Objective 1: Driving prevention by design to build a fraud resilient NHS

Our focus will be building on frameworks, relationships and tools required to embed fraud-resilience design into national and local systems, processes and decision-making.

Preventing losses to fraud before they occur is the most cost-effective and sustainable way to protect NHS resources. As the health sector undergoes large-scale reform, there is an opportunity to ensure that fraud prevention is built into the whole system. In 2026–27, our focus will be on building on the frameworks, relationships and practical tools required to continue to embed fraud-resilient design into national and local systems, processes and decision-making, so that prevention becomes a routine and expected part of how services are developed.

To deliver this, we will:

  • identify and assess fraud vulnerabilities in priority high risk national and local schemes, including identified capital and infrastructure programmes providing targeted counter fraud advice, embedding of fraud prevention principles, capability and the inclusion of proportionate fraud prevention and detection controls at the point of initiation
  • work collaboratively with and influence ICBs and health bodies to better understand local counter fraud challenges due to their unique system factors, building fraud prevention capability through piloting ‘Counter Fraud Health Checks’, implementing quick wins and developing longer term improvement plans
  • promote existing and develop further practical counter fraud tools, frameworks and guidance to influence policy development, commissioning and service redesign, aligned to GOVS013 counter fraud standards
  • ensure health organisations have a robust response to the failure to prevent fraud requirements from the Economic Crime and Corporate Transparency Act 2023
  • start to engage the DHSC and PSFA on the development of local performance standards
  • strengthen existing and establish new national and regional partnerships for fraud prevention, working collaboratively with system leaders to identify and address fraud vulnerabilities, influence system design and promote the adoption of proactive fraud resilience, practice and tools
  • where fraud has occurred, provide targeted support, overseeing improvement plans and sharing learning from investigations with the sector

By March 2027, this work will have resulted in:

  • selected priority national schemes having clearer visibility of their fraud risk profiles, early identification of proportionate mitigations to enable effective fraud prevention and strengthened confidence and capability in managing fraud risk
  • relationships between NHSCFA, national programmes and regional system leaders being stronger and more structured, enabling earlier and more constructive engagement on fraud prevention
  • participating ICBs having an improved understanding of their fraud prevention responsibilities, maturity, key vulnerabilities and practical actions needed to strengthen local controls through Counter Fraud Health Checks. Follow ups evidence progress and strengthened controls

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