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Any independent healthcare provider (IHP) who signs up to provide services under the NHS Standard Contract will be subject to either service condition (SC) 24.1 or SC 24.2 in relation to counter fraud work.

IHPs will be subject to SC 24.2 if both the following conditions apply:

  • they have a Monitor licence
  • they receive over £10 million of NHS income each year under the NHS Standard Contract

SC 24.2 mandates organisations to comply with our standards. This can include voluntary organisations and charities.

SC 24.1 relates to any other IHP and means they do not have to comply with NHSCFA counter fraud standards, but must pay due regard to them. This mainly applies to IHPs who do not have sufficient NHS-derived income to require a Monitor licence. However, a small number of Monitor licence holders will also fall into this category.

The relevant question here is whether or not the IHP receives NHS income of over £10 million each year under the NHS Standard Contract.

Two practical examples of where a Monitor licence holder may only need follow SC 24.1 are those organisations who receive less than £10 million each year via the Standard Contract; for example, their income may come from bespoke contracts. This is more likely to apply to providers of non-clinical services.

The second example relates to a small number of IHPs who need Monitor licences because they are deemed to be a CRS (commissioner requested service).

If a Monitor licence is issued to a CRS, then the question to be answered is whether or not they receive over £10 million NHS income each year under the Standard Contract. If they do not receive more than that amount, they need to follow SC 24.1. If they do receive over that amount, then they need to follow SC 24.2.

Any IHP who is in any doubt as to whether or not they need to follow SC 24.1 or SC 24.2 can email Fiona McIlwraith, National Quality Lead, at

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We estimate that the NHS is vulnerable to £1.21 billion worth of fraud each year.

Report any suspicions or concerns about fraud against the NHS to the NHSCFA.

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