NHS Requirement 5
The organisation maintains an annual work plan that is informed by national and local fraud, bribery and corruption risk assessment identifying activities to improve capability and resilience. This includes (but is not limited to) defined objectives, milestones for the delivery of each activity and measurable areas for improvement in line with strategic aims and objectives. The plan is agreed, and progress monitored by the audit committee (or equivalent body).
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):
- Counter fraud, bribery and corruption work plan
- Audit committee minutes
- National and locally based risk assessments
- NHS Audit Committee Handbook (relevant sections)
- Other evaluation materials such as reports on proactive exercises
- Evaluation materials resulting from participation in national exercises
- A measured reduction in risk or expenditure
- Documentation arising from any NHSCFA engagement
- Evidence of the implementation of any recommendations made by the NHSCFA as part of any engagement
- Internal audit reports
- Increased compliance with policies and procedures
- Examples of where findings have been suggested for policy development
- Examples of where findings have influenced policy development