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Four strategic pillars

Published on 29 November 2023


Strategic Objective

Understand how fraud bribery and corruption adapt and impacts the NHS.

Why it is important?

The more we know about fraud in the NHS the more effective our response will be. We will develop and manage a range of processes, tools, knowledge, and expertise to ensure we have a comprehensive understanding of the threat.

Strategic actions years 1 to 3

Produce a comprehensive assessment of the risk, threat, and impact of fraud against the NHS together with recommendations to respond to them.

Deliver a comprehensive intelligence gathering and dissemination function to support all parts of the NHS to evaluate, initiate and deliver an appropriate and effective operational response to fraud.

Develop and maintain an enterprise level Fraud Risk Assessment (FRA) which proactively identifies, describes, and assesses the fraud risks and mitigating controls across the NHS.

grow our collaboration on FRA with the NHS Counter Fraud Authority and other UK NHS fraud organisations.

direct our data analytical function to find fraud and measure its prevalence.

End State 2026

  • An improved intelligence picture with increased confidence in the assessment of fraud affecting the NHS.
  • Timely dissemination of actionable intelligence.
  • An increased quantity of intelligence and allegations received by CFS.
  • More comprehensive suite of fraud risk assessments conducted and evaluated by CFS.
  • Effective horizon scanning for new and emerging risks across the NHS.

Data will support our understanding and drive key decision making. This will underpin our response, prevention, and assurance across the NHS.


Strategic Objective

We will ensure the NHS is equipped to take proactive action to prevent future losses from occurring.

Why is it important?

Fraud prevention is a critical factor in reducing organisational vulnerability to fraud. As a default position we will seek to identify and remove the enablers of fraud. We will achieve this through raising awareness and understanding of fraud, greater use of fraud impact assessments and influencing organisational level changes designed to drive down vulnerability.

Strategic actions years 1 to 3:

  • Lead and promote a fraud prevention and deterrence programme for the NHS.
  • Proactively promote a counter fraud culture within the NHS that develops fraud awareness and understanding across all areas of spend.
  • Develop and share good practice and lessons learned from all aspects of counter fraud activity in the NHS.
  • Support the delivery of fraud impact assessments across areas of NHS expenditure and promoting the fraud-proofing of all NHS systems and processes.
  • The innovative use of data to support the opportunities for prevention across key areas of business by designing, developing, and delivering proactive analysis.
  • Exploit multiple media channels to promote fraud awareness and deterrence messaging and advice.

End State 2026

  • Major new systems and processes adopted by the NHS are routinely fraud risk assessed in design (initial fraud impact assessments).
  • Emerging risks are identified and responded to collaboratively across the sector through effective horizon scanning and fraud risk assessments.
  • Operational intelligence and lessons learned reviews inform a programme of fraud prevention action (systems weakness).
  • Data analysis is used to direct/inform prevention activity across the sector.
  • Focused communications campaigns and the associated impact is realised.
  • Promotion of impactful counter fraud activity across the system as a means of revenue protection and recommendations widely adopted across the system.
  • Value of counter fraud activity more widely recognised and improved awareness and confidence in our counter fraud function.


Strategic objective

When we know that fraud has occurred, we are equipped to respond.

Why is it important?

Timely information and intelligence are disseminated for action. Our response is increasingly proactive and led by our understanding of the threat. Enforcement resources are suitably trained and configured to maximise the impact of investigation.

Strategic Actions years 1 to 3

  • Use our understanding of fraud to develop a control strategy, agree priorities, develop action plans, manage strategic and tactical tasking of resources and close intelligence gaps.
  • Through developing a response to allegations of fraud we will prioritise prevention and disruption to reduce harm and loss.
  • We will conduct and support, criminal, financial and civil investigations to establish whether a) fraud, bribery or corruption has occurred b) determine or influence appropriate action/sanctions and c) initiate recovery of funds lost.
  • We will provide support and advice to health boards to respond to fraud.
  • We will develop our analytical capability to provide insight that presents patterns in data indicative of fraud.

End State 2026

  • Action is initiated to meet intelligence requirements and performance targets are set.
  • Prevention and disruption activity are routinely initiated, recorded, monitored, and used.
  • Investigative activity and resulting outcomes are recorded.
  • Our counter fraud professionals have awareness of and access to appropriate professional development and training.
  • A reduced vulnerability to fraud.
  • Our response is quantified as a demonstration of impact.
  • Data modelling and analytical learning will support the formulation of ‘fraud flags’ in data which are indicative of fraud.
  • All investigation, risk assessment and prevention activity are comprehensively recorded on our fraud management system.


Strategic objective

We can assure our key partners, stakeholders, service users and the public that the overall response to fraud across NHS Scotland is robust.

Why is it important?

The public expects health boards to mitigate effectively against the risk of fraud. Using our technical expertise, impartiality, and independence we will lead on providing assurance through standard setting, legislative levers, providing a sound basis for statements on loss and being the organisational voice on matters of fraud.

Strategic Actions years 1 to 3

  • Support health boards to achieve the NHS Scotland Counter Fraud Standard.
  • Provide a robust evidence base demonstrating the positive impact of the NHS counter fraud response.
  • Provide and manage a case management system for the NHS to ensure all counter fraud activity and outcomes are captured.
  • Lead the health boards to drive measurable improvements in the counter fraud response through collaborative partnerships.
  • Protect NHS funds by reducing vulnerability to fraud and reducing fraud losses.
  • Continued development of the NHS capability to counter fraud.

End State 2026

  • Achievement of the NHS Scotland Counter Fraud Standard has increased across health boards.
  • Demonstrating a return on the investment in CFS.
  • Performance methodology delivering demonstrable return on investment is established.
  • Increased volume and quality of information and intelligence entered onto our case management system.
  • UK-wide benchmarking informs our approach to continuous improvement.

Return to the NHSScotland Counter Fraud Strategy