In response to the COVID-19 pandemic, the government introduced emergency funding streams including the procurement of supplies, COVID-19 testing and delivery of the vaccine programme. This allowed for the use of direct awards to suppliers without any competition, and the removal of procurement thresholds. As such, it may have led to increased vulnerability to fraud and error and enabled criminals and organised crime groups (OCGs) to adapt and develop schemes targeted at exploiting the NHS in England and the public.
The urgent nature of the pandemic also impacted NHS staffing resources with anticipated increases within patient admissions alongside increased staff absences due to COVID-19 related sickness and/or testing positive and having to isolate. This will have again seen criminals using this as an opportunity for gain.
The impact of the pandemic would have been experienced in the financial years covered by this and last year’s SIA. For example, procurement and commissioning of services, where expenditure increased due to the pandemic, had financial vulnerability increases of £36 million in 2022 and another £55.1 million this year. These increases have also played prominent roles in why the overall financial vulnerability to the NHS from fraud, bribery, and corruption has increased consecutively, to £1.198 billion in 2022 and £1.264 billion this year.
The impact has also been highlighted within thematic areas that reflect patient service activity, with decreases in financial vulnerability in the first year of the pandemic. For example, patient exemption fraud vulnerability decreased by £53.7 million in 2022 yet has increased by £57.8 million this year. The former, which included three national lockdowns, led to a significant decrease in those accessing dental and optical treatments and claiming exemption. However, 2021 – 2022 saw activity return to pre-pandemic levels with financial vulnerability totals increasing as a result. This is also the pattern within optical contractor fraud and within areas of healthcare reliant on travel, such as fraudulent access to NHS secondary care and reciprocal healthcare arrangements with the EU.
More broadly, it is envisaged that a return to pre-pandemic levels in patient access activity and claiming behaviour will see increased financial vulnerability to fraud. This should be considered alongside the medium to long-term predicted budget increases in the NHS, even after COVID-19 expenditure is withdrawn.
Part of the NHSCFA’s response to the pandemic included production of the COVID-19 Threat Assessments to support stakeholders, local government and wider government in detection and deterrence of fraud in the NHS. However, it was decided during this reporting period to pause publication and keep as a watching brief due to decreasing COVID-19 specific reporting levels. The graph below shows these reporting levels compared to the previous year and as proportions for the two years 2021 – 2022 and 2022 – 2023.
| Report types | 2021-22 | 2022-23 |
|---|---|---|
| Report types Grand total | 2021-22 1336 | 2022-23 377 |
| Report types Unknown | 2021-22 60 | 2022-23 4 |
| Report types Reciprocal healthcare | 2021-22 1 | 2022-23 0 |
| Report types Pharmaceutical contractor | 2021-22 21 | 2022-23 9 |
| Report types Patient exemption | 2021-22 117 | 2022-23 25 |
| Report types P&C | 2021-22 811 | 2022-23 165 |
| Report types Optical contractor | 2021-22 0 | 2022-23 1 |
| Report types NHS staff | 2021-22 283 | 2022-23 153 |
| Report types NHS Pensions | 2021-22 0 | 2022-23 1 |
| Report types GP contractor | 2021-22 24 | 2022-23 14 |
| Report types Fraudulent access | 2021-22 10 | 2022-23 0 |
| Report types Dental contractor | 2021-22 8 | 2022-23 4 |
| Report types Data manipulation | 2021-22 1 | 2022-23 1 |
| Report types NHS Bursary | 2021-22 0 | 2022-23 0 |