NHS Requirement 1A:
A member of the executive board or equivalent body is accountable for provision of strategic management of all counter fraud, bribery and corruption work within the organisation. The accountable board member is responsible for the provision of assurance to the executive board in relation to the quality and effectiveness of all counter fraud bribery and corruption work undertaken.
The accountable board member is responsible for ensuring that nominations to the NHSCFA for the accountable board member, audit committee chair and counter fraud champion are accurate and that any changes are notified to the NHSCFA at the earliest opportunity and in accordance with the nominations process.
N.B. 'Equivalent body' may include, but is not limited to, the board of directors, the board of trustees or the governing body. Oversight of counter fraud, bribery and corruption work should not be delegated to an individual below this level of seniority in the organisation.
Guidance, supporting documentation and evidence
Organisations should consider the following (the list is not exhaustive):
- Board meeting minutes
- Organisational counter fraud, bribery and corruption work plan
- Annual report on counter fraud, bribery and corruption work
- Progress reports to the audit committee, board or executive level managers
- Minutes of relevant meetings, action points and records of their execution
- Audit committee minutes
- Standing Orders/Standing Financial Instructions
- Evidence of the supply of counter fraud, bribery and corruption information to coordinating commissioners. This may include, but is not limited to, the functional standard return, the annual report of counter fraud work and the counter fraud work plan.
- NHSCFA benchmarking data
- Documentation from the nominations process
NHS Requirement 1B:
The organisation’s non-executive directors, counter fraud champion or lay members and board/governing body level senior management are accountable for gaining assurance that sufficient control and management mechanisms in relation to counter fraud, bribery and corruption are present within the organisation.
The counter fraud champion understands the threat posed and promotes awareness of fraud, bribery and corruption within the organisation.
Board level evaluation of the effectiveness of counter fraud, bribery and corruption work undertaken is documented. Where recommendations have been made by NHSCFA following an engagement, it is the responsibility of the accountable board member to provide assurance to the board surrounding the progress of their implementation.
The organisation reports annually on how it has met the requirements set by NHSCFA in relation to counter fraud, bribery and corruption work, and details corrective action where requirements have not been met.
Guidance, supporting documentation and evidence
Organisations should consider the following (the list is not exhaustive):
- The NHSCFA strategy
- Meeting minutes, decisions, action points and records of their execution, particularly for decisions taken at board level
- Audit committee minutes evidencing monitoring and evaluation of counter fraud work conducted in compliance with the counter fraud functional standard
- Documentation from the nominations process
- A nominated Counter Fraud Champion.
- Communications to staff directly attributed to the Counter Fraud Champion
- Counter fraud, bribery and corruption work plan
- Communications to staff directly attributed to the chief executive and/or board members, particularly communications to all staff
- Documentation arising from any NHSCFA engagement process
- Evidence of the implementation of any recommendations made by the NHSCFA as part any engagement
- NHS Audit Committee Handbook (relevant sections)
- Evidence that the Audit Committee Chair has an NHS.net account or an organisational account
- Annual report on counter fraud, bribery and corruption work
- Fully completed functional standard return
- Relevant meeting minutes, action points and records of their execution
- Action plan made as part of any NHSCFA engagement