Policy paper

DHSC counter-fraud strategy: 2023 to 2026

Published 8 June 2023

Applies to England

Foreword

Every pound lost to fraudsters is a pound lost from patient care. Over the course of the Department of Health and Social Care’s (DHSC) last counter fraud strategy: 2020 to 2023, the NHS Counter Fraud Authority (NHSCFA), working with partners, met its overall 3-year target of preventing, detecting and recovering £400 million of fraud. This was a vast improvement from the previous period total of £151 million and is evidence of the great strides being taken in this area.

However, the methods and means of attack from fraudsters are constantly changing and I am determined that we not only keep pace but anticipate their actions. No level of fraud is acceptable, and DHSC and its partners will do even more in response to this threat, with an ambitious new 3-year strategy target of £500 million.

NHSCFA estimates that the NHS in England is vulnerable to £1.198 billion of fraud each year. This DHSC counter-fraud strategy is a key element in the government’s response. It provides a co-ordinated activity programme, which aims to tackle the underlying factors that allow fraud to be committed by:

• improving the building and sharing of counter-fraud knowledge

• tackling the most harmful threats

• disrupting and punishing fraudsters

• enhancing our long-term capability to prevent fraud

To do this, we must improve the use of data and artificial intelligence in the fight against fraud – and we will therefore significantly increase investment in our data analytics capabilities over the next 3 years.

We will protect valuable taxpayers’ money at every opportunity. This will ensure greater confidence in not only the NHS, but also the wider services government provides. Such confidence is essential for investment, spending and prosperity in our communities across England.

I am committed to strong governance at the heart of all spending with fraud prevention and detection being understood and prioritised from beginning to end. Only by doing that can we protect the NHS now and for future generations to come.

I commend this strategy to you as a much-needed development in the fight against fraud that builds on the government’s existing successes in this area. Together we can reduce the harm fraud causes us all, and strengthen our communities and economy.

Lord Markham CBE

Parliamentary Under Secretary of State, Department of Health and Social Care

The problem

The nature and challenge of fraud

Fraud is the most commonly experienced crime in the UK and poses a significant challenge. The very nature of fraud changes over time, and evolves to take account of new opportunities and different methodologies. Crime groups attack the UK public sector and government departments, including the NHS, and billions are estimated to be lost to tax and benefit fraud each year.

Healthcare expenditure in 2021 is estimated at £277 billion, which is an increase in nominal terms of 7.4% on spending in 2020. NHSCFA has assessed that, in the context of a 2021 to 2022 NHS budget in England of almost £150.614 billion, the NHS is vulnerable to fraud, bribery and corruption to an estimated £1.198 billion.

The challenge for the government in protecting the public sector from fraud remains significant, with increasing pressure to support those who may be struggling, be it for economic or health reasons.

It remains vital that we balance quickly getting support and healthcare to those who need it, while also doing what is required to protect taxpayers’ money.

Continually reviewing and assessing risk

We regularly review and assess our risk areas across the healthcare system, with discussion through our cross-system Counter Fraud Board, as set out in ‘Annex A: delivery roles’ below. Drawing on this, and the work of our partners – in particular the annual NHSCFA Strategic Intelligence Assessment – the particular risk areas we propose to focus on over the next 3 years include:

• procurement and commissioning fraud – this includes securing pre-tender activity, the commissioning process, post-tender activity and fraud associated with bank transfer payments. We aim to ensure that the full range of fraud prevention and detection measures are in place across the entire process
• prevention policies – prevention is always better than cure and we plan to further strengthen fraud prevention policies, particularly in the sphere of grant awards and human resources
• primary care – we plan to further secure the gateway to NHS care from fraud by working with GPs, dental contractors and pharmaceutical contractors to tackle not only contractual fraud but fraud relating to inappropriate claims and reimbursements

This list is not exhaustive, and DHSC will remain responsive, agile and alert to fraud risks, ensuring it is able to swiftly pivot counter-fraud resources to where they are needed most as new threats emerge. The target end state is for the health sector to fully understand its fraud risks, and have an acceptable level of risk with adequate controls and mitigations in place that are proportionate in all instances.

Data analysis and artificial intelligence (AI)

Through the life of this strategy and beyond, we will be data driven and use this as an integral and core tool to inform our work.

To that end, we will:

• increase investment in the NHS’s data analytics capabilities
• support NHSCFA to establish a new operating methodology, which will revolutionise the response to fraud by allowing NHSCFA to equip arm’s length bodies (ALBs) and partners to undertake both real-time and reactive monitoring of data to identify and respond to suspicious activity

Generating opportunities to disrupt fraudulent activity and allow DHSC to make policy changes that reduce or remove the likelihood of fraud occurring will be central to this work.

DHSC will also work in partnership with the Public Sector Fraud Authority (PSFA) to use the latest cross-government data-driven initiatives to prevent and detect fraud.

Our response

Fraud is a hidden crime and to fight it, you have to find it. There is no one solution. DHSC will continue to address fraud with a holistic response incorporating detection, prevention and redress, underpinned by a strong understanding of risk.

DHSC will apply this response across the areas for which it is responsible, including both the NHS and social care sectors. It will also work in close co-operation, and with a spirit of collaboration, with its agencies, ALBs and other business partners.

You can read more about the organisations that make up this wider health group in ‘Annex A: delivery partners’ below.

Our vision

Our vision remains clear and reflects that from the previous strategy:

A system-wide approach to tackling fraud that protects taxpayers’ money for better patient care.

Overall savings target

Overall counter-fraud savings for the life of this strategy, encompassing prevented fraud, detected fraud and recovered funds, will be £500 million.

Health fraud risks and response

Clearly this is bigger than the remit of the heath sector alone. DHSC will continue to align its activity with both PSFA and other law enforcement agencies to form a strong and resilient response. The role of the core department remains one of co-ordination, education, assurance, investigation and enforcement. Senior management will drive the work on counter fraud, supported by the sharing of skills and information across teams to recognise risks and design out or manage those risks.

Fraud will continue to evolve and target different areas. The departmental response will also change to both tackle existing crime, and identify new threats and prevent fraud occurring in the first place wherever possible.

We will work in partnership with all parts of DHSC, its agencies and ALBs to identify and tackle key fraud risks.

Delivery

DHSC will set the direction and pace of the health group’s counter-fraud work through the Counter Fraud Board and ensure it is integrated with the wider aims and objectives of the overall DHSC strategy. This work will also form part of the annual DHSC governance statement.

Relevant DHSC policy units will support delivery of actions against each fraud risk. We will demonstrate and encourage the principles of:

• responsibility – fraud is the responsibility of everyone. Therefore, all work should have consideration for fraud risks, with ownership taken for finding and minimising risk, and managing residual risk. Fraud risk assessment training will be available and completed alongside mandatory counter-fraud training

• knowledge – everyone should have the knowledge and confidence to take basic steps, commensurate to the level of risk to which they may be exposed in their role, to minimise risk. This includes considering deterrent, preventative, detective and corrective measures where reasonable and appropriate

• taking the right action – using the advice, tools and expertise available, be able to identify action against fraud at any stage of the workstream lifecycle

• sharing resources – offering help, advice and guidance. Be willing to share experience, knowledge and data to help others, especially those who may be working in similar work areas or facing similar delivery risks

‘Annex A: delivery roles’ to this strategy sets out the roles of DHSC, its ALBs, agencies and companies owned by the Secretary of State for Health and Social Care.

Objectives

The objectives in this strategy aim to build on or continue the work started in the previous term (‘Annex B: achievements from last strategy’ sets out more details of what has already been achieved).

We want to evolve from our last strategy, as well as rising to the new challenges that we face, not only from coronavirus (COVID-19), but the growing development of new technologies, ways of working and means of support offered by the health sector.

There are 4 key themes, building on the solid foundations we have from the previous strategy, with the aim of allowing us to be increasingly proactive, adaptable, collaborative and intelligent.

1. Proactivity and prevention

Counter fraud will be part of day-to-day activity.

Everyone will understand fraud and its impacts, with responsibility taken at the right level.

Preventative action will be taken as soon as possible to minimise risk.

To achieve our objectives, we will:

• ensure staff of all levels in both the core department and the wider health family understand fraud and how it could impact their work, and their roles and responsibilities to prevent it

• work with policy teams to support the use of fraud risk assessments (FRAs) and initial fraud impact assessments (IFIAs), ensuring senior responsible officers own fraud risks

• make sure teams and delivery partners are able to identify and take action to prevent and detect fraud at the right level as part of business as usual, ensuring timely and knowledgeable steps are taken to prevent fraud or reduce residual risks

• share identified risks with relevant partners and stakeholders to enable co-ordinated action to eliminate or otherwise mitigate the risk across health and wider government

Measuring success

To demonstrate continuous improvement, outcomes and measures will include:

• increasing the number of FRAs, including IFIAs, submitted to DHSC Anti-Fraud Unit (AFU) by 50% – particularly from work areas not previously engaged

• establishing a new baseline measure for amount of fraud prevented and use this across all key organisations by the end of year 3

• ensuring 100% of FRAs submitted for review will have sign-off by a senior responsible officer

• maintaining a library of common fraud risks – linked to the Strategic Intelligence Assessment, intelligence and past experience – to share with policy teams

2. Using digital and data analytics

We will:

• use new technology to improve the reach, power and savings of our counter-fraud operations
• use and share available data to identify fraud and take appropriate action to minimise loss, including through the National Fraud Initiative
• identify new and existing data sets to assess the impact of counter-fraud activity

To achieve our objectives, we will:

• wherever possible, use new technology to improve and enhance our counter-fraud work. Technological solutions will become an integral part of our work to prevent and detect fraud across the health group

• use data sets to highlight outliers in data and proactively investigate the causes. For example, we will increasingly work with our delivery partners to identify outliers and anomalies in large data sets worthy of further investigation

• increase data sharing between ALBs and departments, in line with data-sharing and protection legislation, to ensure appropriate data is shared quickly and securely to reduce potential loss. For example, subject to Parliamentary time, the PSFA will work to develop or amend legislation and, where relevant or useful, we will seek to be included in any changes they explore

• continue to explore ways to quantify the impact of fraud prevention work by gathering information on prevented, detected and recovered fraud losses, where they occur, from all available sources to gauge the impact of both fraud and our counter-fraud actions

Measuring success

To demonstrate continuous improvement, outcomes and measures will include:

• ensuring new technology taken on by DHSC, where relevant, will be able to demonstrate through a monetary value its impact in countering fraud

• following receipt of reports on frauds identified as a result of data analysis, establishing a process in year one where teams can carry out the assessment and report risks. This will establish a baseline

• developing our methodology, leading to a better indication of the impact of counter-fraud measures in financial terms

• seeking for DHSC to be included in and, if possible, influence any relevant data-sharing legislation, memoranda of understanding (MoUs) or other agreements

3. Collaboration and co-ordination

We will:

• build contacts and relationships across teams, using skills, knowledge and experience wherever it can be found
• learn from others across government
• act as a beacon for counter-fraud work across the health sector, providing expertise and support for help within and outside DHSC

To achieve our objectives, we will:

• continue our strong relationship with PSFA to help lead and influence wider counter-fraud policy. Everyone in health will work towards meeting the functional standards, ensuring a co-ordinated and consistent cross-government response

• develop and mature enterprise and thematic FRAs to identify the risks, actions and owners, and drive counter-fraud activity across all teams

• work beyond health to learn and share lessons to accelerate our knowledge and insight

• create a departmental network that enables access to support, guidance and advice from similar teams or specialists

• explore new sources to gather and share intelligence or risks with relevant teams

Measuring success

To demonstrate continuous improvement, outcomes and measures will include:

• ensuring all health ALBs are fully compliant against Government Functional Standard GovS 013: Counter Fraud (GCFFS)

• introducing a fraud risk assessment for all levels – ‘enterprise’, ‘thematic’ and ‘full’ – where appropriate. We will have a thematic FRA as a minimum but not limited to 3 areas: human resources, grants and procurement

• continuing to be a valued partner and contributor to cross-government assurance groups

• creating a network of ‘fraud champions’, who are not fraud experts, in at least the 3 key areas of human resources, grants and procurement

• increasing intelligence alerts issued by DHSC by 50%

4. Response and enforcement

We will:

• improve DHSC’s response to fraud by re-enforcing processes and building confidence in reporting fraud
• investigate instances of fraud and bring those guilty to justice
• introduce a range of options beyond prosecution to recover funds, where possible, to be fed back into the health system, including seeking civil redress based on the balance of probabilities

To achieve our objectives, we will:

• educate colleagues in identifying fraud, ensuring they feel confident to report suspected fraud early

• continue to use a range of options to deal with those who commit fraud, allowing proportionate and cost-effective action to be taken

• look to increase the amount of money saved by increasing our prevented, detected and recovered amounts across the core department

• with our partners across government, continue to look at options for widening the scope and nature of our legal powers where proportionate and appropriate

Measuring success

To demonstrate continuous improvement, outcomes and measures will include:

• increasing internal fraud reports from within DHSC’s core department by 20%

• excepting urgent referrals, ensuring 85% of all referrals received by DHSC AFU receive an initial assessment within 10 working days and a disposal decision within 30 working days

• increasing the amount of prevented, detected and recovered fraud by 10%

Our values and principles

This response is underpinned by the following 5 factors.

1. Principles

There are 5 internationally recognised principles for public sector fraud and our counter-fraud work is predicated by these.

Figure 1: 5 principles of fraud and corruption

Figure 1 above shows the 5 principles of fraud and corruption: there is always going to be fraud, finding fraud is a good thing, there is no one solution, fraud and corruption are ever-changing, and prevention is the most effective way to address fraud and corruption.

There is always going to be fraud

It is a fact that some individuals will look to make gains where there is opportunity, and organisations need robust processes in place to prevent, detect and respond to fraud and corruption.

Finding fraud is a good thing

If you do not find fraud, you cannot fight it. This requires a change in perspective, so the identification of fraud is viewed as a positive and proactive achievement.

There is no one solution

Addressing fraud needs a holistic response incorporating detection, prevention, enforcement and redress, underpinned by a strong understanding of risk. It also requires co-operation between organisations under a spirit of collaboration.

Fraud and corruption are ever-changing

Fraud, and counter-fraud practices, evolve very quickly, and organisations must be agile and change their approach to deal with these evolutions.

Prevention is the most effective way to address fraud and corruption

Preventing fraud through effective counter-fraud practices reduces the loss and reputational damage. It also requires fewer resources than an approach focused on detection and recovery.

2. Values

While delivering the principles, we will follow the 5 values outlined by PSFA. Following these will help us in delivering a consistent approach across government. These values are:

• expertise – we will ensure that our expertise drives decision-making, building our reputation as authoritative and credible experts in our field
• innovation – we will continue to develop to meet the ever-evolving fraud threat through creativity and agility
• collaboration – we will work in close alliance with partners and across all business areas to achieve our collective goals and maximise our strengths
• integrity – we are professional, committed, honest and transparent. Integrity underpins every aspect of our work
• respect – we respect each other and celebrate diversity, valuing different ways of working to bring inclusion to the heart of our working practices

There is still much more that needs to be done to tackle the spectre of fraud across the NHS in England. However, everything that is set out in this strategy is achievable and we should not lose sight of the significant progress that has already been made.

3. Restrictions

We must also acknowledge that fraudsters have the motivation, skills and budget, meaning they are able to adapt rapidly to exploit weaknesses in any process or policy. They can often develop and change quicker than larger organisations. Therefore, it is important that we focus on prevention rather than cure.

There is a large breadth of work carried out across DHSC that requires specialist skills and knowledge not held by DHSC AFU. We will manage this by ensuring everyone knows their responsibility to contribute to counter-fraud activity, and is ready and able to do so.

We will also ensure that effective enforcement measures are in place to react to any fraud. The counter-fraud budget is just a small part of the overall health budget and there is more strain than ever on resources, so it is important that we achieve the best return on investment as possible.

Additionally, we will ensure that this strategy aligns and links with DHSC’s fraud, bribery and corruption policy and response plan.

4. Ambitions

The increase in funding given to DHSC during the COVID-19 pandemic has provided services to help those in need. We have limited resources within to build and develop tools that can keep pace with determined and sophisticated fraudsters.

This means we need to focus on identifying priority areas, including encouraging more widespread and early action, by working with those outside the counter-fraud specialism. This would include:

• sharing knowledge and experience
• increasing awareness
• encouraging responsibility

By building knowledge and understanding in every corner and at every level of DHSC, we will be able to identify risks and close the gaps as much as possible before breaches occur.

This will be supplemented by developing and analysing data to build risk analysis and detection capability in a wide range of areas.

5. Other strategies

Part of thinking differently is ensuring we work in a co-ordinated way, presenting a strong and consistent defence against fraud. We continue to work closely with the PSFA, other government departments and our ALBs, finding strength in numbers and sharing knowledge and resources. This will include improving how we share best practice and identify new and innovative ideas to tackle fraud.

Conclusion

This strategy is the beginning, not the end, of a continuous process to ensure that we bear down on fraud in the healthcare system in England. Much has been achieved during the life of the previous strategy. Healthcare fraud currently equates to less than 1% of the NHS budget but is still an unacceptable amount.

We must be agile, and continue to evolve and develop our work. The methods and means of attack from fraudsters are constantly changing and we must not only keep pace but anticipate the actions of fraudsters. To that end, this strategy clearly sets out how we will deliver a step change in counter-fraud work and make ever greater use of new technology to tackle this problem.

As set out in ‘The problem’ above, we will be intelligence-led and focus on where our efforts can have the greatest effect. In particular, we will consider:

• procurement and commissioning fraud
• prevention policies
• primary care

This list is not exhaustive, and DHSC will remain responsive, agile and alert to fraud risks, ensuring it is able to swiftly pivot counter-fraud resources to where they are needed most as new threats emerge.

Next steps

We will regularly review and assess our risk areas across the healthcare system, with discussion through our cross-system partners. Additionally, we will continually monitor progress both in terms of savings and achievement of targets.

Where new fraud threats emerge, we will take all necessary steps to address them and, ever more frequently, we will be ahead of the fraudster – anticipating their actions, identifying the weaknesses and taking the strongest possible actions to protect the NHS.

Through this, we will deliver a system-wide approach to tackling fraud that protects taxpayers’ money for better patient care.

Annex A: delivery roles

DHSC Anti-Fraud Unit (AFU)

DHSC AFU provides support and co-ordination in the development and delivery of counter-fraud work, and holds to account those responsible for actions. It has a team of investigators who are members of the government Counter Fraud Profession. Their role is to investigate allegations of fraud and corruption in DHSC, its ALBs and possibly companies owned by the Secretary of State for Health and Social Care, where the health service is not affected.

DHSC AFU also seeks to ensure fraud prevention is built in to DHSC policy development at the earliest possible stage and promotes awareness of fraud risks across the health group. DHSC AFU also has representation at the Government Counter Fraud Function and is on the board of the Government Counter Fraud Profession.

As part of the wider cross-government counter-fraud agenda, DHSC AFU engages with PSFA and other government departments at a strategic level to prevent and deter fraud. DHSC AFU is also the departmental sponsor team for NHSCFA, the organisation that tackles fraud, bribery and corruption in the NHS.

NHS Counter Fraud Authority (NHSCFA)

NHSCFA is the single expert intelligence-led organisation providing centralised intelligence and investigation for tackling fraud, bribery and corruption in the NHS in England.

NHSCFA acts as a repository for all information and intelligence related to fraud in the NHS and the wider health group, and has oversight of and monitors counter-fraud work across the NHS. It will provide strategic and tactical solutions to identified fraud risks, counter-fraud standards and assessment of performance through the provision of comparative data. Working together with our stakeholders, NHSCFA will drive improvement to counter-fraud work that is undertaken across the NHS.

Since NHSCFA was established, and through collaborative actions, £360.8 million savings were made between 2017 to 2018 and 2019 to 2020 across a range of preventative and enforcement activity.

NHSCFA will work collaboratively across the NHS, DHSC and other relevant organisations to obtain better information and intelligence on the types of fraud the health group is exposed to, and assist in putting in place effective measures to better prevent, deter and investigate fraud. NHSCFA will also be better equipped to provide valuable information to the health group on weaknesses and risks that can expose us to serious financial loss.

Arm’s length bodies (ALBs)

In addition to the counter-fraud work undertaken by NHSCFA and PSFA, other bodies at a national level such as NHS England (NHSE), the NHS Business Services Authority (NHSBSA) and the UK Health Security Agency (UKHSA) routinely undertake activity to tackle fraud.

All health ALBs adopted the GCFFS, submitting evidence to PSFA for review by September 2019. This compared positively with a 78% take-up across government.

Since September 2021, it has been mandatory for all government departments and their ALBs to put in place a plan to comply with the GCFFS and it was expected that the standards should be embedded in organisations’ business plans from 2022 to 2023 onwards.

PSFA is developing a continuous improvement framework to provide consistent, comparable management information to support functional assurance and continuous improvement. DHSC AFU is actively engaged to inform and influence the development of the new framework and has formed the Health Peer Review Group in readiness for this model.

We continue to work with health ALBs to address areas for improvement and drive year-on-year improvements in compliance against the current standard, which has already seen an increase since starting in May 2022.

Key national health ALBs have their own counter-fraud teams responsible for tackling fraud in their organisations. DHSC will continuously work with them to identify opportunities for further alignment of counter-fraud resources to realise greater efficiencies or savings.

Government companies owned by the Secretary of State for Health and Social Care

These organisations, as limited companies, are regulated by the Companies Act 2006.

While they are not currently within scope of GCFFS, we are providing proactive advice and support to improve their counter-fraud capability, using the functional standards as a baseline.

Counter Fraud Board

Chaired by DHSC, the aim of the Counter Fraud Board is to bring together key national partners across health and the NHS, and assure urgency, pace and co-ordination in delivery of the counter-fraud agenda.

The board ensures a collaborative approach to its strategic oversight of DHSC counter-fraud response, including the work of NHSCFA, NHSBSA, NHSE and UKHSA, ensuring it supports delivery of the DHSC counter-fraud strategy and that activity is co-ordinated to maximise delivery against targets.

Counter Fraud Liaison Group

Chaired by DHSC AFU, this group brings together counter-fraud leads from each of DHSC’s ALBs and a representative from the companies owned by the Secretary of State for Health and Social Care, providing a forum and wider network to support each other.

Meeting each quarter, the group promotes best practice between organisations, and shares fraud risks that may impact other public health sector organisations and the wider health group. The aim is to set an engaging and relevant agenda, bringing in expert speakers from across government, including PSFA, who provide updates from the centre.

Public Sector Fraud Authority (PSFA)

PSFA will provide oversight of our progress and delivery through our action plan. This plan will set out the actions designed to meet the objectives of this strategy, and our progress towards defined targets and metrics.

We will be expected to provide these updates on a quarterly basis and accept challenge on any targets or metrics.

Annex B: achievements from last strategy

Our previous strategy covered the period of 2020 to 2023. This coincided with the emergence of the COVID-19 pandemic, which altered plans and priorities, significantly impacting on DHSC.

The COVID-19 pandemic required government to adapt to circumstances it had not expected. This included having to rapidly recruit and train staff in a variety of roles required to protect the public or help monitor and contain the virus, as well as working at pace to develop its approach to procurement. Large quantities of personal protective equipment (PPE) were procured from suppliers with which we had not previously worked and in a highly competitive international market. The size, pace and complexity of much of DHSC’s response to COVID-19 meant that new processes were developed rapidly to provide the required resilience.

Despite this, we continued to work on our key objectives, which aimed to minimise loss to both DHSC and ALBs. What follows is not an exhaustive list, but notable successes under each of our objectives.

Getting the basics right

We have carried out a full review of counter-fraud guidance available to colleagues across DHSC. This has included an overhaul of our intranet page, new contact routes to separate advice and reporting, and a refresh of the fraud, bribery and corruption policy and response plan.

We have also redeveloped and refreshed our training offer, including the development of a bitesize package that can be used to refresh knowledge in a small window. We have also worked closely with learning and development colleagues to expand the mandatory training offer, ensuring it is publicised and monitored.

We have continued, through our sponsorship role of NHSCFA, to roll out the GCFFS to NHS ALBs. This has helped to drive best practice in fraud prevention and detection, and ensure all activity is aligned across the health sector and central government. We have begun to extend this to the companies owned by the Secretary of State for Health and Social Care to ensure they are also working to the minimum standards of counter-fraud activity.

As part of this roll-out, we have also completed a review of all health ALBs’ compliance with the GCFFS, some of which had not previously been assessed.

As a result of these changes, counter-fraud is increasingly a part of policy development and existing policies are being reassessed with this new information. This means policies are better protected from fraud.

Building capability

A new NHS standard contract was launched by NHSCFA. This gives a standard set of counter-fraud expectations for anyone undertaking work for the NHS. This thereby delivers greater assurance and control over counter-fraud training and the skills of those in counter-fraud roles across the NHS.

We are now in a position to identify key decision-makers and work owners to be able to drive and influence change or counter-fraud activity.

Insight

In this area, the changes we have made have allowed us to maintain strategic oversight of key organisations, ensuring collaboration and alignment, and presenting a more united front against fraud and a more ‘team-orientated’ approach to fraud issues across the sector.

We have established a Counter Fraud Liaison Group. This brings together counter-fraud experts from across health ALBs, DHSC-owned companies and other key organisations. It is a forum to share information and best practice, and ensure alignment in activity.

An offshoot of this is a peer review group, where DHSC and ALBs work together to ensure that they can continually improve against the GCFFS.

Real Time Exemption Checking was also launched. This allows pharmacists that have this system to check the eligibility of the patient to free prescriptions at the point of dispensation. This ensures a quicker service by:

• enabling pharmacists to know the patient’s status
• removing the need to investigate eligibility
• deterring those who are not eligible

Working together

Fraud now has a forum for all aspects of the health sector. Being able to quickly share information has led to information and skill-sharing, and built the positive attitude to counter-fraud work – namely, finding fraud is a sign of strength and good processes.

With our improved training and awareness, we have been actively encouraging the use of FRAs. These help policy teams to identify risks so that we can advise on appropriate mitigations. We have ensured that we get the most benefit from this work by linking up teams to allow them to share their findings and experience across similar work streams. Teams can share knowledge and experience in areas where risk may exist, particularly those requiring specialist knowledge.

ALBs and directorates now provide increased reporting of fraud, loss and error in line with Cabinet Office guidance, meaning we have greater oversight into the impact of fraud and can ensure ongoing work is relevant or identify trends.

The Counter Fraud Board brings together senior leaders from DHSC, PSFA and key national health bodies to ensure urgency, pace and collaboration. This drives a co-ordinated approach to delivery of the counter-fraud agenda from a strategic perspective. This continues to operate, and membership continues to expand. As this group has matured, it has led to far better collaboration and work alignment.

Minimising loss

Since the launch of the last strategy in 2020, the ‘high-level’ FRA has been developed. This has led to better risk assessment and communication with risk owners across DHSC, encouraging those with the greatest influence to make an impact to take responsibility and accountability.

We have worked with ALBs to ensure that interdependencies are recorded on their action plans and, using the liaison groups, have a forum to engage with appropriate bodies.

As we expanded our ability and priority to engage with policy teams across all areas of DHSC, we have seen a year-on-year increase in the amount of engagement from policy teams, both inside and outside the organisation.

This has included working with learning and development to ensure that DHSC’s mandatory learning for counter-fraud is effective by encouraging a fresh focus on completion and monitoring.

NHSCFA, working with partners, has also achieved their £400 million target for prevented fraud. PSFA provided assurance that, during 2020 to 2021, DHSC detected fraud and error amounting to £58.5 million.

This demonstrates that we are taking a much more proactive approach to counter fraud. By engaging earlier, we are more easily able to identify risks and implement appropriate mitigations.