Building up a local counter fraud service
An interview with Lee Sheridan, Head of Counter Fraud at Gloucester Shared Service for NHS.
Work by local counter fraud providers is more important than ever after the launch of NHSCFA, which is driving improvements in the standards of counter fraud work across the NHS and wider health group. James Robertson, the NHSCFA's Senior Media Relations Officer, asked Lee Sheridan, Head of Counter Fraud at Gloucestershire Shared Service for NHS for his perspective on a changing landscape.
Well James, it is as busy as ever here. We have recently dealt with a direct payment fraud which resulted in a guilty plea and recovery of £17,000. The case attracted media interest which will be useful for future presentations, as direct payment/personal health budgets is an area of emerging risk. I have another significant case which is shortly reaching conclusion, but watch this space in the months ahead! Both cases have been result of three years’ hard work!
The media play an important part in spreading the counter fraud message. The BBC is always very keen to report on my team’s work – people like Steve Knibbs, who covers Gloucestershire for BBC One West. We also have a good relationship with the local media. We are fortunate to be well supported in our publicity efforts by my client NHS trusts’ comms departments.
Gloucestershire is a very well established unit, comprising three LCFSs including myself, all of whom have an enforcement background whether in the local authority, DWP or police. Building the service up has taken a combination of many things; all the historical contacts you build up over the years count, but key people retire or leave, so you must get out and about, refreshing those networks. One very important relationship for us, for obvious reasons, is with Gloucestershire Police. We work together on joint investigations, and they are very keen to promote our work.
Aside from the reactive work, I am a firm believer that an effective local counter fraud service should create a large proportion of their own workload to ensure that awareness is raised and best practice is shared and promoted proactively. Because of that, you come into contact with a variety of agencies and this can lead to being invited onto various committees. We are members of a group focused on organised crime, hosted by Gloucestershire Police and made up of various enforcement bodies. We have regular meetings with all the local authorities in the county.
I am a member of the NHS national fraud managers group. It is all part of networking to share initiatives and good practice. As a result of that, we have organised a national conference in Newcastle on 28 June. Between us, we have all used our contacts to get speakers from the CPS, City of London Police, NHS England fraud department, NHS CFS Wales and more. It is all about building networks.
I was an LCFS for 12 years. I was quite blinkered because I didn’t see the bigger picture, I didn’t see the benefits of networking. Now I have gone to the next level in this management role, I can see it is the way forward – partnership working. You need the support, partly because it can be an isolating role. There are 15-16,000 NHS workers in our county and only three LCFSs. A nurse can easily speak to a doctor, a consultant… who do we speak to? It requires more of an effort for us to link up others in our field.
With the transition from NHS Protect to NHSCFA, there have been changes that take some adjusting to. For example, there are no longer regional meetings, which is a shame as I think gatherings of this kind are imperative to the services we deliver. In the South West we have put that regional meeting back in place and this has been exceptionally well supported by NHSCFA. We have had speakers including your CEO, Sue Frith, Jayson Gall [Senior Quality and Compliance Inspector], Patrick Kelly [Senior Information Management Officer] and Iain Henderson [Social Media Officer]. We’ve also had speakers from the Cabinet Office, and from the police – talking about cyber fraud.
Building local networks with other local LCFSs is important to enable you to share local risks and best practice. We also conduct benchmarking reviews comparing the number of cases between different NHS bodies across the South West where possible to support this further.
The investigation side to the role is a very small fraction of the work we need to do. It is a very strategic role and very few enforcement roles within the public sector roles have such a broad job description. It is both reactive and proactive, ranging from raising awareness to reviewing policies and presenting reports to audit committees, on the strategic side.
In my experience, LCFSs are dedicated individuals and the colleagues I work with in Gloucestershire and those I meet nationally are proud of their work ethics. It is difficult at times when you are working on a particular case to say ‘That is enough, it is time to go home.’ And it is frightening if you switch on your computer at night; you see that the LCFS network comes alive.
When you hear of NHS ‘hardworking staff’, you immediately think of the frontline clinical staff and their long hours. Support roles like ours don’t always get the acknowledgment but in Gloucestershire we are quite fortunate there are three of us. For a new LCFS working in isolation, I think it can be a lonely role, a daunting experience. I feel the loss of the AAFS (Area Anti Fraud Specialist) role – that was a really good shoulder to use, to chat something through.
All my clients ask the question: how do we sit with our neighbouring organisation? The LCFS community struggles with the lack of intelligence from NHSCFA. The launch of the £1.27 billion table was really interesting, it stimulated a huge amount of questions. “Where are the fraud risks associated with the acute sector?” … “Where are the fraud risks in mental health?” … “Where, in a CCG?” … “How many allegations have there been in relation to sickness?” and so on. That is the bit we are not getting from the intelligence side. Whilst locally we do this to the best of our ability with colleagues from Somerset, Devon and Cornwall, a national perspective would be hugely beneficial, it is what organisations are seeking and would further develop the LCFS role and enable us to focus our efforts where it counts.
Ultimately, we are all here to protect the public purse, but we are all, at times, working in silos. For example, we are all trying to do counter fraud e-learning packages and that is the way forward. Rather than every organisation trying to develop their own learning package, let us have a national one. There is no point me investing £5,000 in an e-learning package when one could be developed centrally which could encourage consistency of message and would be guaranteed to be fit for purpose when inspection time comes.
I welcome any training that is available. We have just become members of a Midland Fraud Forum hosted by various constabularies. This is a potential way to get more training, which is difficult to source.
Going forward I think we’ve got the blueprint, with people putting back those regional meetings and the support process involved – the cup of tea, the “What do you think of this? What do you think of that?”. I am someone who always sees there is the room to make it better, and always feels keen to work with anyone we possibly can, including NHSCFA.
Under the old Compound Indicator Process, anyone who hit a level 4 [rating] was available to share that. Under the new process including the self review tool, it would be nice to have a library kept of good practice.
Last year we commissioned City of London Police to run a three-day training event on bribery, which we then sold to LCFSs in the South West and local authorities. As a result of splitting the costs, we probably saved the group of organisations about £10,000 in total.
LCFSs have realised there is no longer a national training department, or centrally organised network of meetings, that we have to do it ourselves, take responsibility for it.
My message is really that the more people you network with, the higher you raise the profile of what you do, it spreads the word. As a result of that, people want to work with you. You see more referrals. The LCFS shouldn’t be a role where you only get seen when there is an allegation. It should be a department of prevention, which is better than cure. One initiative this year was to run a staff survey. In the past I wasn’t a great believer. But working jointly with a client you can do a county-wide staff survey and use the data for benchmark purposes. We had close to a 48% completion rate, fabulous. The average response rate is usually between 10% and 14%.
LCFSs and fraud are often not seen as a priority, so we need to keep raising the profile. I always welcome national-level counter fraud publicity. As an LCFS, ideally you want to feature local cases, that is a really powerful message to your local audience. But these can be supplemented with cases from other regions.
Very. People become confident in you as an individual if you have high personal standards. You have got to have a moral compass, and practise what you preach. It is no good saying, “You have all got to complete your timesheet accurately” if we don’t do it ourselves. You are there to be “shot at”.
Yes. It does give you a certain view of society!
People say Gloucestershire is a big village, and everyone knows each other. You can think you know a person fairly well, and then you could be doing an investigation into them. That can be quite difficult. So when you walk into a pub you don’t immediately relax, the first thing you do is look around for a few minutes.
It is imperative as an LCFS that you deal with people in a professional setting. It is not personal. However the person under investigation will have all sorts of personal relationships. Sometimes everybody loves them, and it can be part of their modus operandi to be charming, to win the trust and affection of people around them, so they don’t observe them critically, and it can also be used to commit fraud.
Compassion counts, absolutely. In my experience fraud is not only done for greed. There can be other reasons and it is important to ask ourselves – why It could be that they have an addiction or other issues. You have got to be very understanding. If you can put someone at ease, they are more likely to talk to you. If not, they can feel the atmosphere and their barriers go up. People skills are very important in the LCFS role.
There must be no assumption of guilt. You are purely a factfinder. It is important when that person under suspicion comes in, there are no preconceived ideas about them. The job is not to find their guilt – the fact is they might be innocent.
We are not different to any other county [in terms of people’s propensity to commit fraud]. My predecessor 14 years ago took the decision to split reactive and proactive, and that is still the model we operate to this day. So I have an LCFS responsible purely for investigations and one for proactive work, and the rest we do between us.
Staff here appreciate the face-to-face. We are doing a lot of drop-in sessions. We place ourselves in an office and say come and talk to us, face to face. It takes just that one person to come forward and say something is not quite right, and all of a sudden you could have a million pound fraud on your hands. People are grateful if they are used to getting everything by email, if you give them a story in person. That is what they remember.
We are the internal police of the NHS, aren’t we? It can at times be quite a threatening message that we deliver: “if you mess up, we are here and we are going to catch you”. But if delivered well, and made humorous, that is what they will remember. We give some top tips.
Many say, “What you do must be top secret!” What I encourage my team to do is go out in the community, meet people. If you want them to come forward, people must have confidence in you and the system as well.