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 actions over the life of the strategy (year 1 – 3) |
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| 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 actions over the life of the strategy (year 1 – 3) |
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| 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 actions over the life of the strategy (year 1 – 3) |
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| 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 actions over the life of the strategy (year 1 – 3) |
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| 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 actions over the life of the strategy (year 1 – 3) |
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| 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 actions over the life of the strategy (year 1 – 3) |
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| 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 |