In July 2019, NHSCFA launched a fraud prevention campaign as part of the NPE. The campaign was a programme of prevention activity to influence behavioural change across the NHS procurement landscape, thereby effecting change in staff and organisational behaviours and a subsequent reduction on the reported PO vs non-PO spend baseline dataset (2018 – 2019). The campaign purposely targeted NHS staff in procurement and finance teams to educate and increase awareness of fraud risk vulnerability within finance and procurement processes. The range of activities and products NHSCFA provided to support behavioural change are as follows:
- Targeted workshops and focus groups
- Webinars for the counter fraud community
- Speaker engagements at NHS procurement & finance conferences
- Key stakeholder engagement with government and national bodies
- Series of engagement visits with NHS procurement and finance personnel
- A range of newly developed procurement fraud prevention guidance documents
- A toolkit designed to assist LCFSs with implementation and engagement activities on procurement fraud prevention.
NHSCFA collaborated closely with NHS procurement and finance staff to ensure the tone and content of the prevention material would be relevant and applicable to NHS processes and procedures. We listened to our NHS colleagues in terms of the final guidance design and layout of the NHSCFA series of eight fraud prevention quick guides focusing on specific areas of fraud risk vulnerability in NHS finance and procurement:
- Contract splitting (disaggregate spend)
- Contract reviews
- Buying goods and services
- Due diligence
- Suppliers’ code of practice: preventing fraud, bribery and corruption
- Mandate fraud
- Petty cash
- Credit card
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:
- Brief summary of the fraud risk
- How to spot fraud
- How to stop fraud from happening
- How to report suspicions of fraud
To further raise the profile of the campaign, NHSCFA staff presented at various conferences such as P4H, HCSA, CIPFA and the Australian 11th National Public Sector Fraud and Corruption Congress. There were also articles, webinars and locally held events. Exposure from the campaign project led to the NHSCFA playing a significant role in a cross-public sector working group on fraud and corruption in procurement, initially led by Ministry of Housing, Communities & Local Government and later, the Joint Anti-Corruption Unit at the Home Office.
Following completion of the baseline collection, the NHSCFA undertook site visits at 25 NHS organisations of varying sizes and types, meeting with Directors of Finance, Heads of Procurement, and LCFSs to identify the impact of the campaign, promote good practice and further promote implementation of NHSCFA’s fraud prevention materials.
Feedback obtained from the visits established that the campaign had supported internal policy and procedural change in many NHS organisations. Several key themes emerged from these engagement meetings, particularly around the difficulties associated with managing contracts and contract oversight within NHS organisations. The visits also revealed NHS organisations were undertaking reviews of local policies, procedures, and Standard Operating Procedures (SOPs) against the fraud prevention quick guides and developing action plans to raise awareness.
Assessing the impact
During the 2019 – 2020 period NHSCFA undertook an assessment of the impact of fraud prevention campaign which identified a total of 138 incidents recording the use of the quick guides to deter fraud following the release of them in the campaign. In addition, NHS organisations initiated 5,753 proactive measures as a result of the campaign. This included measures such as fraud awareness training, alerts sent to staff, local proactive exercises, and changes/reviews of organisational policy, procedures, or practice.
Fraud prevention activity was effective as early as April 2019 which saw NHSCFA reaching out to NHS organisation LCFSs, Directors of Finance and Audit Committee Chairs, updating them with the upcoming NPE and fraud prevention campaign.
Our analysis shows a positive correlation between NHSCFA-led fraud prevention activity, the behavioural change at NHS organisation level, and the reduction in FVE in procurement fraud.