ICB footprints are changing from the 1 April 2026 and 1 April 2027, with some ICBs being abolished and others established, along with mergers. Additionally, the NHS Neighbourhood Healthcare Framework has been introduced as part of the government’s 10 Year Health Plan for England, this includes targets with percentage increases and reductions which could inadvertently result in data manipulation.
As part of the 10 Year Health Plan, pharmacists will have more time to treat patients by expanding those who can supervise the dispensing of medicines, pharmacies will also facilitate expansion of patient services. However, Community Pharmacy England has highlighted compromised patient care and increased pressure on pharmacy teams experienced as a result of medicine supply issues.
In addition to the 10 Year Health Plan, the 10 Year Workforce Plan shifts the strategy from increasing pure headcount to achieving a more productive, community-based, and digital-first workforce. Alongside the merger of NHSE and DHSC, as well as the merger of some Integrated Care Boards, the government aims to cut administrative costs and reduce bureaucracy. Furthermore, the Procurement Act 2023 and the merger may remove duplication and overlapping.
The workforce strategy is a move toward a domestic first pipeline, doubling medical school places and significantly expanding clinical apprenticeships to reduce reliance on international recruitment.
The NHS is increasingly shifting ophthalmology services from hospitals into community optometry to ease secondary care pressures and improve patient access, though funding gaps remain a challenge. New commissioning frameworks and expanded services such as CUES and MECS aim to strengthen primary eye care pathways and keep more patients in community settings. National consultations are exploring extended medicines responsibilities for optometrists and changes to ophthalmology payment structures, including price adjustments for cataract and non-cataract services. Despite a small uplift in sight test fees, wider GOS payments remain frozen. However, the NHS's digital transformation plan emphasises better IT interoperability and increased use of AI across eye care.
Investments have already been made in rolling out AI within trusts, however health information management professionals reportedly have concerns around the use of AI and machine learning for coding within healthcare. Frontline staff will see the introduction of mandatory wellbeing standards and AI-driven tools, such as ambient voice scribes, designed to automate paperwork and improve retention. Furthermore, the landscape will transition toward a community-focused model, phasing out expensive agency staff in favour of multidisciplinary teams based in local Neighbourhood Health Centres.
Although the shift towards digitisation in the 10-Year Health Plan for England may increase exposure to procurement fraud, this is against the backdrop of reduced ICB running costs of 50%, and increased emphasis on decision-makers to maximise public benefit through “social value”.
The Dentistry Recovery Plan was introduced in February 2024, with the aim of creating 2.5 million new NHS dental appointments. It is possible this may present more opportunities for fraudulent activity as individuals attempt to avoid costs. From April 2026, the dental reform incentives aim to increase the number of patients and improve access to urgent care. However, it is possible that this could be exploited in the way of false claims, including urgent care claims. Practices may also onboard new patients in order to receive incentives but may not actually provide NHS appointments.
If increased funding and incentives are tied to specific targets/UDAs, some dental providers may inflate the number of treatments provided to claim more from the NHS. Urgent care treatment is 1.2 UDA.
The DHSC has reported there are 2,400 overseas trained dentists currently living in the UK who are unable to practise due to limited exam capacity. With new government investments, up to 1,350 overseas-trained dentists will be able to join the General Dental Council (GDC) register by 2028 and will be able to provide dental services in the UK. Increased funding will also allow more candidates to sit the Licence in Dental Surgery (LDS) examination, with the aim of strengthening the dental workforce. However, there are also the risks around fraudulent qualifications during recruitment processes and an increase in dentists and dental activity could potentially result in further fraudulent activity, for example an increase in false claims.
The media reported a drop in UK visa applications over the last year as stricter immigration rules have been introduced. Including the requirement for an application for a Skilled Worker Visa to undertake a degree-level role, with lower-skill jobs no longer qualifying for a visa. The salary threshold has also increased from £38,000 to £41,000 and from 8 January 2026, Skilled Work visa applicants will also be required to speak English to an A-level standard. Following the changes to UK Skilled Work visa rules, fake job or sponsorship offers may also reduce, where overseas workers are promised visas in exchange for money, with no real employment upon their arrival to the United Kingdom.
The introduction of a residency checker in February 2025 could potentially reduce the number of individuals falsely representing themselves as ordinarily resident when applying for a UK EHIC, GHIC, PRC and S2. However, this would not mitigate those using the details of a genuine resident to gain an application fraudulently and so false applications are still likely to occur.
The government pledged to abolish NHS prescription charges in England, following in the footsteps of Scotland, Wales and Northern Ireland, where prescriptions are already free of charge. As a result, the NHSCFA may not need to report on exemption fraud for prescriptions. However, if prescriptions did become free of charge in England, we may see different types of prescription fraud potentially occurring.
For example, individuals may exploit the opportunity to access more medication by falsifying symptoms. For now, the government have taken the stance to freeze charges until a final decision is made on the area.
In 2026 - 2027, investment in the GP contract will increase by £485m, to a total contract value of £13.86 bnj . The introduction of a new practice-level GP reimbursement scheme should; enable the recruitment of new GPs by practices or increase the number of GP sessions for those already employed by the practice. Additionally, the expansion of the Additional Roles Reimbursement Scheme (ARRS), including the removal of the restriction to only recruit newly qualified GPs, allows opportunity for increased means for manipulation.
Advice and guidance (A&G) incentives were previously a paid enhanced service but have now been embedded into core contract expectations for 2026 - 2027 as an expected standard practice. This may lead to recording A&G without genuine clinical need or inflated activity.
- Source quotes as ‘£13,863 million’