Key risks to the delivery of the Business Plan

An outline of the key risks regarding governance and oversight arrangements of the Business Plan

Robust governance and oversight arrangements, detailed later in this document, will support delivery of this business plan. However, several anticipated challenges will require ongoing review and management through regular reporting.

Key risks include:

  • funding – if confirmed funding levels fall short of expected amounts, then areas of the business plan may not be deliverable. The deliverables in this business plan may need to be adjusted, reconsidered and reprioritised, or discontinued where needed
  • data access – barriers and delays in accessing local and national datasets may limit our ability to deliver advanced analytics for fraud prevention and detection. Early engagement with stakeholders and support from DHSC and NHSE will unblock any challenges
  • alignment with the 10-Year Health Plan – as delivery plans emerge, counter fraud resources across the NHSCFA and the wider health sector must remain flexible and responsive to priority areas. This may require adjustments to this business plan, including the reprioritisation, pausing or discontinuation of specific activities where necessary
  • stakeholder collaboration – effective counter fraud activity depends on engagement from key health sector stakeholders. Competing priorities and pressure to focus on frontline delivery may limit capacity for counter fraud engagement, potentially slowing progress on culture change and prevention initiatives
  • operating model transformation – this business plan prioritises driving prevention and fraud resilience across the health sector, supported by digitalisation and performance management. Delivering this shift will require a new operating model, which may result in significant change to the wider counter fraud landscape
  • multi-year ambitions – many objectives in this business plan span several years and, in some cases, will require advocacy with government to secure the legislative or policy changes needed for delivery

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