GovS 013 component 4: Policy and response plan

Have a policy and response plan for dealing with potential instances of fraud, bribery and corruption

GovS 013 ref: 4.4

Published: 08/02/2022

Version: 2.0

NHS Requirement 4

The organisation has a counter fraud, bribery and corruption policy and response plan (the policy and plan) that follows NHSCFA’s strategic guidance and has been approved by the executive body or senior management team.

The plan is reviewed, evaluated and updated as required, and levels of staff awareness are measured.

Organisation meets the requirement

There are significant levels of staff knowledge and awareness of the existence of the policy and plan. Levels of awareness are routinely measured, and any resulting corrective or preventative action is implemented and evaluated.

Organisation partially meets the requirement

The organisation’s policy and plan are in line with the NHSCFA’s strategy, and it has been approved at senior management or executive level, implemented and communicated across the organisation.

There is little or no evidence of the organisation assessing staff awareness and understanding of the requirements and responsibilities set out by the policy and plan.

Organisation does not meet the requirement

The organisation does not have a policy and plan, or where one exists, it is not publicised, or it is out of date.

The organisation’s policy and plan does not meet NHSCFA requirements and it is not in line with the NHSCFA’s strategy.

The policy and plan have not been approved by the organisation at senior management or executive level.

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 counter fraud manual resource document ‘Template Local Counter Fraud, Bribery and Corruption Policy’
  • The organisation’s counter fraud, bribery and corruption policy and response plan
  • The NHSCFA strategy
  • NHS Counter Fraud Manual
  • Standing Orders/Standing Financial Instructions
  • Relevant meeting minutes, action points and records of their execution
  • Materials and supporting evidence to show that the plan has been communicated across the organisation
  • Evaluation measures such as staff surveys or sample checks
  • Evidence of the review of the plan including subsequent amendments to it where appropriate