The Government Functional Standard for Counter Fraud (GovS 013: Counter Fraud) was initially launched across central Government Departments in 2018, with the purpose of setting expectations for the management of fraud, bribery and corruption risk in government organisations and wider public services, while reinforcing the government’s commitment to fighting fraud against the public sector. The Counter Fraud Functional Standard has since been developed and extended further across the public sector and was launched within all NHS bodies in January 2021.
Inherent within the Standard is the concept of a Counter Fraud Champion, a network of which has been in use within central Government since 2011. The role is a key strategic position within an organisation. Within the NHS it is seen as a vitally important part of the collaborative effort to tackle fraud, bribery and corruption and protect funds designated for patient care.
The role of the Counter Fraud Champion is an essential part of the NHS counter fraud community. By promoting and supporting a network of Counter Fraud Champions in all NHS organisations, the NHS Counter Fraud Authority (NHSCFA) seeks to strengthen the fight against fraud and raise fraud awareness in each individual organisation as well as across the NHS by sharing best practices and highlighting vulnerabilities.
The role and duties of a Counter Fraud Champion include:
- Providing a senior strategic voice within the organisation to champion the counter fraud agenda and to enable and support the counter fraud programme of work.
- Promoting and embedding an awareness of fraud, bribery and corruption across the organisation at a strategic level.
- Enabling, facilitating and supporting fraud prevention work at a senior strategic level.
- Removing any blocks to the progress of counter fraud work and driving forward a counter fraud culture across the organisation.
- Providing additional fraud fighting capability at a senior/strategic level which can support the Counter Fraud Functional Lead and the LCFS(s) in delivering their counter fraud work.
The Counter Fraud Champion nomination process
The Counter Fraud Champion role is envisaged as a function that can be added to an existing role, such as Deputy Director of Finance, Director of Risk, HR director, Operations Lead, a senior governance lead or a person who is in a senior and influential position within the organisation. They must also be employed directly by the organisation that they represent.
To nominate a Counter Fraud Champion, please complete sections B and D on the nomination form and email it to firstname.lastname@example.org. We will send the Counter Fraud Champion a link to the Counter Fraud Champion e-learning module. Once the Counter Fraud Champion has completed this, they will be part of the NHS counter fraud community and will have access to the Counter Fraud Champion network.
Frequently asked questions
Here are some commonly asked questions about Counter Fraud Champion .
The documentation you have issued details the role sitting at a strategic level. Can you clarify what is meant by this and provide an example role within an NHS organisation that would adequately cover your interpretation of strategic level?
Someone who is part of senior management and can influence at board level both within and between organisations. An example would be a Deputy Director of Finance or Senior Governance/Risk Lead.
Can the DOF/CFO be nominated as an organisation’s Counter Fraud Champion as they already have defined responsibility for fraud, bribery and corruption? If not, please explain.
Yes, the DOF/CFO can be the Counter Fraud Champion. We just ask that whoever takes on the Fraud Champion role is able to commit sufficient time to it.
Can a non-executive director be a Counter Fraud Champion?
Yes. Ideally, the Counter Fraud Champion should be directly employed by the organisation with a daily presence. A non-executive director, however, can be a Counter Fraud Champion so long as there is someone else on the board ultimately accountable for the management responsibilities of the organisation’s anti-fraud effort. A non-executive director cannot take on operational management responsibilities themselves.
Could an LCFS become a Counter Fraud Champion if they are employed directly by the health organisation they work within? If not, please explain.
No. The Counter Fraud Champion is a senior role and is responsible for supporting the counter fraud agenda at a strategic level within an organisation, rather than delivering the operational counter fraud function. This includes, where necessary, challenging the organisation’s commitment to counter fraud work and the existing level of counter fraud provision. In light of this, a Local Counter Fraud Specialist would not be suitable to be nominated as a Fraud Champion.
The Counter Fraud Champion will be expected to support and enable the LCFS(s) in discharging their responsibilities. The LCFS works on investigations and other counter fraud work at the operational level while the Counter Fraud Champion’s role is strategic. The Counter Fraud Champion does not take part in investigations but supports the counter fraud effort at the board level.
Many NHS organisations outsource their fraud provision to agencies and consortia. Can someone employed by the bought in service deliver the role of Counter Fraud Champion on behalf of the NHS organisation?
No. The Counter Fraud Champion should be employed directly by the organisation rather than contracted in as part of a service.
Can an organisation’s Freedom to Speak Up Guardian be appointed as the Counter Fraud Champion and perform both roles? A part of their role is already to signpost fraud concerns to the LCFS.
Yes, although only the Lead Guardian can undertake the counter fraud champion role and that is on the understanding that the Lead Guardian position at the organisation is not held by the LCFS.
Will the newly appointed Counter Fraud Champion be vetted by the NHSCFA? If so, what will this involve?
There is no vetting procedure for Counter Fraud Champions because the Counter Fraud Champions are already serving in senior roles within their organisations. They will become Counter Fraud Champions as soon as they have passed the initial e-learning module and registered fully on our system.
Will the newly appointed Counter Fraud Champion be required to undertake DBS checks before appointment?
DBS checking is a matter for the employer.
How many Counter Fraud Champion does the NHSCFA expect an organisation to have and is this number determined by the size of the organisation?
There can only be one Counter Fraud Champion nominated for each organisation. Counter Fraud Champions may choose to delegate some of their functions to members of their team or others within their organisation. Health bodies may also choose to let these or other colleagues use the title ‘Counter Fraud Champion’ if that helps their local counter fraud strategy, but only one person can be nominated to the NHSCFA as the individual holding the Counter Fraud Champion role.
Does the NHSCFA have a minimum number of hours a week/month that they expect the Counter Fraud Champion to work?
The NHSCFA does not expect a specific level of commitment to the role. We understand that requirements may vary across different organisations and it is up to the Counter Fraud Champions to do what is best for their organisations.
Will the Counter Fraud Champion play any role in an NHS criminal fraud investigation conducted by the LCFS?
No. The Counter Fraud Champion’s role is to stand above the day-to-day operational level of their organisation’s counter fraud effort and to assist that effort at the strategic level.
Will the Counter Fraud Champion have access to FIRST/CLUE?
No. The Counter Fraud Champion will not participate in active investigations.
Will the Counter Fraud Champion have access to Ngage, the extranet platform for the NHS counter fraud community?
Yes. We encourage Counter Fraud Champions to access Ngage regularly and to make use of the resources there. They will also have exclusive access to other communications channels such as newsletters for Counter Fraud Champions and bespoke webinars, workshops and events.
Is there any plan to deliver any additional training/input to the newly appointed Counter Fraud Champions outside of the initial eLearning module?
Yes. More material is in development and webinars are being held to cover various issues relevant to the Counter Fraud Champion role.
Is there now or planned for the future, a formal Counter Fraud Champion role specification document?
There is no formal Counter Fraud Champion role specification document because each organisation has a different context. The Counter Fraud Champion will adapt the role to their local circumstances. However, we acknowledge that the Counter Fraud Champion role may evolve over time to reflect changing fraud risks and challenges and we will work to provide all Counter Fraud Champions with the resources they need.