Performance analysis
The preceding performance overview section set our overall performance against financial targets. This performance analysis section builds on that summary by highlighting delivery against key performance indicators and the outcomes and impact achieved through our four fraud focused pillars and our enabling pillars; understand, prevent, respond and assure.
It includes illustrative examples of work undertaken within the reporting period and outlines how we have supported our people and deployed our resources to enable to delivery. Also described are details on how activity this year has contributed to the strategic period achievements and includes comparison data where applicable.
The analysis describes how we have been held to account by our Board and departmental sponsor across all performance areas and our future aspirations and targets along with further information on the impact of our strategic risks on our delivery.
The four pillars in action relating to investigations
Fraud by abuse of position and money laundering
Four counts of fraud by false representation by a resident NHS doctor
NHSCFA has a range of expert teams who work together to tackle fraud.
The National Investigation Service has three main areas of investigation – digital forensics,financial investigation and fraud investigation.
The Fraud Hub provides support through case management, enforcement, engagement and prevention.
Privileged access to confidential financial data was used to steal £218,000 and a further attempt of £84,000 was prevented
Positive collaboration with Trusts and LCFSs have produced excellent results in recent cases
Worked on-call night shifts at additional Trusts whilst on sick leave and on reduced duties from employer
Working closely with the CFA finance team investigators demonstrated that they pursue fraudsters where the evidence leads them
Working together by sharing resources, practical advice and expertise resulted in the prevention of further monies being stolen
Proved to have defrauded the NHS out of more than £268,000
Five defendants
Two custodial sentences
Three suspended sentences
Positive outcomes reflect the skills and dedication of the investigators and demonstrates the NHSCFA’s commitment to tackling fraud and protecting public resources
Defendant pleaded guilty and sentenced to three years imprisonment
Investigators used powers under Proceeds of Crime Act (POCA) to trace the stolen funds
Reclaiming funds back for the NHS and exposing the fraudsters in court maintains reputation and public confidence
In sentencing the judge said: “The public does not expect doctors to lie for personal gain.”
Extensive social media, print and broadcast coverage in the UK and internationally
Publicising the positive outcomes through the media raises the awareness of the work of the NHSCFA and is an effective prevention message and deterrent across the sectors and public
Extensive regional and social media coverage
The NHSCFA provides training, advice and guidance to Trusts and LCFSs to help them identify and investigate fraud, these include:
Regular webinars – bulletins for the sector – ongoing training courses – extranet for LCFSs – guidance documents
1. The annual Strategic Intelligence Assessment (SIA) has provided a systemwide view of fraud risk across the NHS, identifying emerging threats, vulnerabilities and trends to inform targeted intelligence led counter fraud activity. The latest assessment identified a 1.5% increase in reported allegations, rising to 6,462 in 2024 to 2025. This reflects improved awareness and reporting across the system, strengthening the evidence base used to prioritise action.
Workshops were developed for stakeholders to explore counter fraud activity and local challenges
2. Collaboration with Local Counter Fraud Specialists (LCFS) was strengthened, delivering faster intelligence sharing, closer relationships and more partnership working, and more efficient case progression. This has enabled earlier identification of risks and more timely targeted interventions across the NHS.
EFRA identifies key fraud themes, emerging risks and control gaps.
EFRA provides a consolidated view of fraud risk exposure, showing direction of travel, priority risk areas and limitations in current controls.
3. The NHSCFA Strategic Fraud Risk team has led the development and production of consistent system-wide Enterprise Fraud Risk Assessment (EFRA) framework for the NHS. This has strengthened the NHS’s ability to identify key fraud risks, expose control gaps and assess risk exposure at both organisational and national level, aligned fully with the government Counter Fraud Functional Standard and recognised best practice.
4. Analysis undertaken within the NHSCFA Fraud Hub identified gaps between fraud identified and funds recovered. In response we launched a dedicated workstream to enhance understanding of this issue and implement measures to improve processes, communication and accuracy of reporting.
5. The NHSCFA operates a dedicated horizon scanning function, systematically monitoring external developments including policy, legislative and technological change to identify emerging threats and opportunities to enhance the counter fraud response. This proactive capability delivered 17 responses during the year, including engagement in consultations and legislative amendments, ensuring that we remain agile and ready to respond to a rapidly evolving fraud landscape. These activities strengthen our understanding of a rapidly changing fraud landscape, ensuring that counter fraud priorities and active interventions remain aligned to emerging threats and the scale and pace of transformation currently underway across the NHS.
1. We continued to place greater emphasis on organisational learning as a key driver of fraud prevention. Learning Reports demonstrating the impact of investigations and identifying fraud prevention opportunities were disseminated directly to stakeholders, providing timely insight into control weaknesses, risks and vulnerabilities. ensuring timely and accessible access to key findings. This enabled NHS organisations to undertake informed local fraud risk assessments within their own operating environments.
Practical advice
to assist the sector with
developing stronger prevention
initiatives has included issuing of
targeted guidance documents.
10 Fraud Prevention Notices (FPNs) and sector bulletins
Our IFAW campaign reached over 1.9 million NHS staff
2.We strengthened our focus on organisational learning as a core component of fraud prevention, supporting the NHS to better understand risks and how action can lead to the prevention of financial loss to fraud.
International Fraud Awareness Week (IFAW) formed a key part of this approach, significantly extending our reach and reinforcing fraud awareness across the NHS. We also engaged with international partners to share insights and strengthen our collective understanding of global fraud risks in health.
3. A new prevention initiative, Project WISE (Workforce Integrity and System Efficiency), was launched during the year. This first of its kind, proactive and data driven pilot was developed as a strategic response to workforce related fraud risks within the NHS. Delivered in collaboration with NHS trusts, Project WISE supports a coordinated, system wide approach to tackling staff related fraud. The programme strengthens early detection, improves transparency and enhances controls by proactively identifying fraud indicators using data analytics and machine learning across organisations. Collaboration has demonstrated the added value of combining local fraud intelligence with prevention capability across the NHS.
Examples of NHS staff fraud relating to Project WISE
- working whilst on sick leave
- undeclared dual employment
- conflicts of interest
4.We have enhanced our platform for capturing and analysing fraud vulnerabilities across the NHS, enabling organisations to report control weaknesses and emerging risks as they arise. This provides a consistent, system-wide view of fraud vulnerabilities, allowing insight to be collated, analysed and shared back across the sector to strengthen prevention activity and reduce exposure to fraud. As a result the number of reports made across the platform increased by 18% to 8501 in the reporting period.
Rapid technological change continues to create new fraud threats and vulnerabilities across the NHS. The provision of targeted fraud prevention advice to the sector forms a key mitigation to this strategic risk. Investment in workforce expertise has strengthened our understanding of emerging risks and enhanced our ability to respond effectively.
1. To coordinate counter fraud activity, we have collaborated with stakeholders to develop a Control Strategy. This is the mechanism for setting and coordinating priority counter fraud activity across the NHS, based on intelligence and risk, so that limited resources are focused where they will have the greatest impact. An example of how this has directed our activity is Project WISE which was set up as a direct result of identification of a risk.
2. Our National Investigation Service (NIS) has continued to lead on serious, complex and high value investigations, progressing cases through criminal, civil and disciplinary routes. Further information on the outcomes of these is available in the news section on our website. This year has seen an increase in the number of cases progressing through to positive Crown Prosecution Service (CPS) charging decisions and ultimately to court, although capacity issues across the criminal justice system continue to impact upon timelines.
£7.05 million target for the National Investigation Service teams to identify, prevent and recover monies lost to fraud.
Total achievement £20.16 million
Investigations are supported by the Digital Forensics Unit (DFU). This provides specialist digital capability. The team enable the lawful acquisition, examination and presentation of digital evidence from a wide range of devices and systems, supporting criminal, civil and regulatory proceedings. The DFU operates is accredited under ISO/ IEC 17025 and is aligned with the Forensic Science Regulator’s Code of Practice.
3. Our National Investigation Service (NIS) has continued to lead on serious, complex and high value investigations, progressing cases through criminal, civil and disciplinary routes. Further information on the outcomes of these is available in the news section on our website. This year has seen an increase in the number of cases progressing through to positive Crown Prosecution Service (CPS) charging decisions and ultimately to court, although capacity issues across the criminal justice system continue to impact upon timelines.
The CSL has been accredited by Skills for Justice and recognised by the Government Counter Fraud Profession (GCFP) as an approved academy model, positioning NHSCFA at the forefront of professional standards development across the public sector.
This establishes a clear pathway for NHS counter fraud specialists to develop and demonstrate professional competence and become part of the GCFP strengthening the consistency, capability and professionalism of the workforce.
4.Developing our analytical capability to detect fraud has been a key activity. Project Athena has strengthened NHSCFA’s counter fraud capability by embedding advanced data science and analytics into operational practice. In its first year, the programme exceeded a 11:1 return on investment, formally recognised by the Public Sector Fraud Authority, and identified millions of pounds in fraud prevention savings.
Total achievement of fraud prevented by Project Athena £42.30 million for 2025 to 2026
Athena has established scalable data infrastructure, expanded access to national datasets and enabled earlier identification of potential fraud through advanced analytics, including artificial intelligence and machine learning. This has strengthened our ability to detect anomalies, generate actionable insight and intervene earlier.
The programme has also strengthened collaboration with partners across the NHS, law enforcement and financial institutions, improving the sharing and use of data to support investigations and disruption activity.
Together, this work has laid the foundations for data analytics to operate as a sustainable, business-as-usual capability within NHSCFA, supporting more proactive fraud detection, evidence-based decision-making and the ongoing protection of public funds.
£16.63 million target to prevent, detect and recover monies lost to fraud at local level. Total achievement £18.38 million an increase of 17.6% from 2025 to 2026.
5. Operational support, oversight and engagement enhanced fraud detection, supported investigative work and increased recovery of funds lost to fraud.
Risks associated with the delivery of Project Athena were actively managed throughout the reporting period. Robust governance arrangements ensured ethical data acquisition and supported the development of consistent, repeatable data analytics models.
We have achieved this by strengthening confidence across the counter fraud system by actively engaging with local stakeholders and partners, demonstrating that NHSCFA’s support, standards, and interventions are effective, responsive, and valued by the wider counter fraud community.
1. Operational support, oversight and engagement enhanced fraud detection, supported investigative work and increased recovery of funds lost to fraud.
383 Local Proactive Exercises to identify issues and provide assurance completed.
The latest cycle achieved a 99.6% submission rate, demonstrating strong engagement across the sector. Analysis of this data enables us to identify trends, highlight areas of strength and target improvement activity where it is most needed, driving increased compliance and more consistent standards across the NHS.
2. Nationally driven improvements to reduce vulnerability to procurement fraud have been supported by NHSCFA through the development of local proactive exercises. These enable organisations to evaluate existing controls, identify weaknesses and implement targeted improvements, strengthening procurement fraud resilience at local level.
3. Guidance on the new ‘Failure To Prevent Fraud’ offence, introduced under the Economic Crime and Corporate Transparency Act 2023, has been issued to the counter fraud community. Supplementing the Home Office guidance, this supports NHS organisations to act with integrity and to gain assurance that effective and proportionate fraud prevention arrangements are in place. Through this coordinated approach, the organisation seeks to enhance resilience to fraud across the NHS and encourage a culture of continuous learning and improvement.
21 targeted awareness campaigns delivered.
Strengthening knowledge on how to counter procurement fraud.
1 contract register reviewed, which listed over 200 contracts worth £1,395,000 identified anomalies such as:
- missing contract values
- contracts still marked as ‘draft’ despite start or end dates having passed
As a result of the Local Proactive Exercise these gaps were addressed, resulting in benefits to the organisation of improved contract management and monitoring.
4. We strengthened assurance across the counter fraud system by supporting LCFSs and promoting collaboration across the NHS. The enforcement team played a key role in sharing expertise and supporting investigations, with approximately 90% of cases originating from LCFS referrals. A structured engagement approach ensured consistent communication with key stakeholders, including LCFSs, Directors of Finance (DoFs) and governance leads, strengthening alignment, oversight and confidence across the system. This was supported by a programme of conferences, webinars and drop-in sessions, providing a platform to share knowledge, address emerging risks and support continuous improvement.
A second LCFS conference, alongside follow-up drop-in sessions, further strengthened sector collaboration and the sharing of insight.
Stakeholder feedback and surveys demonstrate the impact of this approach, with overall measured satisfaction increasing by more than 10% and confidence in communication and relationships rising from 60% to 77%. This feedback is used to continuously refine engagement activity and ensure it remains relevant, targeted and effective.
Our webinar on Failure to Prevent Fraud attracted 270 attendees -the highest number recorded for this type of engagement.
Quarterly Fraud Hub Bulletins
Engagement forum stakeholder survey
5.Clue, our case management system, underpins assurance across the counter fraud system by ensuring investigations, intelligence, outcomes and identified fraud are captured accurately and consistently. This provides a robust audit trail, strengthens oversight and supports reliable, high-quality data for reporting, assurance and organisational learning.
A case management team provides ongoing support to users, resolving issues and offering clear guidance, helping to maintain data quality, operational continuity and confidence in the system.
6. During the year, we commenced a fraud loss measurement exercise within General Ophthalmic Services, working in collaboration with NHS England and the NHS Business Services Authority. This work will provide robust, evidence-based insight into the scale and nature of fraud risk in this area, with the final report due in Q1 2026 to 2027. This strengthens assurance by improving the accuracy and consistency of fraud measurement and supporting more informed, risk-based decision-making across the system.
These activities rely on a range of technology solutions, making IT resilience and protection against malicious cyber threats a strategic priority for the organisation. Cyber security risks are continuously monitored to support business continuity and maintain effective controls.
Our People and our Resources
Our enabling services support the delivery of all our counter fraud activity. Information regarding our Board, governance and compliance and financial position are detailed in the Accountability Report.
Technology
- redesigned the online fraud reporting tool to enhance the quality of intelligence gathering
- further developed our customer relations management platform to support our approach to engagement and communications
- achieved an average customer satisfaction score of 96.6%
-
improvements to our cyber security
resilience including:
- resolution of 40% of system alerts via automation
- improved phishing awareness
- maintained ISO27001 ISO20000 accreditations
Communications
- implementation of a new media management platform
- international, national and regional media and social media
- delivery of social media campaigns
- internal communications via our intranet
- regular CEO Live events
Performance and Transformation
- introduction of AI assistance i.e.Copilot
- designing new fraud resilient project and programmes
- strengthened Board-level assurance and risk oversight
- supported organisational review and operating model development
- maintained delivery discipline and enabled effective use of technology
People
- active recruitment monitoring to assess fairness and differences in ethnicity outcomes
- supported inclusive decision making with Equality Impact Assessments
- 82% of staff would recommend NHSCFA as a good place to work
- delivered a range of core leadership training
- all-staff conferences held
Performance reflections
Overall performance against our published business plan was strong. Over the reporting period we have reviewed delivery and adjusted resources to support additional areas of work including a significant increase on our international engagement.
During the year, we undertook additional international engagement activity, establishing a formal collaboration with the Health Insurance Organisation in Cyprus to support the development of its counter fraud capability.
This work involves the delivery of a structured programme of knowledge-sharing and capability-building activity, including webinars and follow-up engagement sessions focused on fraud awareness, intelligence, risk assessment and data analytics.
The programme commenced in Q4 and will continue into 2026 to 2027, supporting the development of organisational capability to detect, prevent and respond to fraud.
This activity reflects the growing recognition of the NHSCFA’s expertise internationally and demonstrates our ability to apply our knowledge and experience to support counter fraud capability beyond the NHS.
We committed to developing a dedicated deterrence strategy to promote a stronger counter fraud culture across the NHS. While a standalone strategy was not formally published during the reporting period, significant progress has been made in delivering the underlying components.
This has included strengthening engagement with key stakeholders, expanding awareness and behavioural change activity, and increasing focus on risk assessment and fraud reporting across the system.
Progress on implementing enhanced management reporting, including proposals for mandatory fraud reporting through NHS England, was paused in light of wider system reform and the transition away from the arm’s length body model. This ensures that future reporting arrangements align with emerging accountability structures across the NHS.
Taken together, this work has advanced a more mature, system-wide approach to deterrence and has informed the development of strategic objectives within our 2026 to 2029 Strategy, where this activity is being taken forward as part of a broader, integrated counter fraud approach.
Sustainability Reporting
NHSCFA is not currently required to provide full sustainability reporting under Task Force on Climate-related Financial Disclosures, as it does not meet the threshold criteria.
We comply with the Greening Government Commitments and report through the DHSC as set out in the sustainability section of the framework agreement between both bodies providing quarterly data.
Social responsibility is a consideration in strategic decision making and assurance processes including the procurement life cycle and project management.
A review of our longer-term estate requirements will take place during 2026 - 2027 once the of changes to our operating model are confirmed.
The environmental impact of the organisation is described in the following sections.
Estates
We occupy three offices, all of which are in multi occupancy buildings. The lease for our Citygate office in Newcastle was renewed in 2025. Our London and Coventry offices are within government hub buildings. As we operate within shared premises, there is limited scope for us to take direct action in relation to climate adaptation and carbon offsetting. We do not own or control any sources of Scope 1 greenhouse gas emissions within our offices and do not directly procure energy supplies.
Our Coventry office is in Cheylesmore House, which is currently undergoing an internal reconstruction project aimed at decarbonising the building by the end of April 2026. This initiative represents an important step in the broader effort to reduce carbon emissions across the public estate.
Once the decarbonisation measures have been completed, Cheylesmore House is anticipated to see a reduction in its overall carbon emissions. This improvement will also help to lower the carbon footprint of the NHSCFA.
All offices are fitted with automatic hand washing taps, instant hot water taps to reduce unnecessary water use, and sensor controlled lighting. Recycling schemes operate across all buildings. During the reporting period, we did not undertake any biodiversity related activities.
Social responsibility
Most of our workforce is fully or partially home based, with staff attending offices and meetings as required. Home based workers who live more than five miles from their nearest office may claim business travel when attendance is necessary. This approach to flexible working continues to support recruitment by widening our potential talent pool and promotes a positive work-life balance for staff.
We have continued to raise awareness of social responsibility through the regular publication of information for staff and the delivery of drop in engagement sessions. This has included the publication of an internal Sustainability Strategy to support shared understanding and ongoing engagement across the organisation.
Currently, we cannot provide specific figures regarding employees’ domestic energy consumption or the reduction in emissions resulting from decreased commuting. To improve future reporting and support sustainability, we have introduced two voluntary questions into the Safety, Health, and Environment (SHE) app as part of our home worker risk assessment:
- is the electricity supply at your home address on a green energy tariff?
- which primary mode of transport would you normally use to travel to your primary NHSCFA office location?
| Sustainability goals | Milestones reached |
|---|---|
| Delivery of workforce engagement activities |
Publication of articles/promotional material to promote environmental and sustainability initiatives
launched by the wider building management terms
Signage for recycling schemes Promotion of cycle to work schemes, access to electric salary sacrifice scheme cars, commitment to paperless working where possible |
| To embed social responsibility in procurement activity |
Procurement guidance amended to improve signposting for contract managers on consideration of social
responsibility on all expenditure
Assessment of supply chain partners to identify their commitment to sustainability |
| To increase awareness of managers and leadership to consider sustainability and environments impact in decision making | Continued promotion of sustainability activity and process for recovery and recycling of furniture when home workers leave employment with the organisation |
| Responsible disposal of endof-life IT equipment | All equipment disposed of appropriately including recycling of parts and electrical appliances in accordance with regulations |
| Removal of consumer single use plastic (CSUP) | Stationary orders managed centrally to ensure CSUP is factored into purchases |
| Collation of data as required by DHSC | Ongoing liaison with landlords to obtain required data |
| Greenhouse gas emissions | ||||||
|---|---|---|---|---|---|---|
| Category | Measure | 2019- 2020 |
2023- 2024 |
2024- 2025 |
2025- 2026 |
Movement from 2019-2020 baseline |
| Scope 1 emissions1 (tCO2e)5 | Emissions from organisation owned fleet vehicles | 2.81 | 1.08 | 0.57 | - | — |
| Gas | - | - | 7.48 | 1.67 | — | |
| Total scope 1 emissions | 2.81 | 1.08 | 8.05 | 1.67 | -40% | |
| Scope 2 emissions2 (tCO2e) | ||||||
| Electricity | - | - | 81.16 | 50.14 | — | |
| Total scope 2 emissions | - | - | 81.16 | 50.14 | -% | |
| Scope 3 emissions3 (tCO2e) | ||||||
| Road travel | 8.11 | 4.03 | 18.80 | 17.91 | — | |
| Rail travel | 31.81 | 14.05 | 20.52 | 19.17 | — | |
| Domestic air travel | - | 2.79 | 1.36 | 2.61 | — | |
| International air travel | - | 3.05 | 0.18 | 0.97 | — | |
| Total scope 3 emissions | 39.92 | 23.92 | 40.86 | 40.66 | 2% | |
| Total tCO2e | 42.73 | 25.00 | 130.07 | 92.47 | 116% | |
| Related use and cost4 | ||||||
| Scope 1 emissions (tCO2e) | Scope 1 business travel | Miles | 46,654 | 16,171 | 8,600 | - |
| Scope 1 business travel | £ | 6,532 | 2,264 | 1,204 | - | |
| Gas | kWh | - | - | 40,924 | 9,153 | |
| £ | - | - | 2,861 | 640 | ||
| Scope 2 emissions (tCO2e) | Electricity | kWh | - | - | 360,161 | 256,439 |
| Electricity | £ | - | - | 97,352 | 69,315 | |
| Scope 3 emissions (tCO2e) | Road travel | Miles | 101,452 | 50,110 | 93,081 | 84,677 |
| Road travel | £ | 25,055 | 22,172 | 43,545 | 62,230 | |
| Rail travel | Miles | 454,056 | 246,564 | 360,397 | 336,156 | |
| Rail travel | £ | 192,250 | 128,167 | 194,914 | 174,178 | |
| Domestic air travel | Miles | - | 6,362 | 2,906 | 7,067 | |
| Domestic air travel | £ | - | 1,129 | 1,270 | 2,624 | |
| International air travel | Miles | - | 9,478 | 599 | 4,784 | |
| International air travel | £ | - | 946 | 393 | 576 | |
| Total miles (scope 1 and 3) | 602,162 | 328,685 | 465,583 | 432,684 | ||
| Total cost of business travel £’000 (scope 1 and 3) | 223,837 | 154,678 | 241,326 | 239,608 | ||
| Total cost of all related use £’000 (all scopes) | 223,837 | 154,678 | 341,539 | 309,563 | ||
2 Scope 2 emissions arise from the consumption of purchased electricity, heat, steam and cooling
3 Scope 3 emissions arise from official business travel by vehicles not owned by the organisation
4 Miles and £ rounded to nearest whole number
5 tCO2e stands for tonnes of carbon dioxide equivalent, a standard unit for counting greenhouse gas emissions
| Air Travel | |||||
|---|---|---|---|---|---|
| Flight type | Haul | Class | 2023 to 2024 | 2024 to 2025 | 2025 to 2026 |
| Total distance (kilometres) | |||||
| Domestic | n/a | Economy | 10,239 | 4,677 | 13,839 |
| International | Short | Economy | - | 964 | 7,707 |
| International | Long | Economy | 15,252 | - | - |
Alex Rothwell
Chief Executive Officer
Date: 1st July 2026