NHS Requirement 2
The organisation aligns counter fraud, bribery and corruption work to the NHSCFA counter fraud, bribery and corruption strategy. This is documented in the organisational counter fraud, bribery and corruption policy, and is submitted upon request. The counter fraud work plan and resource allocation are aligned to the objectives of the strategy and locally identified risks.
(The organisation may have its own counter fraud, bribery and corruption strategy, however, this must be aligned to and referenced to the NHSCFA counter fraud, bribery and corruption strategy)
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):
- Organisations should consider the following (the list is not exhaustive):
- The NHSCFA strategy
- Counter fraud, bribery and corruption policy referencing the NHSCFA strategy
- Organisation over-arching strategy referencing the NHSCFA strategy
- Risk assessment materials
- Evidence of risk monitoring being conducted at a senior level
- Counter fraud work plan
- 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