Counter Fraud Action Plan

Sets out the recommendations and actions to be consider by the sector

Recommendation(s) Action(s) Priority Owner
1. Health Sector CFB to review the effectiveness of centralised support / coordination for NHS organisations in sourcing and procuring essential equipment during the onset of Covid-19. An enhanced understanding of overseas markets and use of intermediaries should form the core support mechanisms provided in future emergency management scenarios. HIGH Health Sector CFB, DHSC, NHSE&I
2. NHSE&I and individual NHS organisations to drive improvements in due diligence capability. HIGH NHSE&I, NHS organisation, Director of Finance, LCFS
3. NHS organisations to continue to implement and review the appropriateness of their fraud risk management regime under both: business-as-usual and emergency management scenario circumstances. MEDIUM NHS organisation, Director of Finance, LCFS
4. NHS organisations to ensure there are adequate requirements for staff to record: decisions, actions taken, and risk assessments on procurement activity (by way of organisational policy). Suitable mechanisms for maintaining such records should also be put in place; this is likely to derive from contract management software platform. MEDIUM NHS organisation, Director of Finance, LCFS
5. NHSCFA to review and update its existing procurement fraud prevention guidance (available on the NHSCFA website), taking into consideration the outcomes from this exercise. MEDIUM NHSCFA

Our classification system is defined in appendix 3 of this report.

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