted and powered by Crimestoppers. You can find out more about Crimestoppers on their website

Component 8 - Reporting Identified Losses

It is important to report all allegations of fraud, bribery and corruption to CFS as soon as possible.

CFS records each allegation in NHS Scotland fraud case management system. This system stores all investigation material and outcomes.

CFS will work with the health board to review all outcomes. This helps to develop an understanding of local and national high-risk areas of fraud, bribery and corruption.

Component 9 - Access to Trained Investigators

CFS will provide an annual statement of competency to each health board. The health board can use this to show that they meet component 9 of the NHS Scotland Counter Fraud Standard.

The annual statement shows to what extent, CFS' counter fraud specialists are “appropriately trained”. It also declares that CFS has the knowledge and skills to “conduct the full range of counter fraud, bribery and corruption work on the board's behalf”.

Component 10 - Undertake Detection Activities

CFS supports each NHS Scotland health board to detect fraud and to assess the outcomes from local and national fraud, bribery and corruption activities. Where fraud is detected, CFS will investigate and take any appropriate action. If system weaknesses are identified, CFS will offer to undertake prevention work to reduce loss in that area.

Whilst evaluating these activities, CFS and the health board will agree on areas requiring improvement in the following year. In deciding these areas, CFS will look at the information available from the previous year, such as:

  • Internal and external audit reports
  • Fraud risk assessment
  • Outcomes from investigations
  • Loss measurement exercises.

Component 11 - Access to and Completion of Training

CFS offers a suite of training products and events to each health board covering a variety of risk areas.

This training helps to develop an understanding of the problem area, its solutions and promotes a counter fraud culture among employees and contractors.

Training products are designed for the risks that exist in specific areas of the health service or to be relevant to the audience.

CFS will work with the health board to measure the uptake and effectiveness of training and develop a best practice approach.

Component 12 - Policies and Registers for Gifts and Hospitality and Conflicts of Interest

Each health board should have a 'Managing Conflicts of Interest' policy. This includes registers for gifts and hospitality. The Policy should refer to the prevention of fraud, bribery and corruption. It should also stress the relevance of terms and definitions in the Bribery Act 2010.

The health board should demonstrate that the policy and registers are communicated to employees and implemented.