Data manipulation fraud

Fraud through falsifying data to meet targets, increase revenue or hide undesirable outcomes.

Data manipulation includes falsifying data to meet targets, increase revenue or hiding undesirable outcomes, including within A&E. It encompasses the ‘2023 - 2025 NHS Payment Scheme’ (NHSPS) and the four different payment mechanisms it governs within secondary care.

The financial vulnerability estimate has increased because of the increase in the funding allocated to ICB core services and elective recovery care funding compared to the previous year.

£189.1m

vulnerable from an expenditure of £63 billion

Strategic intelligence picture

There is the potential to manipulate performance data and accounts within an NHS Trust to meet cost improvement targets. Potentially enabled if senior management request staff submit false accounting figures, request suppliers issue invoices before a cut off, cancel invoices with credit notes, create false provisions to meet targets, and increase purchase orders with the intent of reducing them in the future.

It is a realistic possibility for performance data to be falsified with the intention of meeting targets in advance of multiple tendering processes. Staff could be instructed to input the date of when an appointment was booked into a system instead of when the appointment was due. Thus, allowing the appointments to appear compliant when targets were not actually being met.

There is the potential to falsify statistics to ensure monthly targets are met for patients being discharged. Management could instruct clinicians to delay discharging specific patients during certain months which could impact on targets.

It is probable that some medical staff could claim to provide programmed activities at an NHS trust and receive payment, yet not perform these services. This is potentially enabled through the conduct of these individuals being omitted by senior management. Furthermore, there is the potential to submit false information around a compliance inspection without accessing the relevant location.

A Trust has the ability to manipulate data to appear as if there is high utilisation of hospital facilities. By closing lists which are not filled and then excluding them from reporting, the metrics can be manipulated to appear as if there is high utilisation of certain facilities.

It is likely that trusts are manipulating performance data to appear as if they are delivering higher levels of performance or improvement. These manipulations can result in a financial benefit, as the acute trusts which achieved the highest-level target percentage and/or improvement for A&E 4-hour performance could receive between £1million to £4 million within the urgent and emergency care (UEC) capital incentive scheme. Managers could instruct staff in the emergency department to amend data to appear as if 4 hour waiting times have been achieved. There is also the potential to abuse the use of diagnostic holding centres or clinical decision units to avoid breaching and possibly incurring additional charges.

It is highly likely that a trust could record a patient as a day case instead of outpatient to incur additional funding. It is possible for a department in a trust to be recording appointments in a way which enables additional funding to be accrued. When patients are admitted as a day case this can attract a higher price than if they are recorded as an outpatient attendance, as a day case would be considered as an inpatient to the hospital. However, the reverse can be incentivised through setting a higher price in policy, where a day case can legitimately be recorded as outpatient.

Information reports received for data manipulation fraud

The change in the number of fraud reports received in relation to data manipulation from 2020 - 2021 to 2024 - 2025 is illustrated in the below chart:

Table showing the annual reporting trends for data manipulation fraud between 2020 - 2024
2020 - 2021 2021 - 2022 2022 - 2023 2023 - 2024 2024 - 2025
2020 - 202114 2021 - 202216 2022 - 202313 2023 - 20248 2024 - 202525

Horizon scanning

The consultation for the proposed 2025/26 NHSPS closed on the 28th of February 2025. However, the amendments which were proposed were yet to be confirmed at the time of writing this assessment, therefore the full impact was unknown. Inflation has reportedly eroded the financial allocations received by Trusts, with an inflation assumption of 2.5% in 2023 - 2024 being surpassed by a reported 6.2%.

The UK has been impacted by the baseline tariff (other than with automobiles) as part of the reciprocal tariffs introduced by the United States of America, with some other countries receiving higher tariffs. These tariffs could potentially impact on the current price caps, drug tariffs, the market forces factor (MFF) or funding allocations in the NHS.


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