One of the fundamental principles of any NHS organisation is a commitment to ensuring that public funds are used appropriately. It is therefore vital that all staff understand what fraud, bribery and corruption is, how it affects the NHS and could affect the CCG, and what they should do if they suspect fraud, bribery or corruption has taken, or is taking, place.
The CCG has a Counter Fraud Specialist to whom all suspicions of fraud should be reported. All referrals will be professionally investigated and treated with the utmost confidentiality.
The CCG’s Counter Fraud Specialist is:
360 Assurance, Oak House, Moorhead Way, Bramley, Rotherham S66 1YY
Main Office 0116 225 6114; Fax 0116 295 4099
If we are to succeed in reducing fraud, bribery and corruption to an absolute minimum, we need the help and vigilance of staff within the CCG. Staff have a vital role to play in putting a stop to the fraudulent actions of a dishonest few.
If you think that you have identified fraud, bribery or corruption:
DO …report your suspicion to your Counter Fraud Specialist immediately …keep any evidence safe …make notes on what you heard/saw
DON’T …rely on someone else to make the call …ignore it …contact any suspect yourself …start an investigation yourself …discuss your concerns with anyone other than the Counter Fraud Specialist
Remember, everyone has a part to play in the fight against NHS fraud, bribery and corruption. If you suspect it, report it!
If you would not feel comfortable speaking to somebody connected to the CCG, there are a number of other ways in which you can share your concerns:
- Complete a reporting form
- Call the NHS Protect Fraud, Bribery and Corruption Reporting Line on 0800 028 40 60 (Monday to Friday, 8am to 6pm).
The CCG’s Counter Fraud Specialist produces a quarterly newsletter, Fraudulent Times, which contains a variety of features including case studies, news about recent scams and advice about fraud prevention. The latest issue can be found below.
Fraud Awareness Month
November is Fraud Awareness Month. You can read about working whilst sick here
You can read a copy of a fraud policy article here
You can read an article about pre-employment checks here
What is Fraud, Bribery and Corruption?
Fraud by an individual is a dishonest attempt to either make a gain for themselves, or expose another to a risk of loss (an offence is therefore committed simply by dishonestly trying to increase the risk of a loss to another even if the attempt fails and no loss actually arises).
The Fraud Act 2006 came into force on the 15 January 2007 and introduced the general offence of fraud. This is broken into three key sections:
- Fraud by false representation
- Fraud by failing to disclose information
- Fraud by abuse of position
The Fraud Act also created a range of other offences which include:
- Possession and making or supplying articles for use in fraud (for instance forged identity documents)
- Fraudulent trading (sole traders)
- Obtaining services dishonestly
- Computer Misuse
The Bribery Act 2010 replaced the Prevention of Corruption Acts 1889-1916 and created two general offences of bribery:
- Offering or giving a bribe to induce someone to behave, or to reward someone for behaving, improperly and;
- Requesting or accepting a bribe either in exchange for acting improperly, or where the request or acceptance is itself improper.
The Bribery Act 2010 introduced a new corporate offence meaning that organisations will be exposed to criminal liability, punishable by an unlimited fine, for failing to prevent bribery.
How does Fraud, Bribery and Corruption affect the NHS?
Fraud, Bribery and Corruption can be found anywhere where money or valuable resources exist. With a total budget of over £110billion, the NHS is a prime target for fraudsters.
In 1998, in response to the risk posed by fraud, the NHS Counter Fraud Service was set up to oversee work to prevent and detect fraud within NHS systems and build a culture intolerant to fraud across NHS bodies. This organisation is now known as NHS Protect. The CCG’s Counter Fraud Specialist is accredited by NHS Protect to carry out work within commissioners and providers of NHS funded healthcare. NHS Protect has a public facing website which can be found here>> .
Since 1998 frauds have been detected and investigated across the whole range of organisations commissioning or providing NHS funded healthcare. Frauds have been uncovered involving patients, contractors, GPs, Dentists, Optometrists, Pharmacists, Consultants, Directors; in fact in every area of staffing. In short, fraud can strike anywhere and be committed by anyone. In particular, during times of economic uncertainty and change, the risk of fraud has been proven to increase. This is especially pertinent in the NHS at this time.
How might Fraud, Bribery and Corruption affect the CCG?
As a new organisation, the CCG has taken responsibility for a number of areas, with a significant level of public funding at its disposal. A variety of frauds have occurred in Primary Care in recent years. In most cases, fraud has arisen because proper checks have not taken place and the controls that do exist have not been sufficiently robust.
Detecting Fraud, Bribery and Corruption – what to look out for:
The CCG’s responsibilities cover a number of areas and account for a large sum of public expenditure. While it is not possible to provide an exhaustive list of potential frauds which could affect the CCG, the following list does attempt to describe the indicators of potential fraud, bribery and corruption that you may encounter at work:
- Data showing high performance compared to similar practices or organisations
- Lack of evidence to support claims for payment or for additional services
- Unexpected claims for payment
- A change in behaviour or performance when management changes
- Prescribing habits changing dependent on the pharmacy used by patients
- Inability to explain rationale for prescribing or clinical decisions based on clinical need
- Conflicts of interest causing business decisions to be made against the weight of evidence