NHS Requirement 6
The organisation identifies and reports on annual outcome-based metrics with objectives to evidence improvement in performance. This should be informed by national and local risk assessment, national benchmarking and other comparable data. Proactive and reactive outcomes and progress are recorded on the approved NHS fraud case management system.
Metrics should include all reported incidents of fraud, bribery and corruption, the value of identified fraud losses, the value of fraud recoveries, the value of fraud prevented, criminal sanctions and disciplinary sanctions.
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
- NHS Counter Fraud Manual
- The NHSCFA instructions and guidance on the use of the NHSCFA case management system.
- Approved NHS fraud case management system records
- Approved NHS fraud case management system weakness records
- Investigation files
- Evidence of proactive prevention and detection exercises
- NHSCFA Benchmarking data
- Counter fraud, bribery and corruption work plan
- Audit committee minutes
- A measured reduction in risk or expenditure
- NHSCFA circulars
- NHSCFA’s Intelligence Alerts, Bulletins and Local Warnings Guidance
- Results of thematic engagements
- Evidence derived from participation in the National Fraud Initiative (if appropriate)