2023-24 delivery plan

NHSCFA's delivery by strategic pillar.

Within this plan we will achieve a fiscal impact on fraud that will contribute to the three-year strategic target of £500m. This will be a combination of initiatives and activities resulting from fraud prevention, fraud detection and fraud recovered.

Counter fraud financial impact will be driven by partnership working in key agreed areas within the strategic tasking and coordinating process to maximise counter fraud impact. We estimate that our year one combined minimum financial impact on fraud will be a minimum of £138m. This also includes counter fraud impact delivered locally and within Arm’s Length Bodies.

Strategic Pillar - Understand
Strategic Objective - Understand how fraud, bribery, and corruption affects the NHS.
Strategic Actions over the life of the strategy (year 1-3)
  • Produce a comprehensive assessment of the threat and effect of fraud against the NHS together with an identification of opportunities to respond to them from intelligence
  • Deliver a comprehensive intelligence gathering and dissemination function to support all parts of the NHS to evaluate, initiate and deliver an appropriate and effective operational response to fraud
  • Develop and maintain an enterprise level Fraud Risk Assessment (FRA) which proactively identifies, describes, and assesses the risks to fraud across the NHS, and identifies and evaluates mitigating controls
  • Enhance our data analytical function to generate insight and counter fraud action from patterns in data indicative of fraud
  • Develop and maintain a comprehensive assessment of the capacity and capability of the NHS to respond to counter fraud threats, to inform future development opportunities
Key areas of focus (year 1) Deliverables
Continue to improve the organisation’s intelligence picture on Threats, Vulnerability and Enablers to fraud
  • Improved knowledge in key areas of fraud within the NHS by addressing intelligence gaps where possible – increase in confidence in key areas
  • Production of the annual SIA
Standardise dissemination and collation of information for intelligence purposes
  • Improved timeliness from receipt of intelligence to decision and dissemination to relevant parties
Continue to develop mechanisms for fraud reporting to the NHSCFA with the implementation of smarter online systems
  • Improved automation of the online fraud reporting system into the NHSCFA developed in 2022/23
Undertake horizon scanning for new and emerging risks across health
  • Proactively conduct horizon scanning and continue to develop its effectiveness across the NHSCFA
Continue to develop advanced data analysis techniques to tackle complex fraud problems with data
  • Develop the skill and capabilities within NHSCFA to use advanced data analysis techniques e.g. Machine Learning
Utilise data to support our understanding and drive key decision making
  • Continue to develop and refine our insight and reporting capabilities that will inform and support the counter fraud community
Actively pursue access to data and systems that will be used for counter fraud purposes
  • Complete a range of sharing and practice agreements across health to key datasets and systems
  • Collaborate with partners to develop business systems that will provide key analytical capabilities

Strategic Pillar – Prevent
Strategic objective – We will ensure the NHS is equipped to take proactive action to prevent future losses from occurring.
Strategic actions over the life of the strategy (year 1 – 3)
  • develop, co-ordinate and lead a fraud prevention and deterrence programme for the NHS
  • coordinate and lead robust fraud prevention and deterrence activities across the health group to protect the NHS from fraud losses
  • proactively promote a counter fraud culture within the NHS that develops fraud awareness and understanding across all areas of spend
  • develop and share good practice and lessons learned from all aspects of counter fraud activity in the NHS
  • influence the delivery of Fraud Risk Assessments and Initial Fraud Impact Assessments across areas of NHS expenditure and promoting the fraud-proofing of all NHS systems and processes
  • the innovative use of data to support the opportunities for prevention across key areas of business by designing, developing and delivering proactive analysis
  • develop a targeted fraud-focused communications and deterrence strategy
Key areas of focus (year 1) Deliverables
Fraud prevention activity directed by strategic tasking considerations
  • coordinated fraud prevention campaigns in areas of specific and targeted risk
Development of a comprehensive horizon scanning process and system weakness identification process
  • development of a comprehensive horizon scanning process integrated with priority setting and planning
  • provide lessons learned intelligence to the sector in the form of dynamic fraud prevention guidance and advice on fraud proofing existing systems
Directly support fraud prevention activity at a local level through the Fraud Hub
  • provide direct support and advice in respect of local proactive exercises
  • provide dynamic information on system weaknesses that are an enabler of fraudulent activity
  • provide a high standard of counter fraud guidance to the local counter fraud response
Develop a programme of engagement supporting the promotion of a counter fraud culture across the NHS
  • development of a webinar programme to support counter fraud activity
  • delivery to non-fraud specialists but targeted at subject matter experts and risk owners
Identify the programme of fraud risk assessment across the NHS
  • development with stakeholders, action plans developed across priority area of identified vulnerability
Exploratory use of data to inform future prevention opportunities
  • proactively using data to provide prevention opportunities

Strategic Pillar – Respond
Strategic objective – When we know that fraud has occurred, we are equipped to respond.
Strategic actions over the life of the strategy (year 1 – 3)
  • use our understanding of fraud to develop a control strategy, agree priorities, develop action plans, manage strategic and tactical tasking of resources and close intelligence gaps
  • through developing a response to allegations of fraud we will prioritise prevention and disruption to reduce harm and loss
  • we will conduct and support, criminal, financial and corporate investigations to establish whether a) fraud, bribery or corruption has occurred b) determine or influence appropriate action/sanctions and c) initiate recovery of funds lost
  • we will provide support, advice and guidance to the counter fraud community in developing capability and capacity to respond to fraud.
  • we will develop our analytical capability to provide insight that presents patterns in data indicative of fraud
Key areas of focus (year 1) Deliverables
Launch of the NHSCFA Fraud Hub
  • establishing a new function to provide support and enable an improved counter fraud enforcement response at a local level
  • establishing a new function to provide support to and enable an improved counter fraud prevention response at a local level
  • establishing a new stakeholder engagement and relationship management function to develop a more collaborative counter fraud community within the NHS
  • establishing a new function to provide an improved case management process to capture and realise the activity and impact of all counter fraud activity in the NHS
Together with partners lead both the strategic tasking and tactical tasking coordinating groups to agree priorities and areas of new and emerging fraud to tackle
  • coordinated and resourced areas of activity agreed with key counter fraud partners to maximise impact across the NHS that will contribute towards the health group financial achievements
  • production of an agreed strategic action plan
Increase opportunities for prevention
  • improved integrated response to intelligence and horizon scanning, data analysis and learning from enforcement
  • produce timely Fraud Prevention Notices, Intelligence Bulletins to enable counter fraud action
Provide an effective national counter fraud enforcement response
  • Undertake national enforcement activity in all instances of serious fraud, bribery and corruption
  • Improved outcomes in both the financial and deterrent impact of NHSCFA enforcement activity
  • Develop a highly skilled enforcement workforce through a robust programme of Continuous Professional Development
  • Provide high levels of assurance relating to enforcement activity via a robust quality management system applied to investigations
  • Extend current scope of accreditation to provide a responsive expert digital forensic capability to support criminal investigations in England, Wales and Scotland
Directly support enforcement activity at a local level through the Fraud Hub
  • Improved financial and deterrence outcomes from local NHS enforcement activity
Innovate using data to support of counter fraud response
  • Scope and develop enhanced analytical capability to proactively find novel insight that may be indicative of fraud

Strategic Pillar – Assure
Strategic objective – We can assure our key partners, stakeholders and the public that the overall response to fraud across the NHS is robust.
Strategic actions over the life of the strategy (year 1 – 3)
  • measure, assure and report health bodies’ compliance with the Government Functional Standard GovS 013 and NHS counter fraud provisions
  • provide a robust evidence base demonstrating the positive impact of the NHS counter fraud response and championing the work undertaken in the NHS counter fraud community
  • provide and manage a case management system and reporting tool for the NHS to ensure all counter fraud activity and outcomes are captured
  • provide assurance to the DHSC and PSFA that the reported information relating to fraud affecting the NHS (threat levels, response activity and measurable outcomes) have the highest level of validation and statistical integrity
  • lead the NHS counter fraud community to drive measurable improvements in the counter fraud response through collaborative partnerships
  • protect NHS funds through the reduction of vulnerability to fraud and reduction of losses
  • continued development of the NHS counter fraud community
Key areas of focus (year 1) Deliverables
Ensure that health bodies complete and return the required functional standards (GCFFS)
  • full compliance with the Government Functional Standard GovS 013
Assessment of information provided within the submitted standards return,ensuring consistency and accuracy
  • comprehensive and accurate information that reflects work undertaken by the sector
Ongoing development of the case management system to incorporate additional functionality that will support the counter fraud response
  • intelligence functionality incorporated within our case management system
  • continue to develop and provide detailed performance information across the health group to drive improvements
Providing assurance to the DHSC and the PSFA that the reported information relating to fraud in the NHS (threat levels, response activity and measurable outcomes) has the highest level of validation and statistical integrity. Provide value to the DHSC by protecting NHS funds through the reduction of vulnerability to fraud and the reduction of losses
  • positive external validation and assurance of our processes, practice and verification of values including new methodologies that are subject to challenge
  • work with DHSC colleagues to agree validation processes of new methodologies used to demonstrate the impact of prevention, detection, and recovery
Assess the training and development needs for the NHS counter fraud community
  • we will explore an appropriate method of delivering training to target audiences
Enable health bodies to provide meaningful reports to their audit committees
  • provide a framework providing all necessary detail to allow audit committees to be able to have an informed view of local counter fraud activity
Undertake a measurement of our stakeholder engagement to assess its effectiveness
  • assess our stakeholder engagement and demonstrate an improvement on the baseline

Strategic Pillar – People
Supporting our people in an innovative and agile way to underpin and deliver counter fraud activity within the NHS.
Strategic actions over the life of the strategy (year 1 – 3)
  • a sustainable approach to workforce and succession planning aligned to our People and Workforce Development Strategy to include recruitment and retention initiatives, opportunities for learning and development and access to coaching and mentoring
  • building skills and capabilities to be future fit and recruiting in a smart and targeted way
  • investing in people to achieve a return on that investment
  • managing talent within the organisation and seeking new and emerging expertise where required
  • build on strong, safe, legal, and best practice foundations to enable us to deliver a comprehensive, diverse and inclusive portfolio of people related activities
  • being a flexible and collaborative “One Team” of professionals who are driven by our Vision, Purpose and Values and Behaviours in order to deliver, which is underpinned by personal performance
Key areas of focus (year 1) Deliverables
Strategic Workforce Planning
  • improve recruitment and onboarding processes (underpinned by monitoring and improved metrics in each area as directed by the HR Strategy)
Responsive and Proactive HR Services
  • develop the HR operating model and team/operational structures
  • set the parameters for communication into, within and out of HR and develop the internal HR Advisory Service
  • develop skills, qualifications, and training
  • review and where possible simplify, streamline, and refine the number of and depth of HR policies and processes and ensure consistent application
Inclusive and Effective Leaders and Managers at All Levels
  • define the skills needed at different leadership and management levels
  • develop leadership and management model and behaviours
  • provide access to off-the-shelf management and leadership development programmes, seeking/accessing funding, and support where possible
  • develop and adopt a 360-degree feedback approach for managers and leaders
A Great Place to Work
  • adopting the principles of ‘A Great Place to Work’
  • develop communications approach and people recognition practices
  • develop inclusive and responsive recruitment activities that engage prospective employees from application date
  • develop and or review welcome/inductions programmes for new joiners
  • develop a wellbeing strategy for our people to include a range of support initiatives, improve health, reduce stress, and build resilience
  • promote ‘Time to Change’ as a wellbeing and mental health awareness initiative
  • develop and/or review policies and processes that are intended to improve fairness, dignity and respect within the workplace and encourage a ‘speak up’ culture without fear of retribution through education and communication
  • review recognition and benefits as a package
Delivering Great Performance
  • review appraisal process and improve the rate and quality of appraisals across our workforce
  • develop and/or review the competency/behaviour framework
  • determine parameters for the collection of high quality and reliable performance data and how to make it available to management to support improvement
  • implement a talent management system identifying “Star” talent for development
Building Skills and Capabilities
  • support employees in new roles post Evolution
  • adopt best practice approaches in statutory and mandatory training
  • establish where skills gaps exist and establish whether skills can be trained/learned or need to be recruited for
  • explore and improve the use of e-learning

Strategic Pillar – Resources
Strategic objective – We can assure our key partners, stakeholders and the public that the overall response to fraud across the NHS is robust.
Strategic actions over the life of the strategy (year 1 – 3)
  • ensure access to flexible contract and procurement support
  • develop a flexible approach to strategic, business and resource planning
  • develop the right working partnerships regardless of the sector they are from
  • develop a sustainable long-term financial plan
  • develop mechanism that demonstrate return on investment
  • understand and enable all appropriate routes for counter fraud activity to take place
  • prepare for future delivery and changes in counter fraud approaches
  • ensure our IT infrastructure, systems and people are developed to ensure maximum business impact
  • adhere to and develop our governance and assurance practices
  • our IT will fully support our operational delivery and future ambitions around advanced analytical capability
  • our IT will protect the NHSCFA from risks, threats, and vulnerabilities we face from cyber attacks
  • continually explore technology to enable business success
Key areas of focus (year 1) Deliverables
The ability to manage procurement efficiently and effectively
  • appropriate access to procurement support.
  • Legal and contractual support in place
  • development and implementation of our Customer Relationship Management (CRM) system
Integrated Business Planning
  • flexible business planning approach
  • allocation of resource when required to support strategic and operational aims
  • using data to inform key decision making and verification key methodologies
  • review our priorities to support our planning and strategic delivery and ensure delivery and accountability for action taken within this plan
  • NHSCFA will prepare for new strategic delivery within the next business planning year
Collaboration working and joint initiatives
  • working with partners to bring efficiencies of shared resource, capabilities, and expertise
Return on Investment (ROI)
  • Development of the appropriate mechanism to demonstrate Return on Investment (RoI) in countering fraud and enabling services
  • Demonstrate business line reporting to enhance RoI
IT infrastructure and optimized business solutions
  • Scope, develop and deliver a transformed and agile IT service following review
  • IT environment supports future delivery with Cloud technology at the core
  • Continue to provision technical solutions to benefit and enhance business need
  • We know of the external threats the NHSCFA faces and digital threats, attempts made and prevented
  • Exploration of new and emerging technologies to support effective and efficient operational delivery
Our Governance
  • Further development of our governance processes and practice
  • Delivery of our governance and audit requirements
  • Continue to enhance our assurance practices
  • Demonstrable improvement and timely management from audit recommendations
  • We will manage our existing budget and strive to secure additional funding to support improved financial outcomes across the counter fraud community
  • We will develop and implement organisational cost improvement programmes where required, ensuring capitalisation of areas of efficiency
  • Development of a sustainable long-term financial plan
  • In partnership with internal and external stakeholders develop business cases in preparation for funding opportunities
Performance, Programme and Project management approaches to drive and deliver priorities and continued improvement
  • Development of a service catalogue that supports strategy, delivery, and capability of the NHSCFA
  • Development of a performance culture (year 1 of 3)
  • Defining the PMO evolutionary roadmap
  • Developing practices, people, tools, and knowledge across the NHSFCA
Transformation to benefit countering fraud in the NHS
  • Facilitate the continued transformation of the NHSCFA to maximise impact on fraud within NHS and wider health sector
  • Delivery of a fit for purpose infrastructure, IT, Estates, People and counter fraud impact
  • Collaboration with partners
  • Provision of strategic and operational communications support to the NHSCFA
  • Developing a targeted fraud-focused communications strategy
  • Review of systems and processes to ensure effective delivery of communications both internally to our people and externally across the sector

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