This plan covers the core areas of focus for 2022-23, underpinned by detailed delivery plans which set out our key metrics and activities.
This plan will remain agile and responsive to the needs of the counter fraud effort of the wider NHS during these challenging times. We have also reflected on our impact within the sector and embraced the opportunity to evolve as the national body leading the NHS response to fraud.
Strategic Objective 1
We will lead and influence the NHS to find, prevent and reduce fraud, recovering losses and putting money back into patient care
We will improve awareness of fraud, including how it occurs and how it impacts the NHS
Key areas of focus
- We will continue work to improve stakeholder engagement across the health sector, to build counter fraud capability, support NHS organisations, and develop better understanding of their fraud risks.
- We will develop a counter fraud community-based approach to tackling fraud with a strong focus on shared objectives and priorities across the system.
- We will continue to undertake measurement of our engagement and
increase satisfaction among our key stakeholders in the NHS counter
fraud community by 5% year on year against the baseline established
in 2021-221 A ‘dip test’ survey of stakeholders in the NHS counter fraud community was carried out in 2021. A larger survey which is being undertaken in early 2022 will enable us to establish the baseline for this measure..
- Having achieved our target of 95% of providers having a Counter Fraud Champion (CFC) in 2021-22, we will continue to develop and evolve the CFC role and support networks as part of the NHS counter fraud community.
We will share our expertise with the Government Counter Fraud Function from a healthcare fraud perspective
Key areas of focus
- We will continue to develop a suite of standardised corporate dashboards and reporting for internal and external partners that support continuous improvement in counter fraud activity.
- We will continue to assess the impact of NHSCFA and local counter fraud proactive and reactive activity by undertaking a measurement of return on investment (ROI).
- We will enhance our fraud prevention guidance and advice to the sector.
- We will continue to assess the counter fraud landscape on an annual basis within the NHS in order to drive improved outcomes.
Develop capability through targeted support to NHS organisations enabling a deeper understanding of fraud
Key areas of focus
- We will maintain Government Counter Fraud Profession membership for 100% of those eligible within the NHSCFA.
- We will facilitate and enable access to associate membership of the Government Counter Fraud Profession within the LCFS community, with 50% of those eligible being members by the end of 2022-23.
Support the health sector in meeting the Government Counter Fraud Functional Standard
Key areas of focus
- 98% of NHS bodies to make an annual return against the Counter Fraud Functional Standard Government Functional Standard, GovS 013: Counter Fraud, Counter fraud, bribery and corruption, V2.0, Date Issued: August 2021.
- We will undertake assurance against the Government Counter Fraud Functional Standard returns.
- Improving counter fraud outcomes by engaging with appropriate organisations and adopting a risk-based approach towards prevention and detection work, resulting in measurable proactive and reactive outcomes.
- We will deliver a process of health body reviews in respect of the Government Counter Fraud Functional Standard, to provide assurance to the DHSC and Cabinet Office regarding levels of compliance, and to identify areas where we can provide further support to the local counter fraud function.
Continue to develop the functionality within the NHS fraud case management system
Key areas of focus
- We will continue to develop and configure the NHS fraud case management system (Clue) to ensure that it meets the needs of counter fraud specialists operating across the NHS.
- We will deliver complementary processes that support the sector, e.g. onboarding of members to the NHS counter fraud community, and the recording of key information that supports the overall value of the local counter fraud response.
We will develop a strategic plan and approach that supports and enables the counter fraud response across the health sector
Key areas of focus
- We will produce a strategic plan in collaboration with partners that covers the period 2023-2026 and aligns with DHSC priorities.
- We will produce an integrated business plan that covers the period 2023-24 for the 2023-24 financial year.
- We will develop the performance management approach that underpins the new strategy.
We will continue to work with NHS partners to build strong counter fraud relationships
Key areas of focus
- We will continue to work with NHS partners to build an effective relationship with Integrated Care Boards and the counter fraud community to ensure that the counter fraud agenda is embedded in these new bodies.
- We will provide support to the COVID-19 Inquiry, liaising with the inquiry team when requested and undertaking work that enables the inquiry to establish its core base of information.
Improved alignment of our priorities with our control strategy and intelligence base to drive improved outcomes across the counter fraud landscape
Key areas of focus
- We will continue to develop the SIA and other intelligence products to provide strategic direction in countering fraud and to improve coordination across the counter fraud response.
- We will enhance intelligence where there are gaps in our knowledge.
- We will develop clear partnership delivery plans against the annual SIA.
- We will ensure full integration of the Control Strategy in our integrated business planning approach.
- We will continue to produce and evolve our COVID-19, quarterly, strategic, and financial threat assessments to ensure they continually develop as a valuable asset in countering fraud together.
- We will develop our online fraud reporting system, to make reporting easier and drive process efficiencies internally that will improve our intelligence for the NHS.
- We will record and report the proportion of allegations converted to investigations and improve this by 4% in 2022-23 with our ambition to extend and report on a broader range of outcomes.
Strategic Objective 2
We will work with partners to reduce fraud loss in the NHS
With our counter fraud partners, we will increase the value of fraud detected and prevented across the NHS
Key areas of focus
- We will undertake the investigation of serious fraud, bribery and corruption matters that fall outside the powers, capability, and capacity of individual health bodies, or where there is a national interest requiring the national body to intervene.
- We will support and enable our local counter fraud partners to undertake all counter fraud activity and report and promote their counter fraud outcomes.
- We will undertake forensic computing services to recover digital evidence for use in criminal, civil and disciplinary proceedings, and undertake National Crime Agency (NCA) accredited financial investigation work to support our counter fraud partners across the sector.
Deliver intelligence assessments that identify fraud threats and enablers
Key areas of focus
- We will undertake loss analysis to support and enhance the intelligence picture in a range of thematic areas identified in the SIA, specifically pension fraud, and Real-Time Exemption Checking (RTEC).
- We will undertake an impact assessment of counter fraud solutions deployed within the thematic area of patient fraud.
Continued collaboration with our counter fraud partners within arm’s-length bodies (ALBs) to reduce the vulnerability of the NHS to fraud
Key areas of focus
- We will continue to work with our ALB partners to prevent, detect and recover losses to fraud.
- We will also engage and support our counter fraud partners within ALBs whilst recording the impact of counter fraud work undertaken across the sector.
Building and delivering data analytical capability and approaches to support the detection of fraud
Key areas of focus
- We will undertake further analysis of fraud within dental systems and deliver counter fraud activity and intervention together with key partners.
- We will deliver analysis and intervention required to support changes to policy, working with partners to influence policy changes to eliminate specific system weaknesses.
We will undertake prevention activity in the thematic area of payment diversion fraud
Key areas of focus
- We will lead a system wide response to payment diversion fraud in the NHS.
- We will lead and collaborate with colleagues and stakeholders in the NHS and other agencies to reduce the threat and measure the impact of this crime.
Strategic Objective 3
Enable our people to be the best in their roles and feel valued
Refine our smarter working principles, encompassing organisational evolution
Key areas of focus
- We will embed the principles of smarter working across the organisation through the use of collaborative digital technology, alignment to agile estates access and a flexible workforce.
- We will realise 100% of the workforce adopting smarter working principles by virtue of combined home and office-based working and wider consideration of ad-hoc NHS workspaces.
Establish a Human Resources (HR) function that supports and enables our people-processes and provides technical people-related expertise
Key areas of focus
- We will establish appropriate in-house (or hybrid) HR services that will enable and support all areas of our human resource management.
- We will develop a sustainable approach to workforce and succession planning aligned to our people strategy, such as learning and development, coaching and talent management.
- We will deliver a portfolio of people related activities, including policy development, reward and recognition, analysis of organisational health and management data, wellbeing and equality, diversity and inclusion initiatives.
Empower our people to innovate by creating a safe and supportive environment to develop and implement new ideas
- We will achieve a 10% improvement on the 2021-22 people survey in how our people feel they are led.
- We will achieve a 10% increase in our people satisfaction rating from the 2021-22 people survey.
- We will ensure 90% of our people with identified Learning & Development requirements are able to access relevant programmes.
Strategic Objective 4
Effective use of resources
Managing our existing budget and exploring additional funding opportunities by demonstrating positive financial impact
Key areas of focus
- We will manage our existing and strive to secure additional funding to support improved financial outcomes across the counter fraud community.
- We will account for a 15% reduction in our estate’s footprint, with alignment to the Government’s Places for Growth principles.
- We will monitor the cost of travel and subsistence baseline as we emerge from the pandemic and implement new models of working to agree a revised baseline position for 2023-2026.
Embed effective performance, programme, and project management approaches to drive delivery of our priorities
Key areas of focus
- We will continue developing our programme and project management approach, embedding a consistent approach to managing our delivery.
- We will continue to demonstrate robust governance, assurance, and performance.
Optimise business solutions and IT infrastructure that supports current and future delivery of our counter fraud response
Key areas of focus
- We will enhance the business tools, systems and solutions that support our work: for example, analytical tools, communication and information services, data collections, bespoke IT solutions, security, and collaboration tools to support smarter working in an agile workforce.
- We will drive our cloud first agenda in order to benefit from flexibility to scale, improved security and to enable agile and flexible working.
Our portfolio of key corporate projects
Through our Integrated Business Planning process, the following have been identified as the key projects for the organisation scheduled for delivery/commencement during 2022-23. These areas of work will be governed by a combination of project boards, highlight reports and strategic updates during the performance cycle and accountability process. All of this will be visible on the organisation’s performance, programmes, and portfolio management system.
We will also deliver a programme called Building a Better NHSCFA - Evolving Together that will influence all areas of business delivery and strategic objectives.
The programme is to challenge and facilitate efficiencies and improvements in service delivery for the sustainable future of the organisation.
We will also ensure that the organisation remains fit for purpose within a flexible, agile operating model designed for the future. The specifics of the programme are to:
- Deliver a new blueprint for the way the organisation operates.
- Collaborate with all service areas and identified stakeholders to ensure a successful transition from the current state to the future state.
- Facilitate and support the organisation and its sponsor to deliver the organisational transformation required to successfully operate.
- Deliver financial stability and sustainability for the organisation, now and into the future.
This has been captured under effective use of resources.
2022-2023 Objective | Key Corporate Project/Project Lite/Programme(s) |
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Lead and influence the prevention, detection and reduction of NHS fraud and recover financial loss for the health sector to invest in patient care. |
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We will work with partners to reduce fraud loss in the NHS. |
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Enable our people to be the best in their roles and feel valued. |
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Effective use of our resources. |
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NHSCFA programmes and projects will be delivered in two distinct ways:
- Full governance incorporating a project board and managed reporting of workstreams and activities under the direction of a Senior Risk Owner within the organisation.
- *The Lite approach, which is similar to that operating within full governance but without the need to report to a central board. The work will still be delivered under a project management framework for reporting and accountability.