Information requested
1. Investigation Thresholds and Referral Handling
- The current criteria or threshold used by NHS CFS Wales to determine whether a fraud referral warrants formal investigation
- Internal guidance or policy documents outlining how referrals are assessed and classified as “non-fraud” without direct engagement with the complainant
- The process by which NHS CFS Wales records and closes referrals that are not investigated, including any audit trail or closure documentation requirements
2. Oversight and Review Mechanisms
- Whether NHS CFS Wales is required to notify the complainant when a referral is closed without investigation
- Whether NHS CFS Wales is required to provide the contact details of the investigating officer or team when a referral is reviewed but not pursued
- Any internal review or quality assurance process used to validate decisions not to investigate fraud referrals
3. Interagency Coordination and Delegation
- The standard operating procedure for referrals passed to Local Counter Fraud Specialist (LCFS) teams at Health Boards (e.g. ABUHB)
- Whether NHS CFS Wales retains oversight or audit responsibility for referrals delegated to LCFS teams
- Any memoranda of understanding or referral protocols between NHS CFS Wales and NWSSP regarding shared or delegated case handling
NHSCFA response
1. Investigation Thresholds and Referral Handling
- The current criteria or threshold used by NHS CFS Wales to determine whether a fraud referral warrants formal investigation
- Internal guidance or policy documents outlining how referrals are assessed and classified as “non-fraud” without direct engagement with the complainant
- The process by which NHS CFS Wales records and closes referrals that are not investigated, including any audit trail or closure documentation requirements
The Organisation’s internal guidance and policies concerning investigation methods are confidential documents.
The information you requested is therefore, being withheld as it falls under the exemption in section 31(1)(g) & 31(2)(a) of the Freedom of Information Act. In applying the exemptions we have had to balance the public interest in withholding the information against the public interest in disclosing the information. The attached annex to this letter sets out the exemption in full, as well as the factors the Authority considered when deciding that in all the circumstances of the case, the public interest in maintaining the exemption outweighs the public interest in disclosing the information.
2. Oversight and Review Mechanisms
- Whether NHS CFS Wales is required to notify the complainant when a referral is closed without investigation
NHSCFA Wales is not required to notify complainants where a referral is closed without investigation
- Whether NHS CFS Wales is required to provide the contact details of the investigating officer or team when a referral is reviewed but not pursued
NHSCFS Wales is not required to provide contact details of a Local Counter Fraud Specialist to a complainant when a referral is reviewed.
- Any internal review or quality assurance process used to validate decisions not to investigate fraud referrals.
Guidance on review processes and policies used to investigate cases of fraud is confidential information.
The information you requested is therefore, being withheld as it falls under the exemption in section 31(1)(g) & 31(2)(a) of the Freedom of Information Act. In applying the exemptions we have had to balance the public interest in withholding the information against the public interest in disclosing the information. The attached annex to this letter sets out the exemption in full, as well as the factors the Authority considered when deciding that in all the circumstances of the case, the public interest in maintaining the exemption outweighs the public interest in disclosing the information.
3. Interagency Coordination and Delegation
- The standard operating procedure for referrals passed to Local Counter Fraud Specialist (LCFS) teams at Health Boards (e.g. ABUHB)
The allocation of cases for local investigation is dependent on the scale, complexity and number of health bodies involved in the fraud allegation.
- Whether NHS CFS Wales retains oversight or audit responsibility for referrals delegated to LCFS teams
The Head of the CFS Wales team has access to all LCFS cases in NHS Wales via the Clue Case Management System and reviews and approves all case actions or closures on the Clue system.
- Any memoranda of understanding or referral protocols between NHS CFS Wales and NWSSP regarding shared or delegated case handling
There are no MOUs or referral protocols between NHS CFS Wales and NWSSP regarding shared or delegated case handling as the NHS CFS Wales team are employed by the NWSSP.