NHSCFA Standing financial instructions
SFIs are instructions for the NHSCFA, its Directors, officers, employees and agents relating to all financial matters.
These Standing Financial Instructions (SFIs) are issued in accordance with the Financial Directions issued by the Secretary of State for Health & Social Care under the National Health Service Act 2006 for the regulation of the conduct of the NHS Counter Fraud Authority (NHSCFA) in relation to all financial matters. They shall have effect as if incorporated in the Standing Orders (SOs) of the Authority. These SFIs refer to the financial transactions of the NHSCFA only. Nothing in these SFIs is intended to contradict the establishment order. Hereafter the NHS Counter Fraud Authority will be referred to either as the NHSCFA, or the Authority.
In accordance with Health Service Circular HSG (96)12, these SFIs detail the financial responsibilities, policies and procedures adopted by the Authority. They are designed to ensure that the Authority’s financial transactions are carried out in accordance with the law and Government policy, (including “Managing Public Money” 2013 with revised Annexes May 2021), in order to achieve probity, accuracy, economy, efficiency and effectiveness. They should be used in conjunction with the Scheme of Delegation which includes the Reservation of Powers to the Authority.
These SFIs identify the financial responsibilities that apply to everyone working for the Authority. They do not provide detailed procedural advice and should be read in conjunction with the detailed departmental and financial procedure notes. The user of these SFIs must also take into account relevant prevailing Department of Health and Social Care (DHSC) and/or Treasury instructions. The Director of Finance must approve all financial procedures.
Should any difficulties arise regarding the interpretation or application of any of the SFIs, the advice of the Director of Finance must be sought before taking action. The user of these SFIs should also be familiar with and comply with the Authority’s SOs.
Failure to comply with SFIs and SOs can, in certain circumstances, be regarded as a disciplinary matter that could result in dismissal.
If for any reason these SFIs are not complied with, full details of the noncompliance and any justification for non-compliance shall be reported to the next formal meeting of the Authority’s Audit and Risk Management Committee (ARAC) for referring action or ratification. All members of the Board, and all staff, have a duty to disclose any non-compliance with these SFIs to the Director of Finance as soon as possible.
Wherever the title Chief Executive Officer, Director of Finance, or other nominated officer is used in these instructions, it shall be deemed to include such other directors or employees who have been duly authorised to represent them, except in respect of Banking Arrangements (See Section 4).
Any expression to which a meaning is given in the National Health Service Act 2006 or in the Financial Directions made under the Act shall have the same meaning in these instructions; and:
The Board shall be comprised of the following officers:
The Board exercises financial supervision and control by:
The Authority has resolved that certain powers and decisions may only be exercised by the Board. These are set out in the Scheme of Delegation.
The Board shall delegate executive responsibility for the performance of its functions to the Chief Executive Officer who shall retain overall responsibility for all its activities.
Within the SFIs it is acknowledged that the Chief Executive Officer, as Accounting Officer, will have ultimate responsibility for ensuring that the Authority meets its obligation to perform its functions within the financial resources made available to it. The Chief Executive Officer has overall executive responsibility for the Authority's activities and is responsible to the Board for ensuring that it stays within its resource and cash limits.
The Chief Executive Officer will delegate detailed responsibility for financial activities and controls to the Director of Finance but retain overall accountability. The extent of such delegation will be determined in the Authority’s Scheme of Delegation and should be kept under review by the Board.
The Chief Executive Officer, through the Director of Finance, shall be responsible for the implementation of the Authority's financial policies and for coordinating any corrective action necessary to further these policies.
It shall be the responsibility of the Chief Executive Officer through the Director of Finance to ensure that existing staff and all new employees are notified of their responsibilities within these instructions.
In addition to the above, budget holders, budget managers and those staff who are involved in dealing directly with contractors/suppliers are required to confirm that they have read and understood the SFIs and SOs.
The Director of Finance is responsible for:
Without prejudice to any other functions of the Authority, and employees of the Authority, the duties of the Director of Finance shall include:
The Director of Finance shall require, in relation to any officer who carries out a financial function, that the form in which the records are kept and the manner in which the officers discharge their duties shall be to his/her satisfaction.
The Director of Finance will ensure money drawn from the DHSC against cash limited and non-cash limited funds is required for approved expenditure only and is drawn only at the time of need. They will also be responsible for:
All members of the Board, Senior Management Team and employees, individually and collectively, are responsible for:
The Director of Finance shall be responsible for arranging contracts for the provision of items and/or services and shall ensure that those contracts are correctly entered into, monitored and governed within the contract's terms and conditions.
Any contractor or employee of a contractor who is empowered by the Authority to commit the Authority to expenditure or who is authorised to obtain income shall be covered by these instructions. It is the responsibility of the Chief Executive Officer to ensure that such persons are made aware of this.
In accordance with SOs (and as set out in guidance issued by the then Department of Health under Executive Letter EL(94) 40) (“Code of Accountability” 1994), the Authority shall establish an ARAC. The terms of reference of the ARAC shall be drawn up and approved by the Board and are incorporated in the SOs. The ARAC will provide an independent and objective view of internal control by overseeing internal and external audit services; reviewing financial systems, ensuring compliance with SOs and SFIs; reviewing schedules of losses and compensations and making recommendations to the Board.
Where the ARAC considers there is evidence of ultra vires transactions, evidence of improper acts, or if there are other important matters that the Committee wish to raise, the Chair of the ARA should raise the matter in the first instance with the Director of Finance and the Chief Executive Officer. If the matter has still not been resolved to the ARAC's satisfaction, then the matter will be raised at a full meeting of the Board.
The Authority has a responsibility to prepare and submit financial plans in accordance with the requirements of the DHSC or appropriate body. It shall perform its functions within the total of funds allocated or approved by the Secretary of State for Health & Social Care allowing for any planned changes in working balances during the year. All plans, financial approvals and control systems shall be designed to meet this obligation.
The Director of Finance shall ensure that the financial details contained within the service agreements of contracts entered into by the Authority are consistent with the requirement to balance income and expenditure; and they shall ensure that adequate statistical and financial systems are in place to facilitate the compilation of estimates, forecasts and investigations as may be required from time to time.
The Chief Executive Officer will compile and submit to the Authority an annual business plan which takes into account financial targets and forecast limits of available resources. The annual business plan will contain a statement of the significant assumptions on which the plan is based and details of major changes in workload, delivery of services or resources required to achieve the plan.
The Director of Finance shall, in consultation with budget holders and budget managers, compile such financial estimates and forecasts, on both revenue and capital accounts, as may be required from time to time by the Authority.
The Director of Finance will ensure that money drawn from the DHSC against the resource and cash limit is required for approved expenditure only and is drawn only at the time of need in line with the DHSC’s timetable.
The Director of Finance shall, on behalf of the Chief Executive Officer , prepare and submit budgets within the limits of available funds to the Authority for its approval prior to the commencement of each financial year.
The Director of Finance must review the basis and assumptions used to prepare the budget and advise the Authority that, to the best of the Director of Finance’s knowledge and understanding, they are realistic. In order to be able to fulfill this responsibility the Director of Finance shall have right of access to all budget holders on budgetary related matters. Such budgets should relate to income and expenditure in that year and shall have supporting statements in order to explain any matter material to the understanding of those budgets, covering all revenue and capital items. Alterations to budgets may be requested in line with guidance issued by the Director of Finance.
The Director of Finance shall monitor financial performance against budgets and business plans, periodically review them and report to the Authority on the Authority’s position against these targets. All budget holders and managers must provide information as required by the Director of Finance to enable budgets to be compiled and monitoring reports to be prepared.
The Director of Finance shall be responsible for ensuring that an adequate system of monitoring financial performance is in place to enable the Authority to fulfil its statutory responsibility to meet its Annual Revenue and Capital Resource Limits.
The Director of Finance will devise and maintain systems of budgetary control. These will include:
The Director of Finance shall devise and maintain adequate systems to ensure that the Authority can identify, implement and monitor opportunities for inclusion within Cost Improvements.
The Chief Executive Officer may, in line with the Scheme of Delegation, delegate responsibility for a budget or a part of a budget to operational managers to permit the performance of defined activities. The terms of delegation shall include a clear definition of individual and group responsibilities for control of expenditure, exercise of virement (budget transfers), achievement of planned levels of service and the provision of regular reports upon the discharge of these delegated functions to the Chief Executive Officer.
Each budget holder is responsible for ensuring that:
Except where otherwise approved by the Chief Executive Officer, taking account of advice from the Director of Finance, budgets shall be used only for the purpose for which they were provided, and any budgeted funds not required for their designated purposes shall revert to the immediate control of the Chief Executive.
Expenditure for which no provision has been made in an approved budget shall be incurred only after authorisation by the Chief Executive Officer for the Authority.
The Director of Finance shall keep the Chief Executive Officer informed of the financial consequences of changes in policy, pay awards and other events and trends affecting budgets and shall advise on the financial and economic aspects of future plans and projects.
By virtue of subsection 7(a) of Section 97A of the National Health Service Act 1977 any sums received on behalf of the Secretary of State for Health & Social Care in respect of:
The Chief Executive Officer is responsible for ensuring that the appropriate financial monitoring forms are submitted to the requisite monitoring organisation.
The Director of Finance on behalf of the Chief Executive Officer and the Authority, shall prepare, and submit the Annual Report and Accounts, certified by the Comptroller & Auditor General to the Secretary of State for Health & Social Care in respect of each financial year in such a form as the Secretary of State for Health & Social Care directs.
The Annual Report and Accounts and financial returns shall be prepared in accordance with the guidance given by the DHSC Accounting Manual (GAM), the HM Treasury’s Government Financial Reporting Manual (FReM), and the Authority’s accounting policies. The Annual Report and Accounts shall be laid before parliament, in accordance with the Accounts Directions and the timetable prescribed by the DHSC.
The Director of Finance is responsible for managing the Authority’s banking arrangements and for advising the Board on the provision of banking services and operation of accounts. This advice will take into account guidance issued by DHSC and “Managing Public Money” (2013 with revised annexes May 2021), published by HM Treasury. This guidance recommends only using commercial accounts where the required services are not provided by the Government Banking Service (GBS) or where better value for money for the Exchequer overall can be demonstrated.
The ARAC, on behalf of the Board, shall approve the banking arrangements as required.
The Director of Finance is responsible for:
The Director of Finance will prepare detailed instructions on the operation of commercial bank and GBS accounts which must include:
The Director of Finance must advise the Authority’s bankers in writing of the conditions under which each account will be operated.
The Director of Finance should review the banking needs of the Authority at regular intervals to ensure that they reflect current business patterns and represent best value for money.
The Chief Executive Officer shall ensure that there is an adequate appraisal process in place for determining capital expenditure priorities and the effect of each proposal on strategic plans. T h e Chief Executive Officer is responsible for the management of all stages of capital schemes and for ensuring that schemes are delivered on time and to cost. The Chief Executive Officer shall ensure that capital investment is not undertaken without confirmation of the availability of resources to finance both the capital spend and any revenue consequences including capital charges.
For all capital expenditure proposals, the Chief Executive Officer shall ensure that a business case is produced in line with NHSCFA guidance, setting out an option appraisal of potential benefits compared with known costs to determine the option with the highest ratio of benefits to cost and appropriate project management and control arrangements. The Director of Finance shall certify the costs and revenue consequences of each business case.
The Chief Executive Officer will ensure that all business cases for capital expenditure are approved in line with the DHSC delegated limits.
The Director of Finance shall issue procedures for the regular reporting of expenditure and commitment against authorised expenditure.
The Chief Executive Officer is responsible for the issue to an officer of the Authority specific authority to commit expenditure, authority to proceed to a tender and approval to accept a successful tender.
The Director of Finance shall issue procedures governing the financial management, including variations to contract, of capital investment projects and valuation for accounting purposes.
The Chief Executive Officer is responsible for the maintenance of both the Register of Assets and the Register of Inventory Items, taking account of the advice of the Director of Finance concerning the form and the method of updating the registers.
Each employee has a responsibility to exercise a duty of care over the assets of the Authority and it shall be the responsibility of senior staff in all disciplines to apply appropriate routine security practices in relation to NHS assets. A substantial or persistent breach of agreed security practices or complaint received of theft within the authority shall be reported to the Corporate Secretary, who shall then refer the matter to the Director of Finance, who will determine the necessary action.
The Chief Executive Officer shall define the items of equipment which shall be recorded on either the Capital Asset Register or the Inventory Register. The Capital Accounting Manual, as issued by the DHSC, will be considered when determining the minimum data set for the Capital Asset Register.
Additions to the Fixed Asset Register must be clearly identified to an appropriate budget holder and be validated by reference to properly authorised and approved agreements, architects’ certificates, suppliers’ invoices and other documentary evidence in respect of purchases from third parties; requisitions and wages records for own materials and labour including appropriate overheads.
Where capital assets are sold, scrapped, lost or otherwise disposed of, their value must be removed from the accounting records and each disposal must be validated by reference to authorisation documents and invoices.
The Director of Finance shall approve procedures for reconciling balances on the general ledger against balances on the Fixed Asset Register.
Land and buildings shall be held at current values with a full professional valuation carried out at least every five years. Other assets will be held at depreciated/amortised historical cost as a proxy for current value. This is in accordance with the Authority’s accounting policies which comply with the Financial Reporting Manual (FReM) issued by HM Treasury.
The value of each asset shall be depreciated using methods and rates as specified in the Authority’s accounting policies which comply with the FReM. Estimated useful lives and depreciation rates of assets will be reviewed on an annual basis.
The Director of Finance shall calculate and account for capital charges as specified in the FReM.
Budget holders will ensure that the respective Asset Register for their areas will be physically checked annually.
The Fixed Asset Register and the Inventory Register shall also record items which are transferred from one part of the Authority to another. It is the responsibility of the budget managers to inform the Director of Finance of these changes.
The Director of Finance shall maintain an up to date register of properties owned or leased by the Authority in accordance with the NHS Manual of Property Transactions. This should include details of location, tenancy (where appropriate), and custody of the deeds and lease documents.
Asset control procedures (including fixed assets, cash, cheques and negotiable instruments, and also including donated assets) must be approved by the Director of Finance. This procedure shall make provision for:
All discrepancies revealed by verification of physical assets to fixed Asset Register shall be notified to the Director of Finance.
Whilst each employee and officer has a responsibility for the security of property of the Authority, it is the responsibility of Board members and senior employees in all disciplines to apply such appropriate routine security practices in relation to NHS property as may be determined by the Board. Any breach of agreed security practices must be reported in accordance with agreed procedures.
Any damage to the Authority's premises, vehicles and equipment or any loss of equipment or supplies shall be reported by staff in accordance with the agreed procedure for reporting losses.
Where practical, assets should be marked as NHS Counter Fraud Authority property.
Stocks are those goods normally utilised in day to day or trading activity but which, at any point in time, have not yet been consumed or sold (excluding capital assets).
The overall control of stock shall be the responsibility of the Director of Finance working with the budget holders. The designated manager shall be responsible for ensuring that stocks are kept at a minimum, consistent with good working practices. The Director of Finance shall be responsible for the design, documentation and supervision of local stock control procedures within the national requirements.
The responsibility for security arrangements and the custody of keys for all stock locations shall be clearly defined in writing by the designated officer and agreed with the Director of Finance.
All stock records shall be in such form and shall comply with such systems of control as the Director of Finance may require.
A guidance document on the process to follow for raising requisition orders, purchase orders and receipting goods received shall be made available to all staff. All goods received shall be checked with regard to quantity and/or weight and inspected as to quality and specification.
All goods received shall be entered onto an appropriate goods received/stock record (whether a computer or manual system) on the day of receipt. If goods received are unsatisfactory, the records shall be marked accordingly. Further, where goods received are seen to be unsatisfactory, or short on delivery, they shall be accepted only on the authority of the designated officer and the supplier shall be notified immediately.
The issue of stocks shall be in accordance with the relevant sections of the Finance Procedure Note.
All transfers and returns shall be recorded on forms/systems provided for the purpose and approved by the Director of Finance.
Breakages and other losses of goods in stock shall be recorded as they occur and shall be presented to the Director of Finance at regular intervals. (See also Section 14, Losses and Special Payments).
Stocktaking arrangements shall be agreed with the Director of Finance and there shall be a physical check covering all items in stock at least once a year or by an approved perpetual inventory checking system. The physical check shall involve at least one officer, other than the budget manager responsible for the stock. The stocktaking records shall be numerically controlled and signed by the officers undertaking the check. Any surplus deficiencies revealed on stocktaking shall be reported to the Director of Finance immediately.
Where a complete system of stock control is not justified, alternative arrangements shall require the approval of the Director of Finance.
Stock shall be valued at the lower of cost or net realisable value. For this purpose, cost shall be ascertained on either the basis of being used on the principle of first in, first out (FIFO), or on the basis of average purchase price. The cost of stock, with the exception of finished stock arising from manufacturing, shall be the purchase price including VAT, without any margins.
Stock which has deteriorated or is not usable for any other reason for its intended purposes, or may become obsolete, shall be written down to its net realisable value. The procedure for identification and approval of the write-down shall be approved by the Director of Finance and recorded.
All receipt books, tickets, agreement forms, or other means of officially acknowledging or recording amounts received or receivable, shall be in a form approved by the Director of Finance. Such stationery shall be ordered and controlled by the Director of Finance (or nominated deputy) and subject to the same precautions as are applied to cash.
All officers whose duty it is to collect or hold cash shall be provided with a lockable cash box which will normally be deposited in a safe. The officer concerned shall hold only one key and all duplicates shall be lodged with the Authority's bankers or such other officer authorised by the Director of Finance, and suitable receipts obtained. The loss of any key shall be reported immediately to the Director of Finance. The Director of Finance shall, on receipt of a satisfactory explanation, authorise the release of the duplicate key. All new safe keys will be dispatched directly to the Director of Finance from the manufacturers. The Director of Finance shall be responsible for maintaining a register of authorised holders of safe keys.
All cash, cheques, postal orders and other forms of payment received by an officer shall be entered immediately in an approved form of register.
The opening of coin operated machines (including telephones) and the counting and recording of the takings shall be undertaken by two officers together, except as may be authorised in writing by the Director of Finance, and the coin box keys shall be held by a nominated officer.
The Director of Finance shall prescribe the system for the transporting of cash and where practicable a specialist security company employed.
The holders of safe keys shall not accept unofficial funds for depositing in their safes unless such deposits are in special sealed envelopes or locked containers. It shall be made clear to the depositors that the Authority is not to be held liable for any loss, and written indemnities must be obtained from the organisation or individuals absolving the Authority from responsibility for any loss.
During absence (e.g. annual leave) of the holder of a safe, the acting officer shall be subject to the same controls as the normal holder of the key. There shall be written discharge for the safe contents on the transfer of responsibilities and the discharge document must be retained for inspection.
All unused cheques and other orders shall be subject to security precautions as are applied to bulk stocks of cheques and shall normally be retained by the Authority's bankers and released by them only against a requisition signed by the Director of Finance.
A cheque register shall be kept in which all cheque stocks ordered, received and issued shall be recorded and signed for by nominated officer(s). A separate register is to be kept of payable orders.
The Director of Finance shall ensure that all relevant staff are informed in writing on appointment, of their responsibilities and duties for the collection, handling or disbursement of cash, cheques and other monies.
Any loss or shortfall of cash, cheques, or other negotiable instruments, however occasioned, shall be reported immediately in accordance with the agreed procedure for reporting losses. (See Section 14 - Losses and Special Payments).
The NHSCFA’s credit card is solely for use in connection with NHSCFA business.
The credit card is only to be used in exceptional circumstances and where the standard means of purchasing / payment are unavailable (e.g. online only purchasing).
In line with the Corporate Credit Card Policy, requests must be made in advance on the requisite Corporate Credit Card Purchase Form and must be approved by the relevant budget holder.
The Corporate Governance Manager & Board Secretary is responsible for authorising credit card purchases above £1000 in advance. In their absence responsibility will be delegated to an appropriate individual this responsibility will rest with the Finance & Governance Support Lead and / or the Information Governance Lead.
The details of each transaction will be entered into the Corporate Credit Card transaction register which will be maintained, monitored and reconciled under arrangements approved by the Director of Finance. The register will record the name of the person requesting the transaction, total cost, date and the signatories of both requestor and budget holder if different. If a requested transaction is not approved this must also be recorded in the register together with the reason for non-approval. The register should be accompanied by a receipt relating to each transaction.
The workforce plans incorporated within the annual budget will form the funded establishment. The funded establishment of any budget holder may not be varied without the approval of the Chief Executive Officer.
No Director or employee may engage, re-engage or re-grade employees, either on a permanent or temporary nature, or hire agency staff, or agree to changes in any aspect of remuneration unless:
The Authority will approve procedures presented by the Chief Executive Officer for the determination of commencing pay rates, conditions of service etc. for employees.
The Director of Finance is responsible for:
The Director of Finance will issue instructions regarding:
Appropriately nominated managers have delegated responsibility for:
Regardless of the arrangements for providing the payroll service, the Director of Finance shall ensure that the chosen method is supported by appropriate (contracted) terms and conditions, adequate internal controls and audit and review procedures, and that suitable arrangements are made for the collection of payroll deductions and payment of these to appropriate bodies.
All employees shall be paid by bank credit transfer, unless otherwise agreed by the Director of Finance.
The Authority shall delegate responsibility to the Director of Finance for ensuring that all employees are issued with a Contract of Employment in a form approved by the Authority and which complies with employment legislation and dealing with variations to or termination of contracts of employment.
Director of Finance shall be responsible for the prompt payment of accounts and claims. The term "payment" includes any arrangements established to settle payments upon a non-cash basis. Payment of contract invoices shall be in accordance with contract terms. All payments shall comply with the Government's policy on prompt payment.
All authorised officers shall inform the Director of Finance promptly of all money payable by the Authority arising from transactions which they initiate, including contracts, leases, tenancy agreements and other transactions. To assist financial control, the Director of Finance will maintain a register of regular payments.
The Director of Finance shall be responsible for maintaining a system for the verification, recording and payment of all accounts payable by the Authority. This system will incorporate an approved officers’ signatory list of the budget holders, budget managers and their deputies who are authorised to certify the following:
Appropriate prepayments will be permitted for instances relating to payments for rent, maintenance contracts and in those instances, where, as standard business practice demands, nominal prepayments are required (i.e. training, publications).
Prepayments which fall outside the above categories are only permitted where exceptional circumstances apply. In such instances:
Officers certifying accounts will ensure, wherever possible, that any other officers relied upon to do preliminary checking of delivery or execution of work act independently of those who have placed orders and negotiated prices and terms.
In the case of contracts which require payment to be made on account, during progress of the works, the Director of Finance shall make payment on receipt of a certificate from the appropriate qualified officer or outside consultant. Without prejudice to the responsibility of any Consultant, a contractor's account shall be subjected to such financial examination by the Director of Finance and such general examination by appropriately qualified officers as may be considered necessary, before the person responsible to the Authority for the contract, issues the final certificate.
The Director of Finance may authorise advances on the imprest system for petty cash and other purposes as required. Individual payments must be restricted to the amounts authorised by the Director of Finance.
The Director of Finance shall ensure that payment for goods and services is made only when the goods and services have been properly received.
The Director of Finance shall be responsible for designing and maintaining systems for the proper recording, invoicing and collection of all monies due which shall incorporate the principles of internal checking and separation of duties.
The Director of Finance is responsible for the prompt banking of all monies received.
All officers shall inform the Director of Finance of money due to the Authority arising from transactions which they initiate.
The Director of Finance is responsible for approving and regularly reviewing the level of all fees and charges other than those determined by the DHSC or statute. Where sponsorship income (including items in kind such as subsidised goods or loans of equipment) is considered the guidance contained in the DHSC’s Commercial Sponsorship – Ethical Standards in the NHS shall be followed.
The Director of Finance will be responsible for arranging the level of rentals for newly acquired property and for reviewing rental and other charges.
In respect of pricing the Authority’s goods and services, margins will be determined according to national guidelines approved by the Chief Executive Officer on the advice of the Director of Finance.
The Director of Finance shall ensure that appropriate systems exist for the recovery of outstanding debts.
Income not recovered shall be dealt with in accordance with Section 14 (Losses and Special Payments)
The Director of Finance shall prepare detailed procedures for the disposal of assets and inventory items.
Disposal of all land and/or buildings must be authorised by the Secretary of State for Health & Social Care. Delegated limits for recommending disposal of such assets to the Secretary of State for Health & Social Care are:
Disposal of all other assets shall be authorised as follows:
All assets and inventory items which are considered to be surplus to the Authority's requirements or are considered to be beyond economical repair, should be disposed of in line with the appropriate procedures and should be listed on the appropriate documentation, authorised by the budget holder and forwarded to the Director of Finance who will update the Authority’s Asset Register where appropriate.
All unserviceable articles shall be condemned or otherwise disposed of by an employee authorised for that purpose by the Director of Finance. Prior to disposal it should be determined whether the article is recorded within the Register of Assets. A record in a form approved by the Director of Finance shall be kept of all articles submitted for condemnation and the condemning officer shall indicate whether the articles are to be converted, destroyed or otherwise disposed of. All entries shall be confirmed by the counter-signature of a second officer authorised for the purpose by the Director of Finance.
The condemning officer shall satisfy himself as to whether or not there is evidence of negligence in use and shall report any such evidence to the Director of Finance.
The Director of Finance will determine whether such condemned items should be recorded in the Losses and Special Payments Register, as set out in Section 14 of these SFIs.
As a Public Sector body, the NHSCFA must ensure that all procurement and contracting activity meets the requirements of domestic law, legislation and policy - notably the Public Contracts Regulations 2015 (PCRs 2015), and international agreements and DHSC and Cabinet Office Guidance. It must also ensure that goods, works and services are procured to deliver value for money for the taxpayers.
Officers must follow NHSCFA procurement operating procedures to ensure that they comply with legislation, policy and these SFIs. The Director of Finance is responsible for maintaining procurement operating procedures across the Authority.
These SFIs set out the instructions which all officers must follow.
Within these SFIs, a scheme of delegated authority is present to ensure that only designated officers authorise procurement activity, and the entering into of contracts.
Officers should consult with Strategic Sourcing at the
Under the PCRs 2015, the value of a contract must be estimated by reference to the contractually committed spend over the life of the contract. This is the total annual value of the contract multiplied by the number of years in the contract, including, but not limited to, all extensions, options, variations and start-up costs (this is Total Contract Value), excluding VAT.
A proposed contract may not be divided into smaller contracts in order to avoid the provisions of these SFIs, PCRs 2015 or any other relevant policy. However, officers should be mindful of Regulation 46 of the PCRs 2015 that requires contracting authorities to divide contracts into lots, where possible.
Deliberate disaggregation to avoid the intended application of these SFIs is a disciplinary offence.
The Director of Finance is responsible for ensuring that aggregation rules are effective across the Authority. Where officers believe that aggregation rules are not operating effectively, they should refer this to the Chief Executive Officer.
Subject to SFI 12.3.4 below, for commercial commitments to suppliers of up to £1,000 (excluding VAT), officers may use their discretion to achieve value for money. These commercial commitments will be audited from time to time by the Director of Finance or their nominated representative.
Subject to SFI 12.3.4 below, for commercial commitments to suppliers between £1,001 and £10,000 (Total Contract Value, excluding VAT), officers must seek a minimum of three written quotations from potential suppliers and complete the necessary purchasing documentation. Officers may consult with the NHS BSA Strategic
Officers must maintain confidentiality of quotations pending their evaluation. Following evaluation confidentiality shall be maintained subject to Freedom of Information Act (FOIA) 2000.
Where a proposed commercial commitment falls within a goods or services category which is covered by a central Government procurement strategy, officers must use centrally-agreed contracting routes unless there is a clear value for money justification for using another route (this should be clarified in advance with the NHS BSA Head of Strategic Sourcing). Details of centrally controlled categories are set out in the procurement operating procedures (available from the NHS BSA Head of Strategic Sourcing) for purchases below £10,000.
For all commitments to suppliers above £10,000 (Total Contract Value excluding VAT), officers must agree an appropriate tender/quotation process and effective evaluation criteria with the Director of Finance. In addition to the above instruction, any commitments to suppliers for ICT infrastructure and / or software applications in excess of £10,000 must be approved by the NHSBSA Head of Business Support Services prior to procurement.
Officers must maintain confidentiality of tenders pending their evaluation. Following evaluation confidentiality shall be maintained subject to FOIA 2000.
Only in exceptional circumstances, may it be permissible to bypass the above quotation/competitive tender processes.
In such instances referred to in 12.5.1 above where the anticipated spend with the supplier is more than £1,000 (excluding VAT), and always prior to such a noncompetitive offer from a supplier being accepted verbally or in writing, officers must consult with the Director of Finance. Written approval to accept the offer must be obtained from the Director of Finance using the appropriate form. Where the Director of Finance requires such approval for their functional business requirements, they will seek approval from the NHSCFA Chief Executive Officer.
In order to award a contract under a single tender action, appropriate procurement processes must be followed so that the total contract value and contract terms are agreed with the supplier. Any associated risks must be properly assessed, and any award must be duly documented and recorded.
Any proposal to extend or vary an existing contract which would result in the addition of more than £10,000 to the existing Total Contract Value (excluding VAT) must be referred to the Director of Finance who will advise if this is possible under the existing contract terms and/or the PCRs 2015.
All commitments to suppliers for goods, works and services must be made on an official purchase order (Purchase Order), unless the Director of Finance has provided alternative written instructions. Such written instructions may be requested where it is not possible to generate a purchase order.
Purchase Orders shall be consecutively numbered, in a form approved by the Director of Finance and shall include all necessary information to enable to the supplier to meet their obligations to deliver the correct goods, works or services on time, to the required specification and at the correct price according to the NHSCFA’s relevant terms and Conditions of Purchase.
Purchase Orders are to be created on the NHSCFA’s finance system. In the finance system, a Purchase Order is created from a Requisition. A Requisition must be authorised by officers with the relevant ‘delegated authority’ in order to become a Purchase Order.
Officers must ensure that details of all commitments to suppliers/Purchase Orders placed by them will be available to the Director of Finance for inspection, either in paper form or through a computerised purchase ledger system.
The Director of Finance will ensure that an appropriate system of delegated authority is in place. The delegated authority system describes the limits within which officers must operate when making commitments to suppliers. All officers must ensure that they understand their level of delegated authority and that they comply with it when they make commitments to suppliers. No commitment to a supplier (verbal or written) shall be issued for any item or service for which there is no agreed budget provision.
No commitment shall be made by any officer for any item for which any offer of gifts, reward or benefit has been made to staff in the circumstances defined in 16.2. All gifts and hospitality shall be recorded in a Register of Gifts and Hospitality. The Director of Finance will ensure that arrangements are in place for the maintenance of the register. The Corporate Secretary will maintain such a register for Board members.
Goods are not to be taken on trial or loan without the prior written approval of the Director of Finance or their delegate.
Delegated authorities for various expenditure levels are summarised in the table below. Only officers with the appropriate delegated authority may authorise commitments to and sign contracts with suppliers.
Each budget holder is responsible for ensuring that spending remains within the sum of their delegated budget as per 2.13 of these SFIs. This will be assured by Finance through the normal monthly budget monitoring process.
|Anticipated expenditure (Total Contract Value, excluding VAT)||Requiredb Budget Holder Approval||Required Finance approval||Required Strategic Sourcing approval||Required CEO/Board approval||Authorised Contract Signatory|
|£0 - £1,000||Budget Holder/ Manager||Not required||Not required||Not required||Budget Holder/ Manager||£1,001 - £10,000||Budget Holder/ Manager||Not required||Not required||Not required||Budget Holder/ Manager|
|£10,001 - £100,000||Head of Service/Budget Holder||Director of Finance||CEO||CEO||Director of Finance|
|£100,001 - £500,000||Director||Director of Finance||CEO||CEO||Director of Finance|
|£500,001 - £1,000,000||Director||Director of Finance||CEO||CEO||CEO|
|£1,000,001 and above||Director||Director of Finance||CEO and Board||Full Board||CEO and Board Chair|
An officer with delegated authority has the following responsibilities:
The Chief Executive Officer & Director of Finance shall be responsible for ensuring that there are arrangements to measure, evaluate and report on the adequacy and effectiveness of internal control and efficient use of resources via use of the DHSC’s shared internal audit service.
The Authority shall appoint a Head of Internal Audit who will have overall responsibility for the internal audit function via the DHSC’s shared internal audit service.
Management's responsibility is to establish systems of internal control for all operations, both computerised and manual, to ensure that these are properly run.
Internal Audit shall be entitled, without necessarily giving prior notice, to require and receive:
Where a matter arises which involves, or is thought to involve, irregularities concerning cash, stores or other property of the Authority, or any suspected irregularity in the exercise of any function of a pecuniary nature, the Director of Finance shall be notified immediately.
The Corporate Secretary shall report directly to the Chief Executive Officer and shall refer audit reports to the appropriate designated officers. Failure to take remedial action within a reasonable period shall be reported to the responsible Manager. Where, in exceptional circumstances, the use of normal reporting channels could be seen as a possible limitation on the objectivity of the audit, Internal Audit shall have access to report directly to the Chief Executive Officer, the Chair of the Authority or the Chair of the ARAC.
The Director of Finance shall prepare procedural instructions on the recording of and accounting for losses and special payments.
Any employee discovering or suspecting a loss of any kind must immediately inform their respective Director, who must immediately inform the Chief Executive Officer and the Director of Finance. Where a criminal offence is suspected, the Director of Finance must immediately inform the police. In cases of fraud and corruption or of anomalies which may indicate fraud or corruption, the Director of Finance must inform the relevant LCFS and both Internal and External Auditors. The Director of Finance will provide the Treasury with details of all novel or unusual frauds or attempted frauds.
For losses apparently caused by theft, arson, neglect of duty or gross carelessness, except those which are of a trivial nature, the Chief Executive Officer will immediately notify:
Within the limits delegated to it by the DHSC, the Authority shall delegate its responsibility to approve losses and authorise special payments to the Chief Executive Officer and Director of Finance acting jointly.
No losses or special payments exceeding the delegated limits shall be made without prior DHSC approval.
The Director of Finance shall be authorised to take any necessary steps to safeguard the Authority's interest in bankruptcies and company liquidations.
For any loss, the Director of Finance should consider whether any insurance claim can be made.
The Director of Finance shall maintain a losses and special payments register in which write off action is recorded.
All losses and special payments must be reported to the ARAC on a regular basis.
All NHS bodies are required to take necessary steps to counter fraud in the National Health Service in accordance with the Secretary of State’s Directions, the NHS Standard Contract and in line with guidance provided by NHSCFA.
In accordance with Secretary of State’s Directions the NHSCFA will undertake all necessary steps to counter fraud. The Chief Executive Officer and Director of Finance monitor and ensure compliance as per the Secretary of State’s Directions and have placed the responsibility for monitoring and ensuring compliance with the Corporate Secretary.
The Audit and Risk Assurance Committee shall monitor and ensure compliance with Secretary of State’s Directions on countering fraud within the NHSCFA.
The investigation of allegations within the Authority of misappropriation or other irregularities will be allocated and conducted in line with relevant procedures and the standard operating procedure for the Allocation of Wrongdoing Referrals.
The NHSCFA core business is countering fraud and it has strong and effective counter fraud management process to measure, prevent, detect and respond to instances of fraud, bribery and corruption as well as theft and criminal damage. The NHSCFA wants to ensure there is an open and honest reporting culture across the business, where NHSCFA employees and any agency or contract staff have the confidence to speak out. It is extremely important that employees speak out if they have concerns. This is in accordance with the Authority’s Values and Behaviour Framework and its Principles of Good Practice. NHSCFA employees, agency and contract staff are encouraged to raise their concerns either internally, through the Fraud and Corruption Reporting line, through the Fraud and Corruption Reporting On-Line (FCROL) or via the NHSCFA Fraud, Bribery, Corruption, Theft and Damage Policy, or NHSCFA Whistleblowing Policy, or Standards of Business Conduct Policy.
The Bribery Act 2010 came into force on 1 July 2011. This made it a criminal offence to offer or promise to offer a bribe or to request, agree to receiving or receive a bribe which is intended to cause another party to "improperly" perform a "relevant function or activity". When receiving a bribe or bribing another (including a foreign official) individuals may be liable to prosecution. The maximum penalty on conviction is 10 years imprisonment and an unlimited fine.
It is important to note that there is no need for any transfer of goods and/or money to have taken place for the intended action to be classed as bribery. The intention alone is sufficient to complete the offence. The NHSCFA will not tolerate acts of bribery and will treat the giving or receiving of bribes as gross misconduct which may result in disciplinary action and/or criminal proceedings. Employees who have concerns should raise either internally, through the Fraud and Corruption Reporting line, through the Fraud and Corruption Reporting OnLine (FCROL) or via the NHSCFA Fraud, Bribery, Corruption, Theft and Damage Policy, or via the NHSCFA Whistleblowing Policy, or Standards of Business Conduct Policy.
In line with their responsibilities, the appropriate NED will monitor and ensure compliance with relevant standards.
The Authority shall identify activities required and allocate resources to ensure appropriate security measures are maintained.
The Director of Finance has overall responsibility for controlling and coordinating security measures.
“Managing Conflicts of Interests in the NHS” sets out the principles for standards of business conduct for NHS staff.
All offers of gifts or hospitality shall be recorded in line with the Standards of Business Conduct Policy.
Casual gifts, unless of low value (less than £10 e.g. diaries) should be declined, and all unsolicited gifts returned.
Hospitality such as lunches in the course of working visits may be accepted though they should be of commensurate value to that which the NHSCFA would provide in the same circumstances. In exceptional circumstances, hospitality (meals and refreshment) which is proportionate to the nature and purpose of a business-related event may be accepted. Such circumstances shall be pre-approved by the Board Secretary in line with the Standards of Business Conduct Policy.
Other offers of gifts or hospitality, including travel and accommodation shall be declined.
In addition to the ongoing requirement to declare relevant matters/interests under the Standards of Business Conduct Policy, employees must specifically also make relevant managers aware of any controlling or financial interests that they or their associates hold in organisations that may supply goods or services to the NHSCFA. The declaration should be made when they start employment, on the acquisition of the interest, when the nature of their interest alters and/or when they become aware of a potential commercial relationship between the interest and the NHSCFA. If the interest is significant then full written details must be provided. These will be recorded in a Register of Business Interests. Where there is potential for a conflict of interest the NHSCFA may require employees concerned to take action towards resolution.
Employees who have responsibility or designated responsibility for the procurement of goods and services; are an authorised signatory; work in the Finance & Corporate Governance Directorate; or have access to customers credit card details; must make a declaration to their manager and the Finance and Corporate Governance unit if they are:
Employees must not seek preferential rates or other benefits for private transactions with any company which they have had or may have, dealings within their capacity as NHSCFA employees.
Procurement guidance should be adhered to, as detailed in Section 12.
No organisation of any sort that may bid for NHSCFA business can be given an advantage over competitors. This applies in all cases. All contracts are awarded on merit and in line with SOs and associated procedure notes. In addition, no favour can be shown to the business of current or former NHSCFA employees or their relatives or associates. Employees known to have a relevant interest are excluded from all stages of the selection process.
All invitations to potential contractors must include a notice warning of the consequences of engaging in corrupt practices under the Bribery Act 2010.
Procurement guidance should be adhered to, as detailed in Section 12.
Employees must not engage in any employment (including self-employment) outside of their contract with the NHSCFA without the written permission of their manager. In the case of collaborative research with any outside body, representatives of the NHSCFA must be fairly rewarded for their input. Managers must refer requests for collaborative research to the Chief Executive Officer (or nominated deputy) who will ensure that a written contract is drawn up and that there are no potential or actual conflicts of interest.
Employees must adhere to the NHSCFA IT Acceptable Use and Information Security policies.
Any breach of the Standards of Business Conduct procedure, for personal gain or otherwise, may result in disciplinary action. In certain cases, criminal proceedings or civil litigation may result. Any doubts or queries about the content of this procedure or any course of action to be taken should be referred to the Director of Finance in writing.
Staff status regarding the declarations they make concerning the matters set out at 16.2, 16.3 and 16.6 are monitored no less than annually.
Declaration forms are available on the Authority intranet site or from the Finance & Corporate Governance unit.
All declarations made by employees will be held centrally by the Finance and Corporate Governance team. All information will be held in accordance with data protection legislation. The information will be held in confidence but may be available for public access where required by law. Information may also be disclosed for disciplinary or criminal or civil legal action.
Each individual declaration will be reviewed and added to the register and all declarations will be reviewed periodically by the Board Secretary.
The external audit of the NHSCFA is undertaken by the Comptroller and Auditor General (C&AG), whose powers are conferred under the National Health Service Act 1977.
The C&AG’s powers to obtain documents and information were consolidated in the National Audit Act 1983. This legislation provides that the C&AG shall have a right of access at all reasonable times to all such documents as he may reasonably require for carrying out examination and shall be entitled to require from any person holding or accountable for any such document such information and explanation as are reasonably necessary for that purpose.
These rights of access extend to the annual audit of all systems, establishments and processes associated with the Authority’s functions.
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