The guidance documents on this page may be used to develop or adapt local policies, procedures and systems. Additional guidance is available on the NHSCFA Extranet (currently available to Local Counter Fraud Specialists and Directors of Finance).


Procurement fraud quick guides

The NHSCFA has produced a series of eight fraud prevention quick guides focusing on specific areas of fraud risk vulnerability in NHS finance and procurement.

Procurement accounts for a significant amount of NHS spend and activity, and procurement fraud is one of the NHSCFA's priority action areas for the 2019-20 financial year.

The purpose of the guides is to reduce the NHS’s vulnerability to procurement fraud by helping organisations to embed control measures and implement preventative action. Each quick guide covers the following topics:

  • Brief summary of the fraud risk
  • How to spot fraud
  • How to stop fraud from happening
  • How to report suspicions of fraud

The guides have been produced as part of a national exercise on the prevention of procurement fraud, which the NHSCFA is undertaking with NHS provider organisations during the 2019-20 financial year (please see below for more details). However, their content will be of interest to any NHS organisation as well as NHS suppliers.


Contract splitting (Disaggregate spend)

This quick guide has been developed to provide an understanding on contract splitting (also known as artificial disaggregation of spend) and how this practice increases the risk of fraud occurring in procurement processes by weakening control measures.

The document covers actions on how to control the practice and prevent fraud from occurring. This quick guide addresses the fraud risk area of Disaggregate spend in the national exercise.


Contract reviews

This quick guide has been developed to provide an understanding on the importance of conducting contract reviews to highlight fraud risk vulnerabilities in NHS contracts and actions to be taken to prevent and detect fraud.

The document includes actions to improve the governance and scrutiny of existing contracts. This quick guide addresses the fraud risk area of Contract management in the national exercise.


Buying goods and services

This quick guide has been developed to provide an understanding of the fraud risks when buying goods and services directly from suppliers; particularly maverick spending where goods, services, or works are purchased outside of the purchase-to-pay (P2P) system or without using a purchase order number, and outside of a contract, framework, or from non-preferred suppliers.

This quick guide addresses the fraud risk area of Purchase Order vs. non-Purchase Order spend in the national exercise.


Due diligence

This quick guide has been developed to highlight NHS organisations' roles and responsibilities with regard to preventing fraud, bribery and corruption in the procurement of good and services supply chain .

The document promotes good practice in this area and covers the types of due diligence NHS organisations should be undertaking in their supplier arrangements.


Suppliers' code of practice: preventing fraud, bribery and corruption

This code of practice has been created for the purpose of ensuring that NHS organisations and suppliers have regard for their role and responsibility for preventing fraud, bribery and corruption in the supply chain.

This guidance is intended for NHS procurement teams, who should share the document with the suppliers they work with. It is intended to complement existing guidance and codes of practice and provides direction to suppliers on what is expected from them when engaging with the NHS.


Mandate fraud

This quick guide has been developed to provide an understanding of mandate fraud, which is also known as a change of bank account scams, payment diversion fraud or supplier account takeover fraud.

This document covers actions staff should undertake to prevent and detect NHS mandate fraud and the control measures that should be in place to reduce the risk.


Petty cash

This quick guide has been developed to provide an understanding on the importance of being vigilant to fraudulent activity and loss relating to the management and control of petty cash.

The document highlights the vulnerabilities staff should be aware of and the control measures that should be in place to reduce the risk of fraud and theft.


Credit card

This quick guide has been developed to highlight the common fraud risks relating to the use of credit cards (sometimes referred to as purchasing cards) by NHS organisations.

This document covers actions staff should undertake to prevent and detect NHS credit card fraud and the control measures that should be in place to reduce the risk.


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Payroll fraud: Guidance on prevention, detection and investigation

This guidance document has been developed to provide an understanding of the payroll fraud threat facing the NHS as well as advice and guidance on how to respond to it effectively. It can be used to support work to prevent, detect and investigate the most common kinds of payroll fraud at a local level.

The document covers the following main categories of payroll fraud:

  • Misrepresentation of qualifications/skills or experience
  • Time-sheet fraud
  • Working while off sick
  • Expenses and allowances fraud

Invoice and mandate fraud: guidance for prevention and detection (updated February 2019)

This document provides guidance for Local Counter Fraud Specialists and finance staff working in the NHS on the prevention and detection of the most common kinds of invoice fraud at a local level.

Updated in February 2019, the document provides an introduction to the subject area, an overview of the NHS invoicing environment, and practical advice on the most effective ways of tackling invoice and mandate fraud and how to manage the risk of social engineering. The document also provides details of how to report suspected fraud and corruption.


Pre-contract procurement fraud and corruption: Guidance for prevention and detection

This document has been produced by the NHSCFA to provide Local Counter Fraud Specialists, procurement staff and finance staff working in the NHS with guidance to support work on the prevention and detection of procurement fraud and corruption at a local level.

The focus of the document is on pre-contract fraud and corruption. It reflects our current understanding of the key threats facing the NHS in these areas.

This document is intended to supplement existing polices, directives and guidance available more widely in the NHS by providing an overview of the pre-contract procurement process from a counter fraud perspective.

Management and control of prescription forms: A guide for prescribers and health organisations

The document has been produced by the NHSCFA to assist prescribers, organisations and their staff on effective and safe management control practices to prevent the fraudulent misuse of prescription forms. The guidance has been developed to support all types of commissioners and providers who are authorised to order prescription form stock.

The document replaces the security of prescription forms guidance which was published by our predecessor organisation NHS Protect.

Aide-mémoires

These aide-mémoires highlight and summarise the key points to bear in mind in the management and control of prescription forms.


Employment agency fraud: Guidance on reducing risks

The guidance in this document is intended as a framework for NHS organisations to develop or adapt their own policies, procedures and systems for dealing with employment agency fraud. The document focuses specifically on two areas of agency fraud risk, pre-employment checks and agency invoicing, and it provides a number of recommendations to help NHS organisations deal with these risks.