The COVID-19 period will have inevitably emboldened criminals to exploit the opportunities created by the urgent funding streams generated during the pandemic and the removal of thresholds allowing for an immediate response. These funding streams significantly increased the NHS budget by £20.5 billion between 2019 – 2020 and 2021 – 2022. It is projected the budget will see a 1.2% increase between 2023 – 2024 and 2024 – 2025, and ultimately settle at a significantly larger annual budget than pre-pandemic levels. As such, it appears the pandemic has influenced healthcare spending with a permanent budget uplift, possibly the result of greater public expectation and tackling elective care waiting lists.
The longer-term impacts of the pandemic have increased the burden on the NHS in other areas that may not have seen as much funding over the previous couple of years, hence commitments to increased expenditure in the future. It is assessed, therefore, that financial vulnerability to fraud and error will rise because of this increased expenditure.
Increased financial vulnerability for the NHS could be exacerbated by other factors, such as pressure on the wider economy and a cost-of-living crisis. The impact of this more broadly has already been highlighted by a 17% rise in fraud cases recorded by the National Fraud Database in the first nine months of 2022, when compared to the previous year, and a 11% increase on pre-pandemic levels. As such, there is no reason to suggest this trend will not be replicated in the NHS with increased temptation by some to mitigate financial pressures. For example, those within decision-making positions manipulating the procurement process; patients claiming exemption for prescription items, or NHS staff reporting sick whilst working elsewhere.
To disrupt and mitigate against fraud, the counter fraud community within the NHS in England has developed a collaborative Control Strategy process that includes an annually agreed priority review and strategic action plan. For the strategy period of 2023 – 2026, the NHSCFA and partners will be focussing on four strategic pillars, designed to consider the intelligence picture, assessed risk position, and return on investment:
- Understand (how fraud, bribery and corruption affect the NHS)
- Prevent (ensure the NHS is equipped to take proactive action to prevent future losses from occurring)
- Respond (equipped to respond to fraud when it has occurred)
- Assure (overall response to fraud across the NHS is robust)
With this heightened threat and probably for the longer term, it is important that the strategic priority areas are aligned to the current fraud landscape and remain flexible to identify where resources and activity should be appropriately and proportionately directed for maximum impact.
The NHSCFA and its partners have recently conducted a review of the strategic priority areas, with the organisation evolving its Control Strategy approach to further enhance the response to fraud. This approach consists of an annual review of the intelligence picture, risk landscape and financial vulnerabilities. These inform the integrated planning approach and annual strategies to bring all stakeholders and partners together in a more collaborative manner.
Any assessments made are based on the foundation of intelligence. This is not fact or evidence, but hypothesis and inferences drawn from the best available information at the time of writing. To enrich the intelligence picture and help safeguard valuable NHS resources against those motivated to commit fraud, it is the responsibility of the public and NHS employees to remain vigilant and report any suspicions, whether to Local Counter Fraud Specialists (LCFS) or direct to the NHSCFA using our fraud reporting line (Fraud and Corruption Reporting Online (FCROL)).