Introduction and overview of the new Government Functional Standard 013 for counter fraud

This functional standard exists to create a coherent, effective and mutually understood way of doing business within government organisations and across organisational boundaries, and to provide a stable basis for assurance, risk management, and capability improvement.

This document aims to provide assistance to NHS funded services on how to meet the requirements of the Government Functional Standard 013: Counter Fraud (Functional Standard) and explain what NHS funded services need to do to comply with them.

As part of the NHSCFA support for the Government Digital First strategy the NHS Requirements for the Government Functional Standard are only available as an online digital service, however, each Requirement can be printed if required, though not recommended.

The NHS Counter Fraud Authority (NHSCFA) is a Special Health Authority, established on 1 November 2017 and charged with identifying, investigating and preventing fraud within the NHS and the wider health group. The NHSCFA is independent from other NHS bodies and is directly accountable to the Department of Health and Social Care.

NHSCFA’s vision and purpose is to lead and proactively support the NHS to understand, find, prevent and respond to fraud. A collaborative approach is at the heart of the NHSCFA strategy. To that end NHSCFA provides the wider NHS with the support, guidance and tools to enable effective counter fraud responses at national and local levels.

In providing this support to NHS funded services NHSCFA drawn from its expertise and experience of setting counter fraud standards; in doing so NHSCFA have interpreted the Functional Standard for the NHS.

Every year NHSCFA is required to provide assurance to Cabinet Office of how the NHS is identifying and mitigating the risk of fraud, bribery and corruption. Consequently, NHS funded services will be required to provide NHSCFA details of their performance against the Functional Standard annually.

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The term ‘NHS funded services’ above refers to any organisation with partial or full NHS funding, currently this includes: NHS Trusts, Foundation Trusts, Ambulance Trusts, |Special Health Authorities, Integrated Care Boards, certain Independent Healthcare Providers, and NHS England.

The Functional Standard was launched as a pilot in October 2018, initially it solely applied to government departments and their arms-length bodies. The purpose of the Functional Standard is to set the expectations for the management of fraud, bribery and corruption risk in government organisations and wider public services, while reinforcing the government’s commitment to fighting fraud against the public sector.

The Cabinet Office-hosted Counter Fraud Centre of Expertise formally published the Functional Standard in June 2020 following an extensive trial period, where it has been adopted in more than 100 public bodies including DHSC, NHSCFA and other NHS arms-length bodies. The publication was subject to successful review and clearance by members of the government’s Counter Fraud Functional Board with endorsement by Lord Agnew, Cabinet Office Minister of State.

From April 2021 all NHS organisations will be required to provide assurance against the Functional Standard. This should be overseen by the organisation’s finance director and audit committee and in line with the organisation's existing approach to assurance against counter fraud requirements.

The NHSCFA will support the integration into the NHS and will be responsible for receiving Counter Fraud Functional Standard Returns (CFFSR). The NHSCFA will be engaging with the NHS to review compliance.

A detailed explanation for each of the Government Functional Standard NHSCFA Requirements is given including, an indication of what each organisation needs to do to comply with the requirement.

Subsidiary Companies

Subsidiary companies are separate legal entities and can be up to 100% owned by NHS organisations and it is often the case that trust board members also sit on the subsidiary board.

NHS foundation trusts have power under Section 46 of the NHS Act 2006 to form subsidiary companies for the purposes of, or in connection with, the exercise of their functions – that is, for purposes of core NHS healthcare provision.

In order to reflect the changing nature of the NHS these requirements also apply, subject to the qualifying criteria, to any subsidiary company of an NHS Foundation Trust / Trust.

This qualifying criteria for a subsidiary company to adhere to these requirements is based on the financial reporting of the parent NHS Foundation Trust / Trust, and whether the subsidiary company is consolidated into the NHS Foundation Trusts / Trusts annual accounts. If the subsidiary company is consolidated in the annual accounts, then the subsidiary company is required to adhere to the requirements.

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