The Strategic Pillars

NHSCFA's strategic pillars designed to ensure that the NHS is equipped to respond effectively to any threat of fraud.

Strategic Pillar – Understand
Strategic objective Understand how fraud, bribery and corruption affects the NHS.
Why it is important? The more we know how fraud affects the NHS, the more effective our response will be. We will develop and manage a range of processes, tools, knowledge and expertise to ensure we have a comprehensive understanding of the threat.
Strategic actions years 1 to 3
  • produce a comprehensive assessment of the risk, threat and impact of fraud against the NHS together with recommendations 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 (FRA) 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, to inform future development opportunities
End state 2026
  • an improved intelligence picture with increased confidence in the assessment of fraud affecting the NHS
  • timely dissemination of actionable intelligence
  • a comprehensive suite of fraud risk assessments conducted and evaluated
  • effective horizon scanning for new and emerging risks across the health sector
  • data will support our understanding and drive key decision making. This will underpin our response, prevention and assurance across the NHS

Strategic Pillar – Prevent
Strategic objective We will ensure the NHS is equipped to take proactive action to prevent future losses from occurring.
Why it is important? Taking positive action to prevent fraud from being committed is the most effective and efficient way of protecting public funds.
Strategic actions years 1 to 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 promoting the fraud-proofing 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
End state 2026
  • new systems and processes adopted by DHSC and the NHS are routinely fraud risk assessed in design
  • emerging risks are identified and responded to collaboratively across the sector through effective horizon scanning and fraud risk assessments
  • operational intelligence and lessons learned reviews inform a programme of fraud prevention action (systems weakness) data analysis is used to direct/inform prevention activity across the sector
  • focused communications campaigns and the associated impact is realised
  • promotion of impactful counter fraud activity across the system as a means of revenue protection and widely adopted across the system
  • value of counter fraud activity more widely recognised andimproved awareness and confidence in counter fraud function

Strategic Pillar – Respond
Strategic objective When we know that fraud has occurred, we are equipped to respond
Why it is important? Our response is increasingly proactive and led by our understanding of the threat. Enforcement resources are suitably trained and configured to maximise the impact of investigation.
Strategic actions years 1 to 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 in developing capability and capacity to respond to fraud
  • we will develop our analytical capability to provide insight that presents patterns in data indicative of fraud
  • timely information and intelligence are disseminated for action.
End state 2026
  • strategic priorities are agreed and the response to those priorities defined and resourced
  • action is initiated to meet intelligence requirements and performance targets are set for all key stakeholders
  • prevention and disruption activity is routinely initiated, recorded, monitored and utilised
  • investigative activity and resulting outcomes are recorded with performance monitored and published
  • NHS counter fraud professionals have awareness of and access to appropriate professional development and training
  • a reduction in vulnerability to fraud
  • our response is quantified as a demonstration of impact
  • data modelling and analytical learning will support the formulation of ‘fraud flags’ in data which are indicative of fraud
  • all investigation, risk assessment and prevention activity are comprehensively recorded on our fraud management system

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
Why it is important? The public expects the organisation to mitigate effectively against the risk of fraud. Utilising our technical expertise, impartiality and independence we will lead on providing assurance through standard setting, legislative levers, providing a sound basis for statements on loss and being the organisational voice on matters of fraud.
Strategic actions years 1 to 3
  • measure, assure and report health bodies’ compliance with the Government Functional Standard GovS013: Counter Fraud 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
  • Continued development of a case management system and reporting tool for the NHS to ensure all counter fraud activity and outcomes are captured
  • provide assurance to the Cabinet Office that 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
End state 2026
  • compliance with the Government Functional Standard GovS013: Counter Fraud has increased across all parts of the NHS
  • demonstrating a return on the investment in the NHSCFA and the wider health group
  • lead the wider health group to achieve a total value of £500m over the strategic period relating to counter fraud activity
  • methodology to deliver return on investment performance is embedded across the health group
  • provide and publish detailed performance information across the health group to drive improvements
  • increased volume and quality of information and intelligence entered onto our case management system
  • positive external validation and assurance of our process, practice and verification of values
  • international benchmarking informs our approach to continuous improvement
  • the work to tackle fraud in the NHS is one in which the national and local counter fraud response is demonstrably working in partnership within an effective professional framework

Enabling the delivery of our Strategic Pillars

To underpin our four Strategic Pillars, we have set out two further enabling Pillars

Strategic Pillar – Our People
Strategic objective Supporting our people in an innovative and agile way to underpin and deliver counter fraud activity within the NHS.
Why it is important?

Our people are the greatest asset within the NHSCFA, they provide the foundation for all work we undertake to counter fraud.

To combat fraud together we need to ensure our people have the right skills now and are supported to develop to meet future needs of the counter fraud agenda. Our values of Leading, Influencing, Fairness and Expertise (LIFE) underpin our organisational culture.

Strategic actions years 1 to 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
    • 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 foundations 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
End state 2026
  • making the best use of our people and the skills they have with a forward-thinking workforce plan
  • an integrated and responsive HR service
  • people are proud to work here, are proud of the work we do and feel included, valued, supported and fairly and equally recognised for their efforts
  • a refreshed performance management structure that sets clear, fair expectations supported and informed by organisational health and management data to aid delivery and decision making
  • personal and professional development for all staff to build on existing potential
  • our people fully embrace our core values
  • our people are developed to be flexible, empowered and driven to achieve counter fraud goals

Strategic Pillar – Our Resources
Strategic objective Ensuring we use our resources in an innovative and agile way to support and deliver counter fraud activity within the NHS.
Why it is important?

We have the right resources, both financial and infrastructure, to facilitate our counter fraud impact across the sector.

Our resources within the NHSCFA provide the basis of how and what we deliver. They help us maximise our impact across the NHS, support the targeting of key support and counter fraud areas, and enable our successful delivery. Our resources underpin our ability to be agile and responsive which in turn makes our productivity and impact more efficient.

Our resources also support the NHSCFA to remain compliant with key legislation.

Strategic actions years 1 to 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
  • maintain 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
  • our IT will fully support our operational delivery and future ambitions around advanced analytical capability
  • our IT will protect the NHSCFA from risks, threats, and vulnerabilities we face from cyber attacks
  • continually explore technology to enable business success
End state 2026
  • a fully integrated strategic, financial, people, technology plan
  • closer alignment of resources with our partners and joint initiatives to support efficiencies and removal of duplicated effort
  • flexible model in place to support and develop key areas of NHSCFA’s business
  • budgets will be effective and efficiently managed
  • financial planning will include a forward plan and opportunity
  • business cases will be developed to attract funding and opportunity to counter fraud activity
  • our IT will fully support operational delivery in countering fraud
  • the correct infrastructure in place to enable a range of new initiatives
  • technology will work hand in hand with the business to achieve maximum efficiency
  • IT will underpin our ability to digitally innovate and impact counter fraud

Our Four Counter Fraud Strategic Pillars

Our ambition is for data to underspin the four pillars of our strategy for the next 3 years.

  1. Understand : Understand how fraud,bribery and corruption affects the NHS
  2. Prevent : We will ensure the NHS is Equipped to take proactive action to prevent future losses from occurring
  3. Respond : When we know that the fraud has occured, we are equipped to respond
  4. Assure : We can assure our key partners, stakeholders and the public that the overall responce to fraud across the NHS is robust

These are underpinned by:

  • Our people
  • Our Resources
  • Our 2023 - 2026 strategy

Working with the Public Sector Fraud Authority

"Fraud is an often unseen and underestimated problem, and it takes money away from critical services on which the public rely.

I welcome the new strategy from the NHSCFA - which recognises the extent of the challenge faced, and makes a commitment to real, meaningful and measurable action. It is underpinned by continuing to build a deep understanding of the problem - and seeking to prevent it where possible."

Mark Cheeseman OBE - CEO, Public Sector Fraud

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