As the health sector continues to evolve, counter fraud capability must remain effective, targeted and sustainable. Increasing complexity of healthcare provision, decentralised delivery models and changing system structures require a clear, risk-based approach to ensure counter fraud resources are deployed where they generate the greatest impact and return on investment. In 2026–27, our focus will be on exploring a new target operating model that is sustainable, intelligence-led, empowered to take appropriate action, and aligned with emerging NHS structures, strengthening the system’s ability to prevent, detect and respond to fraud risk effectively.
To deliver this, we will:
- review current counter fraud capacity and capability to understand gaps in provision to better meet the needs of the 2026-29 Health Service Counter Fraud Strategy
- explore alternative health-wide counter fraud operating models with DHSC as the national counter fraud landscape changes, ensuring they are sustainable, flexible and aligned with the future NHS landscape ensuring clearer roles, responsibilities and accountabilities at national, regional and local levels
- investigate revenue opportunities to achieve a sustainable counter fraud operating model
- establish clearer prioritisation approaches to focus counter fraud resources on the highest-risk and highest-impact activities, informed by the SIA, fraud risk assessments and fraud loss measurement
- provide oversight of the delivery and assurance of Year 1 counter fraud savings
- start conversations to strengthen counter fraud powers and mechanisms, including potential legislative considerations to improve adherence, deterrence and recovery
- develop organisational strategies required to enable delivery of a new operating model, including digital, people and financial planning to support delivery of the 2026-29 Health Service Counter Fraud Strategy
By March 2027, this work will have resulted in:
- completion of a gap analysis in counter fraud skills needed to deliver the new strategy
- proposals developed for operating principles and accountabilities, improved clarity on counter fraud roles, responsibilities and expectations across national, regional and local functions, embedding greater consistency of approach
- a defined approach for prioritisation to allow risk-based decision making on counter priorities, realising better alignment between resources, fraud risk and return on investment
- initial discussions held on additional powers for improved counter fraud outcomes
- delivery and assurance of agreed Year 1 counter fraud savings
- delivery of agreed Year 1 activity to develop enabling strategies for workforce, digital and financial planning, laying the foundations for Years 2 and 3 of the strategy