Mapping of previous NHS counter fraud standards

As of April 2021, the Government Functional Standard 013: Counter Fraud (Functional Standard) replaces the previous NHS specific Standards for Fraud, Bribery and Corruption (Standards).

Together with stakeholders the NHSCFA have developed new NHS Requirements to meet the Functional Standard. The mapping tables below provides detail of where previous Standards are aligned to the new NHS Requirements.

Key Principle 1: Strategic governance
NHSCFA Standard		Functional Standard	Notes
1.1	A member of executive board accountable	Component 1 NHS Requirement 1A
1.2	Non-executive or lay members accountable for assurance	Component 1 NHS Requirement 1B
1.3	Employs/contracts accredited LCFS	Component 9 NHS Requirement 9
1.4	Comprehensive risk assessment	Component 3 NHS Requirement 3
1.5	Annual report	Component 1 NHS Requirement 1B
1.6	Counter fraud work necessary tools and resources		Referenced in NHS Requirements 3 and 5.
1.7	Lines of communication		Referenced in NHS Requirements 3, 5 and 7. Includes evidence in the use of the approved NHS Fraud Case Management System.

Key Principle 2: Inform and involve
NHSCFA Standard		Functional Standard	Notes
2.1	Ongoing programme of fraud awareness	Component 11 NHS Requirement 11
2.2	Fraud, bribery and corruption policy	Component 4 NHS Requirement 4
2.3	Liaison with organisations and agencies		Manual of guidance advises on information requests. Further evidenced by use of the approved NHS Fraud Case Management System.
2.4	Code of conduct (inc Bribery Act 2010)	Component 12 NHS Requirement 12

Key Principle 3: Prevent and deter
NHSCFA Standard		Functional Standard	Notes
3.1	Review policies		Manual of guidance.
3.2	Use of info/intel to ID anomalies FBC	Component 10 NHS Requirement 10
3.3	Issue, implement, comply with FBS intel bulletins		Amalgamated into NHS Requirement 10
3.4	Pre-employment checks		Amalgamated into NHS Requirement 10
3.5	Prevent, deter, detect - Procurement		Amalgamated into NHS Requirement 10
3.6	Prevent, deter, detect - Invoice		Amalgamated into NHS Requirement 10

Key Principle 4: Hold to account
NHSCFA Standard		Functional Standard	Notes
4.1	Record on case management system (CMS)	Component 8 NHS Requirement 8
4.2	Use CMS in investigations	Component 8 NHS Requirement 8
4.3	Pursue sanctions		Manual of guidance. Further evidenced by use of the approved NHS Fraud Case Management System.
4.4	Witness statements		Evidence for NHS Requirement 9
4.5	Interviews under caution		Evidence for NHS Requirement 9
4.6	Recovery of losses		Manual of guidance. Further evidenced by use of the approved NHS Fraud Case Management System.