NHS Requirement 11

The organisation has an ongoing programme of work to raise awareness of fraud, bribery and corruption and to create a counter fraud, bribery and corruption culture among all staff, across all sites, using all available media. This should cover the role of the NHSCFA, LCFS and the requirements and national implications of Government Counter Fraud Functional Standard providing a standardised approach to counter fraud work.

Content may be delivered through presentations, newsletters, leaflets, posters, intranet pages, induction materials for new staff, emails and other media, making use of the NHSCFA’s fraud awareness toolkit as appropriate. The effectiveness of the awareness programme is measured.

Organisation meets the requirement

The organisation has an ongoing programme to raise awareness of fraud, bribery and corruption issues among all staff, using a range of methods that are appropriate to different staff groups. There is evidence that presentations and other awareness materials are targeted to specific staff groups.

The organisation meaningfully evaluates the success of the programme and measures levels of awareness.

The results of the evaluation inform future work planning and, specifically, future awareness work.

Organisation partially meets the requirement

The organisation has an ongoing programme to raise awareness of fraud, bribery and corruption issues among all staff using a range of methods. This may include induction, presentations, newsletters, posters and other awareness materials. The awareness work carried out is in line with NHSCFA’s strategy.

The correct channels for reporting suspicions of fraud, bribery and corruption are publicised.

Appropriate case examples are used in awareness materials.

Advice is taken from the organisation’s communications team, and where appropriate from the Organisational Development team at the NHSCFA.

The organisation’s media policy is adhered to at all times, with due regard to media handling guidance from the NHSCFA.

There is limited or no evaluation of awareness work carried out or, where evaluation has been done, this is not recent or there is no meaningful demonstration of impact.

Organisation does not meet the requirement

The organisation has not raised awareness of fraud, bribery and corruption issues among staff and has not attempted to create a counter fraud, bribery and corruption culture.

Where some work to raise awareness of fraud, bribery and corruption issues has taken place, it is extremely limited in scope and reach.

The awareness work carried out does not take identified organisational local risks into account.

The awareness work carried out is not fully in line with NHSCFA’s strategy.

Guidance, supporting documentation and evidence

Organisations should consider the following (the list is not exhaustive):

  • The NHSCFA strategy
  • Links to NHSCFA’s online fraud reporting tool https://cfa.nhs.uk/reportfraud
  • Presentations
  • Intranet, extranet and public website materials
  • Organisation newsletters and team briefs
  • Induction materials
  • Leaflets and posters
  • Presentation evaluations
  • Evidence of where awareness work has been evaluated and changed to maximise its impact
  • Learning aims and outcomes
  • Staff surveys
  • Work plans
  • Organisational risk assessments
  • Meeting minutes, action points and records of their execution
  • Materials in the NHSCFA’s fraud awareness toolkit.