GovS 013 component 2: Counter fraud bribery and corruption strategy

Have a counter fraud, bribery and corruption strategy that is submitted to the centre

GovS 013 ref: 4.2.2

Published: 08/02/2022

Version: 2.0

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)

Organisation meets the requirement

The impact of the organisation counter fraud, bribery and corruption strategy has been evaluated, and the counter fraud work plan or counter fraud resources has been updated as required as a result.

There is significant evidence of the organisation counter fraud work plan or counter fraud resource allocation being aligned to key objectives of the strategy and locally identified risks.

Evidence of the organisation counter fraud, bribery and corruption strategy is provided to NHSCFA on request.

Organisation partially meets the requirement

The organisation counter fraud, bribery and corruption strategy is aligned to NHSCFA’s strategy, and it has been approved at senior management or executive level.

There is little or no evidence of the organisation counter fraud work plan or counter fraud resource allocation being aligned to key objectives of the strategy or locally identified risks.

Organisation does not meet the requirement

The organisation does not have a counter fraud, bribery and corruption strategy.

The organisation counter fraud, bribery and corruption strategy does not align with NHSCFA’s strategy.

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