October 2020 - the NHS Counter Fraud ...
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
HSCFA 2020-2021 N Business Plan October 2020
NHSCFA 2020-2021 Business Plan 2 NHSCFA 2020-2021 Business Plan 3
Foreword by the CEO Sue Frith
Welcome to our NHSCFA 2020-21 work of our specialist counter fraud teams
business plan which sets out what the and the support of our Board and the
NHSCFA will deliver this year. Department of Health and Social Care
sponsor.
As a special health authority focussed
entirely on NHS counter fraud work and However, with an estimated annual
independent from other NHS bodies, loss of over £1.2bn NHS fraud remains
the NHSCFA is directly accountable to a significant risk and we cannot be
Ministers through the Department of Health complacent. Fraud against the NHS is
and Social Care (DHSC). particularly despicable as it diverts precious
resources from patient care and negatively
The impact on the NHS from the Covid 19 impacts the health service’s ability to meet
pandemic has been huge and I would like people’s needs. As fraud is a hidden crime,
to thank all of our colleagues across the we will remain constantly vigilant in our
NHS for their hard work and dedication at review of fraud risks, we will continue to
such a difficult time. Covid 19 has also had improve our understanding of how the fraud
an impact on the NHS fraud landscape; landscape is changing and identify where
criminals will always take advantage of we can make the most impact to protect the
crisis situations. As the NHS faces possibly NHS and reduce financial loss.
the greatest challenge since its creation,
at the NHSCFA we have been doing all To do this the NHSCFA regularly reviews
we can to support our colleagues on the the available intelligence to draw a strategic
frontline of the NHS. We have focussed picture of fraud across the NHS and
our fraud work on the changes to the identify key thematic fraud risk areas. This
fraud threats, vulnerabilities, and enablers information is used to not only assess fraud
associated with Covid19, identifying and risk and estimate the value of loss, but also
sharing that risk information with our to understand in more detail the threats,
NHS counter fraud colleagues. We have vulnerabilities, enabler to fraud across
reviewed and updated our plans to address the whole system. It is essential that the
those risks alongside continuing to deliver NHSCFA understands the capability within
our existing counter fraud work to shield the system to effect change so that we can
the NHS from fraud. We have supported innovate and offer counter fraud solutions
key Covid 19 workstreams - procurement of that support the NHS to implement best
Personal Protective Equipment and the new practice to prevent fraud loss.
Test and Trace programme - with counter
fraud resource and expertise. Innovation is key to the development
of action to tackle fraud. The NHSCFA
Since our launch in November 2017 the will develop and deliver collaborative
NHSCFA has delivered on the commitment intervention with NHS organisations. We
made to Ministers to reduce fraud in the will tailor this approach to support NHS
NHS by £300m by 2021. This was reached organisations and help them identify and
in 2019 through collaborative work with our address local fraud risks effectively. We will
NHS partners, the dedicated innovative provide opportunities to share local andNHSCFA 2020-2021 Business Plan 4 NHSCFA Strategy
2020-20212020-23
Business Plan 5
national counter fraud expertise and work
in collaboration with the NHS to support
activity within Help with Health Costs
with our partners the NHSBSA. Contents
the development of value for money • We continue to progress work to
counter fraud services. Most importantly ensure that monies with general Foreword 3
we will innovate change that encourages practice are not lost to fraud and
and mobilises local and national fraud the allocation is distributed fairly and Our Vision, purpose and strategic objectives 6
resources to tackle risk in partnership. effectively using a range of methods
to understand and highlight areas of At a glance - our successes by 2023 7
In 2019-20 working in partnership across concern.
the NHS the NHSCFA successfully How we work:
delivered against its first financial target of We will identify savings by preventing loss Our Business Model 8
£127m. By directing resources at high risk or reducing vulnerability to fraud across all Our integrated approach to delivery 9
areas, we were able to prevent and detect these areas.
fraud and recover monies to be re-invested Our Delivery Plans for 2020-21:
in NHS care. To achieve our strategy commitments, Lead and Influence 12
we need every individual and every Reduce Fraud Loss 13
The new NHSCFA three-year strategy organisation to take responsibility for finding Support and empower our people 16
sets out our commitment to meet a £400M and fighting fraud. This is a challenge Effective use of our resources 17
fraud detected, prevented and recovered and one we share with the wider public
target, and this business plan describes sector. We will work with partners across Our Portfolio of Key Corporate Projects:
the first year of our delivery against that government, the NHS and the public sector Lead and Influence 18
target. The impact of the pandemic makes to deliver the NHSCFA’s commitment to Reduce Fraud Loss 18
this challenging but through our integrated reduce financial loss to the NHS from fraud. Support and empower our people 18
approach to planning we are in a strong Effective use of our resources 18
position to identify and anticipate where
fraud loss can be identified, and savings Accountability and Performance Delivery 19
realised.
In 2020-21 our plan is to deliver a minimum Sue Frith
of £50m against our overall target and to do Chief Executive Officer
this our focus will be on a number of priority
areas.
• We will continue to support the DHSC
and the NHS to tackle Covid 19
related fraud
• We will work with partners to develop
a targeted approach to tackle Agency
fraud.
• We will continue our measurement
and analytical work in Procurement,
specifically post Covid 19 assurance
and assess the fraud taking place in
the pharmaceutical area.
• We will continue to address fraudulentNHSCFA 2020-2021 Business Plan 6 NHSCFA 2020-2021 Business Plan 7
Our vision - what we are At a glance - our successes by 2023
aiming to achieve 1. Lead and influence
Our vision is to lead and proactively support Our strategic objectives • More people understand NHS fraud, are engaged with the counter fraud agenda and
the NHS to understand, find, prevent and report fraud
respond to fraud. To achieve our vision, we have identified
• A network of fraud champions is embedded in NHS providers
four strategic objectives which will translate
• All NHS organisations are supported in achieving compliance with the Government
Counter Fraud Functional standard
Our purpose our ambitions into delivery:
• We will lead and influence the NHS
• Membership of the Government Counter Fraud Profession is available to the whole
NHS counter fraud community in England, with all eligible professionals empowered
Our purpose is to: to find, prevent, and reduce fraud,
and supported to become members
• Provide leadership and expertise in recovering losses and putting money
counter fraud as a valued NHS partner back into patient care
• Our stakeholders have high levels of satisfaction in the services we provide
• Collaborate nationally and locally with • We will work with partners to reduce
the NHS to understand fraud threats, fraud loss in the NHS 2. Reduce fraud loss
vulnerabilities and enablers • We will support and empower our
• Deliver intelligence-led counter fraud people to be the best in their roles and
• National and local counter fraud activity will result in measurable financial benefits
services to find, respond to and feel valued
• We have a process to measure value for money in local counter fraud functions for
both proactive and reactive counter fraud work
prevent fraud • We will effectively use our resources,
• Reduce the impact of fraud on the identify and pursue opportunities for
• Targeted intervention by the NHSCFA in partnership with health bodies and counter
fraud providers will have delivered measurable results
NHS growth and innovation and reduce our
• Work with partners to deliver financial operating costs
• Data and technology drive efficiencies in how we work and innovate our services
savings that can be reinvested in
patient care Our annual integrated planning approach 3. Support and empower our people
will ensure that we are doing the right
What we will achieve things. This approach will allow us to • We will demonstrate the benefits of adopting smarter working principles
be dynamic and flexible to ensure our • Leaders are seen to create an open, empowering and supportive culture, where
objectives adapt and anticipate the people feel they add value and are treated fairly
Our ambition is that in three years’ time we
will be: changing environment. This includes the • Our people have access to the training and development they need
• Recognised for pioneering counter emerging fraud risks, especially considering • Equality, diversity & inclusion and mental health are promoted and supported in the
the COVID 19 pandemic and its impact workplace
fraud initiatives that deliver real
savings for the NHS globally and nationally on our economy and
• Spearheading the fight against fraud society. 4. Effective use of our resources
in the NHS
• A valued partner for the whole NHS This business plan sets out our programme • We consistently deliver financial balance by integrated alignment of financial,
of work for 2020-2021 and how we will work business and workforce, translating our strategy into effective and resourced
in fighting fraud, with leaders at
with our partners to achieve it. deliverables
national and local level looking to us to
innovate and provide knowledge and
• We have effective performance and project management approaches to drive delivery
of our priorities
expertise
• Recognised internationally as a leader
• All opportunities to secure additional funding and investment are identified & pursued
in finding and fighting healthcare fraud
• We have lower operating costs through rationalisation of our estate, ensuring
accommodation is of a high standard but reduced in size where appropriate
• We will work with NHS partners to develop shared programmes of intervention
including identifying opportunities for income generationNHSCFA 2020-2021 Business Plan 8 NHSCFA 2020-2021 Business Plan 9
Our Business Model Our integrated approach to successful
Counter fraud leadership within the sector delivery
This plan details the high level programme lifespan of the strategy and beyond. To fulfil
of work the NHSCFA will implement during our ambition for our organisation we require
Our support
the first year of our three year strategy. This an integrated strategic approach. This
Our compliance,
advice guidance Our includes working with partners to reduce will ensure that all our strategies around
and Intelligence • Organisational Development
enforcement
Information Systems
the financial loss to fraud within the health estates, finances, digital, data, service
• National
• Quality and investigation Service
Investigation
sector by a minimum of £50m this year and provision, business planning and workforce
Compliance - including Forensic utilising a network of trained investigators are aligned.
• Fraud Prevention Computing Unit and
• Intelligence across the NHS to realise a direct financial
financial investigators
Financial Investigators
value of enforcement activity exceeding Our Integrated Approach
a minimum value of £25m. This plan has
been developed in line with the Secretary Development of an integrated three-year
of State for Health’s priorities, i.e. we will planning cycle in line with the delivery of the
embrace technology to facilitate smarter strategy is essential to this. We also need
Our counter fraud working principles allowing for a more to identify our key projects and programmes
analytical ability, flexible working environment for our people
governance &
and deliver them through a consistent
performance Our stakeholders and
whilst continuing to utilise data to identify organisational approach and common
partnership working areas for collaborative prevention activity standards.
Information Analytics
Performance & across the health sector to strengthen the
Cabinet Office
Governance DHSC AFU controls against fraud. The Strategic Intelligence Assessment (SIA)
Local counter fraud services
NHS Bodies details the key fraud threats, vulnerabilities
Counter Fraud Objectives &
Financial assumptions and enablers within the NHS. With limited
Functional Standard areas of focus resources at our disposal, the SIA assists
The delivery of this business plan is us in identifying which priority areas should
The NHS and patients supported by financial planning that be our focus for the period of the strategy.
are at the heart of includes some key assumptions. We will The SIA informs our Control Strategy, which
what we do deliver against cost improvement plans sets out our decisions as to where and how
(CIP) in year, that the NHSCFA annual we can have the most effective influence
parliamentary funding allocation remains and impact on fraud within the NHS.
Collating Investigations are
at £11.3m for financial year 2020/21, that
Determining Provision of Developing
information considered, thematic counter evaluation and system-wide counter
there will be no further changes in service The Strategic Intelligence Assessment,
against fraud prioritised and fraud priorities assurance of fraud networks delivery requirements outside of the current Control Strategy and integrated planning
threats allocated compliance against plans and that there are no further cost cycle will inform our work to achieve the
Intelligence and the Counter Fraud Maintaining and pressures above the current growth and financial targets set over the lifespan
Strategic Investigating analytical Functional Standard developing a counter inflation assumptions. of the strategy. This will be a mixture of
Intelligence allegations of fraud capability by NHS Bodies fraud culture direct savings from NHSCFA activity and
Assessment across national and We have made considerable progress wider savings due to behaviour change
local services Guidance and toolkits
and achieved a range of successes through our fraud prevention, recovery and
within the NHS network
during the period of our previous strategy assurance work.
(2017-2020). We now face a unique set
of challenges and opportunities over theNHSCFA Strategy 2020-23 10 NHSCFA Strategy 2020-23 11
With the response to COVID-19 dominating learning and analytical techniques over the
the work of the NHS during 2020, issues lifecycle of the strategy. The areas that will
relating to the pandemic will feature heavily be targeted although not restricted to are
in our annual plans including the following NHS staff E-rostering and procurement.
in particular: In addition, NHSCFA are in the early
• An increase in funding for the stages of planning an NHS Counter Fraud
procurement of goods and services, Hub in order to provide a focal point with
with a reduced level of scrutiny during responsibility for coordinating, enabling and
this period, means that vulnerabilities advising the Local Counter Fraud function.
remain and potentially have increased. 2020/21 will see the development of funding
Procurement fraud will continue bids and planning to take these initiatives
to be a key area of focus for the forward during 2021-23.
NHSCFA for the life of this strategy,
with COVID-19 post event assurance
underpinning this work in 2020-21.
• The dynamic nature of people
deployment within the NHS has been
identified as a fraud vulnerability,
therefore the NHSCFA will prioritise
fraud prevention activity in relation to
agency and bank staff during 2021- 2020-2021 Delivery Plan
2023.
• Continued collaboration with the
NHSBSA and access to data has
highlighted key areas for analysis for
fraud taking place during 2020-21.
Targeted prevention activity will take
place during 2021-2023.
• Work will continue in key areas such
as fraud taking place in general
practice in 2021-22, with updated
analysis on Help with Health Care
Costs (patient fraud) in 2022-23.
Our control strategy will be aligned to a
3-year planning cycle and support the
delivery of our financial targets of £400
million as a result of national and local
counter fraud activity (fraud prevented,
detected and recovered).
NHSCFA will also develop a range of
innovative and exploratory interventions
to support the prevention and detection of
fraud by combining technology, machineNHSCFA 2020-2021 Business Plan 12 NHSCFA 2020-2021 Business Plan 13
2020-21 Strategic 2020-21 Strategic
Core Work Streams KPI/Key Deliverables Core Work Streams KPI/Key Deliverables
Objectives Objectives
We will lead and Building on the work We will work with Intelligence Reduce losses to fraud within the health
25% of those eligible for membership
influence the NHS completed in 2018-19 partners to reduce Development and sector by contributing to the overall
within the NHSCFA and 10% of the
to find, prevent and 2019-20, we will fraud loss in the Fraud Prevention three year target of £400m. In year
LCFS community will be members of the
and reduce fraud, work to increase the NHS. strategies primarily delivery of £50 million as a result of the
Government Counter Fraud Profession.
recovering losses engagement across focussed on change in focus.
and putting money the health sector to a) Measuring the
back into patient build counter fraud The NHSCFA will provide its counter impact of NHSCFA
care. capability and support fraud expertise and resource to Fraud Prevention
NHS organisations to NHS Test and Trace – to develop an Guidance and
evolve and develop understanding of inherent fraud risks Advice
better understanding and vulnerabilities, and to establish an b) Undertaking
of their fraud risks, appropriate counter fraud resource and Loss Analysis
vulnerabilities and response. work to inform our
threats. intelligence picture
c) COVID-19
The NHSCFA will continually assess Procurement Post
new and emerging threats to the NHS Event Assurance
during the pandemic and publish regular d) Identification
threat assessments for action by our of the reduction
stakeholders and partners. in vulnerability to
losses to fraud.
The NHSCFA will provide its counter
fraud expertise and resource to support Measuring the Design, develop and deliver a
the DHSC in the review of due diligence impact of NHSCFA compliance exercise to measure impact
in relation to PPE and associated Fraud Prevention of fraud prevention guidance issued as
procurement during the COVID-19 Guidance and part of the 2019-20 Procurement fraud
response across the NHS. Advice. NPE and Fraud Prevention Notices.
Deliver on savings identified from
The number of referrals converted into compliance exercise, impact of fraud
reports in the case management system prevention work and prevention savings
Improving quality of
will increase by 4% by end of 2020- at local level as a result of activity and
fraud reports received
21. Reports converted/promoted to directed work undertaken by the LCFS
by the NHSCFA.
investigations will also increase by 4%. community.
CLUE3 implementation /roll out to Identify savings of a minimum for fraud
LCFS’s NHSE/I, NHSBSA and DHSC prevention activity of £5 million from
AFU completed by the end of March 18/19 & 19/20 FPNs.
2021.
FCROL Review completed in line with
CLUE3 implementation timescales
in relation to usability and logic, to
enhance fraud reporting experience of
those reporting and in turn increase the
numbers of referrals received.NHSCFA 2020-2021 Business Plan 14 NHSCFA 2020-2021 Business Plan 15
2020-21 Strategic 2020-21 Strategic
Core Work Streams KPI/Key Deliverables Core Work Streams KPI/Key Deliverables
Objectives Objectives
Undertaking Loss Help with Healthcare Costs Identification of Fraud taking place in General Practice
Analysis work to Undertake a measurement exercise the reduction in Deliver analysis of fraud taking place in
inform our intelligence to determine the current losses in vulnerability to losses general practice, increasing confidence
picture. prescription charge evasion. to fraud. in the fraud loss assessment to form
a basis for a prevention strategy.
We will also undertake a thematic
assessment on the effectiveness and The analysis and identification of
vulnerabilities within the Real Time vulnerability will be measured in 2021-
Exemption checking initiative. 22.
Fraud taking place in the pharmaceutical Deliverables for 2020-21
area - We will be undertaking a loss • Secure data by the end of Q4
measurement exercise to determine
• Explore opportunities with the
the vulnerabilities within specific areas
to inform targeted prevention activity in NHSBSA to analyse anomalies in
2021-22. the data this year.
COVID-19 Procurement Fraud Agency Fraud
Procurement Post Increase understanding in specific areas
To identify the threat of fraudulent
Event Assurance. of local NHS procurement, identifying
the threat of fraudulent activity and activity in agency staff spend and work
delivering a reduction in vulnerability as with stakeholders in tightening controls
a result. and reducing fraud vulnerability.
Obtain a baseline for local NHS fraud Deliverables for 2020-21
risk on Covid-19 procurement spend • Complete the TVE Assessment
and develop targets for reduction of the
incorporating recommendations on
risk in 2021-22.
fraud prevention solutions to reduce
Deliverables for 2020-21 losses in agency fraud.
• Engage with service owners and
Design and develop, a national stakeholders to develop a Fraud
proactive exercise directing NHS Response Action Plan.
provider organisations to undertake a
Covid-19 Post Event Assurance activity NHSCFA Direct Financial Value of enforcement
focusing on the four PPNs (Part A) and Investigations activity across the NHSCFA, local
PO vs non-PO spend (Part B), deliver counter fraud provision and other arm’s-
the exercise in 2021-22. length bodies will be a minimum of
£25m a year.
LCFS Outcomes Value of reactive enforcement activity
by local counter fraud functions will
represent a 2:1 return on investment.NHSCFA 2020-2021 Business Plan 16 NHSCFA 2020-2021 Business Plan 17
2020-21 Strategic 2020-21 Strategic
Core Work Streams KPI/Key Deliverables Core Work Streams KPI/Key Deliverables
Objectives Objectives
Enable our People Continued alignment 100% of our people will have We will effectively Identify and explore We will achieve best financial outcomes
to be the best in with the Places for successfully adopted smarter working use our resources, opportunities to in investment and income generation.
their roles and feel Growth Programme. principles by 2020-21. identify and pursue secure additional
valued. opportunities funding and Project and Programme Management
Targeted leadership for growth and investment by
The development of a sustainable Approach agreed and implemented
training programme. innovation and demonstrating
workforce plan aligned to the delivery of reduce our positive financial The impact and delivery of corporate
Promote equality, our Strategy and objectives. operating costs. impact. projects will be measured to ensure
diversity and inclusion return on investment is maximised and
in our workforce, 90% of our people will receive Learning Work with NHS benefits are realised, through robust
applying clear, fair and Development programmes. partners to develop governance and assurance structures
and consistent shared programmes
policies. of intervention,
We will observe a 10 percentile point 95% of corporate projects delivered on
including identifying
improvement in how well people feel opportunities for time and to budget.
they are being led. income generation.
We will successfully reduce our estate
An increase of 10% in Our People Integrate financial, by 10% in 2020-21.
Satisfaction rating. business and
workforce planning, Reduce costs of travel and subsistence
translating our
Develop a Management Information by 20% against the 19/20 baseline.
strategy into
Reporting Dashboard including effective, resourced
organisational health metrics around deliverables.
equality, diversity and inclusion for
reporting in Q4. Develop effective
performance and
project management
approaches to
drive delivery of our
priorities.
Reduce operating
costs through review
and rationalisation of
estates to embrace
and reflect new ways
of working.
Application of
good governance
arrangements.NHSCFA 2020-2021 Business Plan 18 NHSCFA 2020-2021 Business Plan 19
Our Portfolio of Key Corporate Projects Accountability & Performance Delivery
Through our Business Planning Refresh process during late summer in response to Our annual business plan supports delivery and performance risks is the SMT
COVID-19, the following have been identified as the key projects for the Organisation delivery of our strategy year on year. The in the first instance.
scheduled for delivery /commence during 2020-21. An overarching Portfolio dashboard NHSCFA has in place a framework in
highlight report will be produced for regular and timely updates to SMT, Board and ARAC. terms of its business planning cycle and The mitigations against these and all other
subsequent performance management strategic risks are regularly reviewed as
and delivery assurance. Quarterly strategic part of our risk management framework
2020-21 Objectives Key Corporate Project/Programmes (s)
accountability meetings with the DHSC, and are reported to the Audit and Risk
Lead and influence the prevention, • Organisation Wide Engagement and attended by the NHSCFA’s Chair and Chief Assurance Committee.
detection and reduction of NHS Fraud and Stakeholder Management including Executive Officer, provide an opportunity to
recover financial loss for the Health Sector LCFS Service Improvement Initiatives discuss progress against our objectives and
to invest in patient care. (Local Embedded Teams Pilot) (scoping targets.
stage).
• CLUE3 Implementation across the Our strategy sets out our key performance
Sector (underway). indicators that have been developed in
• Extranet Development (underway). line with delivery of the three strategic
objectives of the organisation. Delivery of
We will work with partners to reduce fraud • Loss Analysis Help with Health Costs
these are discharged through this Business
loss in the NHS. (underway).
Plan. The plan is then supported by
• Loss Analysis Help with fraud taking
divisional and unit business plans to ensure
place in the pharmaceutical area
a golden thread and alignment across the
(underway).
organisation’s plans.
• Fraud taking place in general practice
(Core project) continue into 2021/22
This plan will be closely managed and
(underway).
monitored at Board and Executive level
• Post Covid-19 Assurance (initiation
through a Board level performance report
stage).
and Portfolio Dashboard Report for
Enable our People to be the best in their • Workforce Strategy (underway).
our key projects and programmes. The
roles and feel valued. • Workforce Management Information
transparency of our Board reporting is
Dashboard (underway).
underpinned by quarterly Performance
• Delivery of the People Plan (Multi-
and Assurance Panels where delivery
strand projects including the Diversity &
and performance across all four Divisions
Inclusion Action Plan) (underway.)
of the organisation are reviewed by the
• Smarter Working (underway).
Panel. The Heads of Service for each
Effective Use of Our Resources . • Development of NHSCFA Project and
division along with their management teams
Programme Approach (underway).
actively engage in this process of delivery
• Income Generation Feasibility Project
assurance and mitigation. These Panels are
in relation to areas to be explored for
chaired by the Director of Performance and
cost recovery or commercialisation of
Improvement, who directly escalates any
activities including Forensic Computing
key issues, concerns or risks to the Senior
Unit, Training and Development (scoping
Management Team (SMT), Chief Executive
stage).
and Board Secretary. The management
• Innovation Projects covering Machine
decision making forum on all escalated
Learning, NHS Counter Fraud Hub
& Rostering (scoping stage, awaiting
approvals).You can also read
