NHS Requirement 7
The organisation has well established and documented reporting routes for staff, contractors and members of the public to report incidents of fraud, bribery and corruption. Reporting routes should include NHSCFA’s Fraud and Corruption Reporting Line and online reporting tool. All incidents of fraud, bribery and corruption are recorded on the approved NHS fraud case management system.
The incident reporting routes are publicised, reviewed, evaluated and updated as required, and levels of staff awareness are measured.
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 organisation’s counter fraud, bribery and corruption policy
- Links to the NHSCFA online fraud reporting tool https://cfa.nhs.uk/report-fraud
- Materials and supporting evidence to show that the incident reporting routes has been communicated across the organisation
- Evaluation measures such as staff surveys or sample checks
- Evidence of the review of the incident reporting routes and subsequent amendments to it where appropriate