2024 to 2025 delivery plan

NHSCFA's delivery plan broken down by its strategic pillars.

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 two combined minimum financial impact on fraud will be a minimum of £126m. 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 (EFRA) 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 and to inform future development opportunities
Key area of focus (year 2) Deliverables
A strengthened intelligence picture

Develop our intelligence to close gaps in knowledge in key areas of fraud within the NHS, thereby increasing our confidence to make our response to fraud more effective

Produce an annual Strategic Intelligence Assessment (SIA) to estimate financial vulnerability, identify threats and evaluate the risk of fraud to the NHS

Continue the Enterprise Fraud Risk Assessment (EFRA) to include development of risk tolerance, risk appetite, identification of additional thematic areas and capture emerging fraud risks. (TBC subject to funding)

Enhance the referral, collation, and dissemination of information Following the successful enhancement of the key areas of focus in year one, we will ensure the embedding process is conducted via monitoring and maintain the challenging timelines from receipt of intelligence to decision and dissemination to relevant parties
Improved learning from intelligence reports Delivery of organisation level Learning Reports to share opportunities for intervention and prevention with stakeholders across the NHS nationally
Continue to innovate the mechanisms for fraud reporting Deliver and embed the Online Fraud Reporting (OFR) system into the NHSCFA
Lead the application of advanced data analysis techniques in countering fraud in health Apply the skills and capabilities within the NHSCFA to tackle the most serious areas of fraud, areas identified through the Control Strategy and the Fraud Risk Assessment
Drive the use of data to support our understanding of fraud and drive key decision making in the counter fraud community Embed and improve our insight and reporting capabilities that will inform and support the counter fraud community
Continue to strive for access to additional key datasets and collaboration with key partners in using data and systems for counter fraud purposes.

Develop and deepen partnership working to secure data access, whilst also maintain existing sharing and practice agreements for key datasets and systems

Collaborate with partners to embed 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 promote the fraudproofing 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 area of focus (year 2) Deliverables
Engage with emerging legislation which is relevant to our function Interpret Home Office guidance to the sector to support the adoption of the Failure to Prevent Fraud Offence introduced under the Economic Crime and Transparency Act 2023
Apply strategic tasking to areas of fraud risk Develop and implement coordinated fraud prevention campaigns to tackle areas of specific strategic targeted risk
Provide fraud prevention support through horizon scanning and system weakness

Evaluate our horizon scanning processes to ensure we are improving our strategic awareness and that we are responding quickly to emerging threats

Issue fraud prevention guidance to the sector when required and provide advice on fraud proofing existing systems

The NHSCFA will explore solutions and advise on the introduction of a central fraud register for the NHS

Support local fraud prevention activity

Provide direct support and advice in respect of local proactive exercises

Provide timely information to our stakeholders on identified system weaknesses to proactively prevent fraud

Provide timely and effective counter fraud guidance to inform and enable a local counter fraud response

Develop a counter fraud culture across the NHS

Deliver a targeted webinar programme to inform and support our stakeholders in their counter fraud efforts

Establish and deliver a programme of face-to-face regional stakeholder liaison events to communicate and facilitate a counter fraud culture

Continue to maintain a quarterly bulletin for our stakeholders

Undertake a systematic Enterprise Fraud Risk Assessment to identify, assess, prioritise and mitigate potential fraud risks In collaboration with our stakeholders, develop and agree effective action plans across identified priority areas of vulnerability
Ensure new systems, processes and major programmes adopted by the NHS have a counter fraud response from the outset Provide expertise and collaborate with key partners to support the delivery of the appropriate counter fraud respond
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 to develop capability and capacity to respond to fraud
  • We will develop our analytical capability to provide insight that presents patterns in data that are indicative of fraud
Key area of focus (year 2) Deliverables
Bring the national and local counter fraud response together through the establishment and operation of the NHSCFA Fraud Hub

Embed and improve our Fraud Hub enforcement function, providing support and enabling an improved counter fraud enforcement response at a local level

Embed and improve our Fraud Hub prevention function to provide support and enable an improved counter fraud prevention response at a local level

Embed and improve our Fraud Hub stakeholder engagement and relationship management function to continue to develop a collaborative counter fraud community within the NHS

Embed and improve our Fraud Hub case management function, providing a case management process to capture and realise the activity and impact of all counter fraud activity in the NHS

Embed and improve our Fraud Hub internal training function, providing an ongoing learning and skill development capability to the NHSCFA

Strategic Tasking and Tactical Tasking Coordinating Group

Coordinate and resource areas of activity agreed with key counter fraud partners to maximise impact across the NHS that will contribute towards the health group’s financial achievements

Produce an agreed strategic action plan with key counter fraud partners to tackle priority areas of new and emerging fraud

Increase opportunities for prevention

Improved integrated response to intelligence and horizon scanning, data analysis and learning from enforcement

Tackle areas of fraud risk vulnerability by producing timely and effective Fraud Prevention Notices and Intelligence Bulletins to enable counter fraud action by our stakeholders

Work collaboratively with partners to provide assurance through shared resources, capabilities, and expertise

Provide an effective national counter fraud enforcement response

Where an instance of serious fraud, bribery and corruption is identified, undertake national enforcement activity to address the fraud

Achieve improved outcomes in the financial impact of NHSCFA enforcement activity

Continue to develop a highly skilled NHSCFA 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

Provide a responsive expert digital forensic capability to support criminal investigations in England, Wales and Scotland through a digital forensic unit operating framework and extending the current scope of accreditation

Deploy accredited financial investigators and financial intelligence officers to support the progress of criminal investigations across the NHS and utilise powers under the Proceeds of Crime Act to recover NHS funds obtained through fraud and return them to the NHS for the provision of patient care

Support enforcement activity at a local level

Support the NHS to improve the value of recorded financial outcomes realised from counter fraud enforcement work undertaken locally and enable health bodies to pursue all appropriate sanctions where fraud is identified

Innovate in the use of data Proactively use data to deliver an innovative enhanced analytical capability which provides novel insights to identify patterns in data 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 requirements
  • 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 Department of Health and Social Care (DHSC) and the Public Sector Fraud Authority (PSFA) 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 area of focus (year 2) Deliverables
Support compliance with the Government Counter Fraud Functional Standard Enable and support health bodies to achieve and improve compliance with the Government Functional Standard ‘GovS 013: Counter Fraud’
Access and report sector standards returns Produce comprehensive and accurate information about standards returns, ensuring consistency and accuracy that reflects work undertaken by the sector
Develop and improve our Case Management System

Improve the intelligence functionality of our Case Management System to identify trends and aid dissemination

Continue to develop and provide detailed performance information across the health group to drive improvement activity

Provide assurance to the Department of Health and Social Care

Review and deliver compliance with the DHSC/NHSCFA performance framework

Incorporate the impact on counter fraud resulting from error and corrective action

Assess our stakeholder engagement Assess our stakeholder engagement and demonstrate an improvement on the baseline established in 2023 to 2024 by undertaking targeted survey work, assessing qualitative feedback and observing performance outcomes
Assure against our governance

Assure ourselves against the requirements of the Govs 013 Functional Standard

Develop and deliver a Continuous Improvement and Assessment Framework to address any gaps in assurance

National and international collaboration enhances our role as the national body for NHS counter fraud Continue to collaborate nationally with our Four Nations colleagues, share in best practice and responses. Strengthen relationships with our international partners in leading in health-related fraud prevention, enforcement and recovery
Strategic Pillar - People
Strategic objective – 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 foundation 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 area of focus (year 2) Deliverables
Make the best use of people and skills through strategic workforce planning Enhance recruitment and onboarding processes, underpinned by monitoring and improvement metrics in each area as directed by the People and Workforce Development Strategy
Ensure the HR advisory is well-qualified, responsive, proactive, and collaborative

Embed and further develop the HR operating model and team/operational structures, contained in NHSCFA’s People and Workforce Development Strategy in this financial year

Continue to simplify, streamline, and refine the number of HR policies and processes, ensuring consistent application

Develop visible, positive, confident, and enthusiastic leaders who exemplify our values

Identify any emerging gaps and develop the skills needed at different leadership and management levels and designing/ providing access to development as appropriate

Publicise and train the leadership and management model (Leadership Essentials) and continue to embed values and behaviours (LIFE), guiding their application in a supportive and inclusive programme

Deliver a workplace where people are proud of the work we do and feel included, valued and fairly and equally supported for their efforts

Pursue accreditations that evidence the NHSCFA as an employer that attracts and retains, creating a truly inclusive environment appropriate to the modern workplace.

Implement the NHSCFA Wellbeing Strategy for our people.

Deliver a refreshed performance management structure that sets clear and fair expectations, supported and informed by organisational health and management data to aid delivery and decision making

Continue to embed the competency and behaviour framework underpinned by our LIFE Values and Behaviours Framework

Review and improve the provision of the people related performance data made available to management, ensuring it is being used to support improvement

Introduce and embed our succession planning process, identifying skills gaps and potential talent for development

Personal and professional development for all staff to build on existing potential Embed and improve the use of technical education and development, exploring the use of technology, delivering an inclusive, engaging and cost-effective way to build skills and capabilities
Strategic Pillar - Resources
Strategic objective – Ensuring we use our resources in an innovative and agile way to support and deliver counter fraud activity within the NHS
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 mechanisms 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
  • Ensure our IT will fully support our operational delivery and future ambitions around advanced analytical capability
  • Ensure our IT will protect the NHSCFA from risks, threats and vulnerabilities we face from cyber-attacks
  • Continually explore technology to enable business success
Key area of focus (year 2) Deliverables
Enable and support procurement

Ensure the organisation has appropriate access to a procurement process, providing support as requested

Develop and implement an appropriate future model to ensure timely access to legal and contractual support

Deliver the NHSCFA integrated business planning process

Deliver a flexible business planning approach, emphasising the incorporation of a lessons learned process

Use our data to inform key decision making; enhancing and transforming the way we use information in the organisation

Review our priorities to support our planning and strategic delivery and ensure delivery and accountability for action taken within this plan

Define the process to develop and deliver our new strategic delivery for 2026 to 2029 during this business planning year

Enhance our approach to prioritisation through the integrated planning approach

Embed our Design Authority within the establishment and management of our key projects and programmes

Establish and enhance our Return On Investment (ROI)

Embed the developed model to quantify the organisation’s Return On Investment (ROI) in countering fraud and enabling services

Demonstrate business line reporting to enhance ROI from base line reporting to improve decision making

IT infrastructure and optimised business solutions

Embed and optimise technology infrastructure and scope, develop, and deliver new business solutions to deliver a transformed and agile technology service

Continue to review our technology environment to support and optimise the delivery of our Digital Strategy

Continue to provision technical solutions to benefit and enhance business needs

Identify the cyber security threats the NHSCFA faces, learn from attempts made to compromise systems, and those prevented

Exploration of new and emerging technologies to support effective and efficient operational delivery

Implement the supported recommendations following completion of the Technology Review

Continue to develop and implement our Customer Relationship Management (CRM) system

Strengthening our governance

Delivery of our governance and audit requirements

Take a risk-based approach to our assurance practices

Continue the development of ‘supporting our governance’ processes / management functions

Demonstrable improvement in the timely implementation of audit recommendations

Strong financial management and controls

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 if required

We will maintain our sustainable longterm financial plan, developing it further as required

In partnership with internal and external stakeholders, support business cases development in preparation for funding opportunities

Deliver a robust performance programme and project management across the NHSCFA

Deliver and promote a service catalogue that outlines the service and capabilities offered by our Project Management Office (PMO) to support the delivery of our strategic objectives

Focus on improving the mobilisation of projects and the delivery of capabilities and benefits

Develop and enhance the organisations PMO Competency Framework to enable delivery, strategy and capability

Continue to develop practices, people, tools and knowledge across the NHSCFA

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 an agile and fit for purpose infrastructure for the NHSCFA

Collaboration with stakeholders

Deliver strategic and operational corporate communications

Continue to provide strategic and operational communications support to the NHSCFA

Embed and improve a targeted fraudfocused communications strategy for our stakeholders

Establish and improve systems and processes to ensure effective delivery of communications both internally to our people and externally across the sector to support organisational deliverables

Optimise the physical and virtual environment where our people work

Deliver an efficient use of space, resources and technology to enhance productivity and collaboration

Manage the policies, procedures and practices that prioritise the wellbeing of individuals, the prevention of accidents or incidents, and the protection of the environment

Agree and implement strategies and procedures to ensure the NHSCFA can continue its essential functions and recover quickly from disruptions

Introduce and embed policies, procedures and practices to meet social responsibility requirements

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