Health Boards. 4.1.1 Accountable Officers are responsible for having adequate arrangements in place to counter fraud within their Health Board. In line with central guidance, these arrangements must include investigation and robust systems of prevention and detection controls to reduce the risk of fraud and contribute to the promotion of a counter-fraud culture.
4.1.2 All fraud impacting on the finances or reputation of NHS Scotland must be reported to CFS, regardless of the value, who the suspect or victim is, and whether or not the fraud was actual or attempted. However, the FLO, in consultation with CFS, may occasionally decide that a fraud is best dealt with by internal management action. In general, this will be on the grounds of low value.
4.1.3 The Accountable Officer should also report alleged losses involving patients’ funds to CFS, where evidence exists of systematic fraud.
4.1.4 By signing this agreement both parties agree to adopt the Counter Fraud Standard from 1st April 2022. This Standard is a best practice approach to countering fraud. It will require iterative development over the period of this agreement to establish its optimal form. Both parties to this agreement accept that in 2022/23, the activities, outputs and outcomes from this approach will not be optimised until the Standards framework has been more fully developed over the course of this Partnership Agreement. The aim is to progressively realise the benefits of the Standard framework without disrupting the current governance and assurance arrangements in place at each Health Board.
4.1.5 The components of the Counter Fraud Standard are as follows:
i. Have an accountable individual at Health Board level who is responsible for counter fraud, bribery and corruption.
ii. Have a counter fraud, bribery and corruption strategy.
iii. Have a fraud, bribery and corruption risk assessment.
iv. Have a policy and response plan for dealing with potential instances of fraud, bribery and corruption.
v. Have an annual action plan summarising key actions to manage and improve fraud resilience.
vi. Have annual metrics summarising what outcome achievements are sought.
vii. Have well established and documented reporting routes for staff, contractors and members of the public to report suspicions of fraud and bribery.
viii. Report identified loss from fraud, bribery, corruption, and associated recoveries.
ix. Have agreed access to trained investigators that meet the agreed public sector skill standard.
x. Undertake...
Health Boards. 4.1.1 Accountable Officers are responsible for having adequate arrangements in place to counter fraud within their Health Board. In line with central guidance, these arrangements should encompass robust systems of prevention, detection and investigation controls, to reduce the risk of fraud and contribute to the promotion of a counter-fraud culture.
4.1.2 All fraud against NHS Scotland must be reported to CFS, regardless of who the suspect or victim is, whether or not the matter has been prosecuted criminally, through civil action or by discipline, or whether the fraud was actual or attempted. However, the FLO, in consultation with CFS, may occasionally decide that a fraud is best dealt with by internal management action. In general, this will be on the grounds of low value.
4.1.3 The Accountable Officer should also report alleged losses involving patients’ funds to CFS, where evidence exists of systematic fraud.
4.1.4 The Scottish Government’s Strategy places the onus on Health Boards to appoint a senior executive or non-executive director as CFC. Their role is to influence cultural change within organisations to achieve a position where fraud is considered unacceptable.
4.1.5 Health Boards nominate a senior officer as XXX to liaise with CFS on all fraud related matters. The FLO will report and receive all allegations of fraud to and from CFS on the Health Board’s behalf. Subject to Section 6.6.3 below, the FLO and CFS will decide the most appropriate sanction route(s) to pursue (See SG circular CEL 11 (2013) for updated roles and responsibilities of CFCs and FLOs).
4.1.6 Responsibility for any necessary actions, based on findings and recommendations from CFS, lies with Health Boards.
4.1.7 The Health Boards’ “Fraud Action Plan” will outline how fraud will be addressed proactively. This should be reviewed and updated regularly.
4.1.8 It is expected that the FLO within Health Boards shall be the appropriate person to take responsibility for distributing all fraud reports and other communications from CFS, to appropriate recipients within the Board. Depending on the circumstances, Boards may wish to nominate other persons to carry out this action, but such persons should be conversant with the necessary fraud procedures, before doing so.
4.1.9 All Health Boards are required to provide a secure environment for staff, practitioners and patients to report suspected fraud in compliance with the Public Interest Disclosure Act 1998. In this respect, a method of c...
Health Boards. 4.1.1 Accountable Officers remain responsible for countering financial crime within their Health Board.
4.1.2 Accountable Officers are required to have adequate arrangements in place for the deterrence, disabling, detection and dealing with financial crime. In line with central guidance, these arrangements should encompass robust systems of prevention and detection controls, to reduce the risk of financial crime and contribute to the promotion of an anti-fraud culture.
4.1.3 In October 2008 and March 2010, the (then) SGHD issued circulars CEL 44 (2008) and CEL 10 (2010) (see Appendix III) noting that all financial crime must be reported to CFS, regardless of who the suspect or victim is, whether the matter is to be/was prosecuted criminally, through civil action or by discipline, or whether the financial crime was actual or attempted. The Accountable Officer must ensure that systems are put in place to notify CFS of all reports of financial crime, so that complete records of financial crime against NHS Scotland are available (see Appendix III – Reporting).
4.1.4 The Accountable Officer should also use CFS to assist in the investigation of actual, and alleged, losses involving patients’ funds where evidence exists of systematic financial crime.
4.1.5 The Scottish Government’s Strategy asks Health Boards to appoint a senior executive or non-executive director to be a Counter Fraud Champion (CFC) to help with the process of changing attitudes to financial crime within organisations, where it is felt that further work needs to done on this challenge.
4.1.6 Health Boards have nominated a senior officer as Xxxxx Xxxxxxx Officer (FLO). The FLO will liaise with CFS on all matters relating to NHS Scotland financial crime and will co-operate with proactive enquiries. The FLO will have a duty to report/receive, on the Health Board’s behalf, all allegations of financial crime to/from CFS, and, subject to Section 6.4.3 of this Agreement, decide in partnership with CFS, whether the allegation will be taken forward for potential criminal prosecution, and/or as a disciplinary or civil case. (See SG circular CEL 11 (2013) for updated roles and responsibilities of CFCs and FLOs).
4.1.7 Responsibility for any necessary actions, based on findings and recommendations from CFS, lies with Health Boards.
4.1.8 The Health Boards’ “Fraud Action Plan” will outline how financial crime will be addressed proactively. These should be reviewed and updated regularly.
4.1.9 It is expected ...
