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.
Note
This requirement directly relates to the organisation's defence in respect of the failure to prevent fraud offence as introduced by the Economic Crime and Corporate Transparency Act 2023. Guidance focusing on the failure to prevent fraud offence has been produced by the Home Office, with supplementary guidance produced by NHSCFA.
As the Counter Fraud Functional Standard Return (CFFSR) is a self-assessment, a GREEN rating does not in itself provide any assurance of the organisation’s defence in respect of the offence. The NHS Requirements and CFFSR can be used as tools to indicate the organisation’s preparedness for a defence; however, value is directly linked to the accuracy with which the organisation’s counter fraud position has been reflected and standard of procedures and other evidence available.
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/report-fraud
- 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.