Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy (Please click the blue arrow below to begin the module) Countering Fraud, Bribery & Corruption in the NHS E-Learning Module for CCG and Member GP Practice Staff Copyright © Assurance All rights reserved

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy How this module works Click on the blue arrow buttons at the bottom of each screen to navigate through this e-Learning module. Questions should be answered by clicking the blue button that corresponds with your chosen answer. The buttons represent: Next slide Previous slide You cannot successfully complete this module unless you answer the knowledge check questions contained within it correctly. When you reach the end of the module you will be asked to submit your details to enable your completion of the training to be recorded.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy The aims of this module are:  To inform you about the risk of fraud, bribery and corruption that might affect the CCG and its member practices  To introduce your Counter Fraud Specialist  To explain what you should do if you have concerns regarding fraud, bribery or corruption It will take about 20 minutes to complete the module.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy All areas of NHS spending may be affected by fraud, bribery and corruption. With CCGs responsible for a significant proportion of this spending, it is imperative that all staff are aware of the risks that exist because staff are ideally placed to contribute to the prevention and detection of fraud, bribery & corruption. In recent years, GP practices themselves have also lost significant sums of money through such criminal acts and so an understanding of the risks is also important for their own practice staff. We are ALL responsible for ensuring that fraud, bribery and corruption cannot easily be carried out by correctly following relevant policies and procedures and by promptly reporting any concerns that we have. Why do you need to know about the NHS Counter Fraud, Bribery & Corruption initiative?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy In the simplest of terms, Fraud is theft with an element of deception involved. The most common offences under the Fraud Act 2006 are:  Fraud by false representation – e.g. submission of false timesheets for shifts not worked.  Fraud by failing to disclose – e.g. failing to declare criminal convictions when applying for NHS employment.  Fraud by abuse of position – e.g. a person in a position of trust using their position to commit Fraud. (Some Fraud offences, committed before 15 th January 2007, continue to be prosecuted under the Theft Acts) What is Fraud?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Fraud by False Representation There are numerous ways in which somebody might falsely represent or falsify information in order to make a gain for themselves or expose another to a loss. Examples of this would include but are not limited to:  The falsification of staff timesheets or expense claims;  Pharmacies falsely endorsing prescription forms after dispensing and/or conspiring with wholesalers and overstating the cost of specials;  Providers inflating the costs attributed to Continuing Care by invoicing for additional costs for services that have not been delivered;  Patients creating false identities in order to register with multiple GP practices and increasing the amount of medication they are prescribed;  Criminal gangs purporting to represent existing creditors by using mocked up letters and other documents in order to change creditor bank details to their own.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Fraud by Failure to Disclose A Fraud offence is also committed when somebody has a legal duty to disclose information but dishonestly fails to do so, in order to make a gain for themselves or expose another to a loss. Examples of this would include, but are not limited to:  Staff failing to report salary overpayments and keeping the money for their own benefit;  Staff failing to declare that they are subject to a criminal investigation and/or prosecution where this is a requirement of their employment;  Failure to declare all outside interests as they arise, allowing conflicts of interest to occur.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Fraud by Abuse of Position Fraud by abuse of position where somebody dishonestly uses their position to make a gain for themselves or expose another to a loss. Examples of this would include but are not limited to:  A GP Practice Manager using their position of trust in order to increase their salary, redirect payments to their own bank accounts and/or order goods for personal use;  A CCG member or staff member with outside interests inappropriately using their position to influence CCG decisions, in such a way as to ensure they make a gain and/or another party makes a loss;  A staff member using their position to cause payments to be made that would not otherwise be made (for example to a bank account in their name or that of a family member).

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Bribery is offering an incentive to someone to do something which they wouldn’t otherwise do. In the context of the Bribery Act 2010, the offence of Bribery refers to both the acceptance and the offer of (whether or not the offer is accepted), a bribe. Any individual associated with an organisation acting in such a way may be prosecuted under the Act for a primary Bribery offence, or for conspiracy to commit the offence with others. The Bribery Act 2010 also introduced a new corporate offence, meaning that organisations will be exposed to criminal liability, punishable by an unlimited fine, for failing to prevent Bribery. The Bribery Act 2010

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Preventing Bribery Bribery, by its very nature, usually involves secretive and undisclosed activity. It is therefore essential that all activity and circumstances which might give rise to a conflict of interest, or which might create the opportunity for Bribery, are disclosed by all employees and recorded in the organisation’s registers for such disclosures. The existence of policies requiring the declaration of other employment, business interests and gifts and hospitality (both offered and received), demonstrates that the organisation has taken appropriate action to satisfy the requirements for the prevention of Bribery. Awareness of and compliance with your organisation’s policies regarding such disclosures may also offer protection to employees who might otherwise themselves be accused of Bribery. All employees must therefore ensure that they have read and comply with the organisation’s policies concerning the disclosure of other employment, declarations of interest and gifts and hospitality.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Between 1999 and 2013: Nationally… Taking Action  More than £70 million was recovered through NHS counter fraud work; and  849 criminal sanctions were applied to perpetrators of fraud against the NHS. In 2012/13 alone:  More than £985,000 was recovered;  128 criminal sanctions were applied; and  435 civil, disciplinary and internal sanctions were applied.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Review Your Learning What have you learnt from this module so far? Here are a few questions…

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Because they are ideally placed to contribute to the prevention and detection of fraud, bribery & corruption. Because they can help to prevent fraud, bribery and corruption by correctly following relevant policies and procedures. Why do CCG and Practice Staff need to be aware of Fraud, Bribery & Corruption? Choose your answer For both of the reasons listed.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Yes, that’s right, but Staff need to be aware of fraud, bribery and corruption both because they can help to prevent these offences by correctly following policies and procedures and also because they are ideally placed to contribute to the prevention and detection of fraud, bribery and corruption. The correct answer is therefore ‘for both of the reasons listed’. Why do CCG and Practice Staff need to be aware of Fraud, Bribery & Corruption?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Staff need to be fraud, bribery and corruption aware because they are ideally placed to contribute to the prevention and detection of fraud, bribery and corruption and also because they can help to prevent such offences by correctly following relevant policies and procedures. Yes, that’s right! Why do CCG and Practice Staff need to be aware of Fraud, Bribery & Corruption?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy An applicant for a CCG post providing false educational certificates. A pharmacist endorsing a prescription with a drug that was not dispensed. Which of the following scenarios could be considered fraudulent? Choose your answer A Practice Manager using practice funds to purchase personal items. All of the above.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy The answer you chose is a potential fraud, but so are the other two. The correct answer is, therefore, all of the above. Yes, that’s right, but … Which of the following scenarios could be considered fraudulent?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy All the options listed are potential frauds. Yes, that’s right! Which of the following scenarios could be considered fraudulent?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy An individual found to have either offered or accepted a bribe. An organisation which has not taken adequate steps to prevent bribery. The Bribery Act 2010 creates offences which can lead to action being taken against whom? Choose your answer Both of the above.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Individuals can be prosecuted if they either attempt to bribe, or accept a bribe. Organisations can also have action taken against them, including the imposition of unlimited fines, if they fail to take adequate steps to prevent bribery occurring. The correct answer is, therefore, both of the above. Yes, that’s right, but … The Bribery Act 2010 creates offences which can lead to action being taken against whom?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Individuals can be prosecuted if they either attempt to bribe, or accept a bribe. Organisations can also have action taken against them, including the imposition of unlimited fines, if they fail to take adequate steps to prevent bribery occurring. Yes, that’s right! The Bribery Act 2010 creates offences which can lead to action being taken against whom?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Can anyone investigate fraud, bribery & corruption? (such as a line manager or a Human Resources Officer) NO It is a requirement that only a nominated and professionally accredited Counter Fraud Specialist can undertake investigations of fraud, bribery & corruption for each Health Body, NHS organisation and/or provider of healthcare services to the NHS. This is to ensure that legislation governing criminal investigations (including the Human Rights Act and Data Protection Act) is not breached and as a consequence, that any potential criminal prosecution is not compromised. However… The CFS works very closely with Human Resources whenever a member of staff is under investigation.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy What do I do if I think fraud, bribery or corruption is occurring?   Do make a note of your suspicions. Sign the note, date it and keep it safe. Do try to secure or copy documents you believe to be suspicious. Do immediately contact your Counter Fraud Specialist. Don’t investigate the matter yourself or report it to anyone other than the Counter Fraud Specialist – this may compromise any potential prosecution. Don’t undertake any covert surveillance – this will breach the Human Rights Act.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Yes and anonymous referrals will be investigated. You might wish to consider that it can sometimes be useful if you provide contact details such as a mobile phone number in case further information is required later. Even if you only give a contact reference and telephone number, this may help with the investigation as initial enquiries might prove inconclusive and we may therefore need to come back to you to see if you have any further information which might help us progress the investigation fully. If you do give us minimal contact details these will not be used to identify you. Can I report my suspicions anonymously?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy What if I am wrong?  Never be afraid to raise your suspicions directly with your Counter Fraud Specialist even though you may be wrong…You could be right!  There will be no ramifications for raising an issue you believe to be fraud, bribery or corruption, regardless of how the investigation is concluded, as long as your referral was made in good faith.  If you are uncertain whether a referral is needed, you should contact your Counter Fraud Specialist anyway for advice.  The person investigated will not be disadvantaged if the investigation undertaken does not uncover any fraudulent or corrupt activity.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy What if I am right?  Your Counter Fraud Specialist will have validated the suspicions and uncovered evidence.  The person under investigation will have explained their actions at a formal interview under caution. (Whatever is said can be used in a criminal prosecution).  A decision will be reached regarding appropriate sanctions to be pursued.  Any ongoing loss will be stopped, losses incurred calculated and a decision will be made regarding appropriate recovery action.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy How do I contact my Counter Fraud Specialist? Please select the location of your CCG or Practice below for full contact details of your Counter Fraud Specialist: DerbyshireLeicestershire South Yorkshire including Bassetlaw CCG Nottinghamshire

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy How do I contact my Counter Fraud Specialist? Your Counter Fraud Specialist is: Matthew Curtis   360 Assurance, Riverside House, Bridge Park Road, Thurmaston, Leicester LE4 8BL You can also call the National NHS Fraud and Corruption Reporting Line (open 8am – 6pm) on , or report online at

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy How do I contact my Counter Fraud Specialist? Your Counter Fraud Specialist is: Ian Morris   360 Assurance, Riverside House, Bridge Park Road, Thurmaston, Leicester LE4 8BL You can also call the National NHS Fraud and Corruption Reporting Line (open 8am – 6pm) on , or report online at

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy How do I contact my Counter Fraud Specialist? Your Counter Fraud Specialist is: Antony Upton   360 Assurance, Riverside House, Bridge Park Road, Thurmaston, Leicester LE4 8BL You can also call the National NHS Fraud and Corruption Reporting Line (open 8am – 6pm) on , or report online at

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy What action might be taken? There are four routes by which action can be taken against those who commit fraud, bribery or corruption: 1.Civil Recovery Action will be taken to recover sums obtained. Although this might initially be sought by agreement, the civil courts can be used if required. 2.Disciplinary Action Evidence of fraud, bribery or corruption would lead to disciplinary action and, potentially, the termination of employment for gross misconduct. 3.Professional Disciplinary Action may be taken by professional bodies such as the NMC, HPC and GMC. This could lead to the end of an offender’s career. 4.Criminal Sanction This could take the form of a caution for minor offences, or lead to prosecution in more serious cases. Fraud, bribery and corruption can attract significant sentences from the courts.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Review Your Learning What have you learnt from this module so far? Here are a few questions…

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Immediately challenge the individual or organisation presenting the claim. Contact your Counter Fraud Specialist and ask for advice. You think a false claim for payment may have been made. What should you do? Choose your answer Take no action as somebody else will take action if it is incorrect.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy By immediately challenging the person or organisation presenting the claim, or by ignoring the problem without first discussing your concerns with the Counter Fraud Specialist, you may compromise any potential criminal and/or disciplinary investigation. There is also a risk that previous false claims submitted by the same individual or organisation will not be detected and you may be accused of collusion. If you think you have identified a false claim for payment, whether or not you think that it has been deliberately falsified, you should immediately discuss your concerns with the Counter Fraud Specialist.  No, that’s the wrong answer, please try again You think a false claim for payment may have been made. What should you do?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy If you think you have identified a false claim for payment, whether or not you think that it has been deliberately falsified, you should discuss your concerns with your Counter Fraud Specialist: Yes, that’s right! You think a false claim for payment may have been made. What should you do?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy As soon as you suspect fraud, bribery or corruption may have taken place. Once you have made a few discreet enquiries and fleshed out your suspicions. At what point should you seek advice from the Counter Fraud Specialist? Choose your answer After gathering evidence and speaking to any individuals involved.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Do not launch an investigation, even it is no more than a few simple enquiries, without discussing your concerns with the Counter Fraud Specialist. Whilst it might appear obvious what information is needed, it is often the case that this information needs to be gathered in a specific way, or with additional supporting evidence, to be useful in a criminal enquiry. By discussing your concerns with the Counter Fraud Specialist first, you can ensure that the matter is progressed in a manner suitable for both criminal and disciplinary enquiries. The answer is therefore to contact the Counter Fraud Specialist as soon as you suspect that fraud, bribery or corruption may have taken place.  No, that’s the wrong answer, please try again At what point should you seek advice from the Counter Fraud Specialist?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy If you suspect that fraud, bribery or corruption has taken place you should immediately discuss your concerns with your Counter Fraud Specialist. Yes, that’s right! At what point should you seek advice from the Counter Fraud Specialist?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Yes, but my concern will not be taken seriously. Yes, the matter will be investigated fully if initial enquiries support my concerns. Can my suspicions be reported anonymously? Choose your answer No, I must give my details which will be shared with other parties.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Can my suspicions be reported anonymously? If you choose to report your suspicions anonymously, your concerns will be taken seriously and you will not be made to give details to be shared with other parties. The correct answer is that the matter will be investigated fully if initial enquiries support your concerns.  No, that’s the wrong answer, please try again

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Can my suspicions be reported anonymously? If you choose to report your suspicions anonymously, then the matter will be fully investigated if initial enquiries support your concerns. If it is possible to provide contact details, however, it can help to support an investigation by allowing further questions to be asked where required. Yes, that’s right!

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Civil Recovery of defrauded sums. Disciplinary internally and/or via professional body. What actions might be taken if evidence of fraud, bribery or corruption emerges? Choose your answer Criminal sanction. All of the above.

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy If evidence of fraud, bribery or corruption emerges, we can potentially take action on a number of fronts: Civil recovery of defrauded sums; Disciplinary action both internally and via professional bodies; and Criminal sanction. The correct answer is therefore that all of the actions listed might be taken. Yes, that’s correct, but What actions might be taken if evidence of fraud, bribery or corruption emerges?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy If evidence of fraud, bribery or corruption emerges, we can potentially take action on a number of fronts: Civil recovery of defrauded sums; Disciplinary action both internally and via professional bodies; and Criminal sanction. Yes, that’s right! What actions might be taken if evidence of fraud, bribery or corruption emerges?

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy You have now completed this training module and are better informed about how you can help reduce the opportunities for fraud, bribery and corruption against the CCG and/or member practice. Please help us stamp out all fraud, bribery and corruption in the NHS and report any suspicions to your Counter Fraud Specialist. Please now click in the green box below to complete a brief questionnaire and submit your details. (Your successful completion of this training module will not be recorded if you do not complete and submit the questionnaire). Well done! You may then close this program by using the escape key and then closing the window, or alternatively continue through the following five slides which provide examples of actual fraud investigations and their outcomes. Submit questionnaire

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy GP Practice – Practice Manager Fraud  A GP Practice manager was employed at one practice for 10 years. One of her duties was to oversee payroll. She abused this position to increase her own pay substantially.  At their peak, her earnings hit £17,000 gross per month.  She claimed 220 hours per month in overtime alone, when she was contracted to work 156 hours per month with no overtime. She even claimed overtime whilst away from work on a two week holiday.  Over a two and a half year period she paid herself an extra £108, in salary plus £159, in overtime that she was not entitled to.  She was sentenced to 3 years imprisonment for the £267k fraud. Case Study 1

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Out of Area Treatment—Hyperbaric Pressure Chamber  Pressure chambers are used by divers who surface too quickly resulting in ‘the bends’  Specialist facilities are dotted around the country, usually at diving schools etc.  Three men used the personal details of divers who had never used the pressure chamber or suffered the bends  37 false patients were created to charge 12 health bodies for services not provided. £6,500 was claimed each time with false charges occurring over a 4 year period  A total of over £250,000 was defrauded  Two of the men received prison sentences of 5years 3months and 2years 3months respectively, with an accomplice receiving a 2year suspended sentence. Case Study 2

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Charity Fraud—Fraud by Charity Treasurer  Fraud was committed against a charity funded by 2 PCTs to provide advice on safe sex  The Treasurer obtained a debit card and began misusing charity funds  He began to live an extravagant lifestyle and purchased a Mercedes  He was found to have misappropriated over £140,000 of the charity’s money  Following his arrest, the charity went into liquidation with 5 job losses  The former Treasurer was sentenced to 2 years imprisonment Case Study 3

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Continuing Care—NHS Manager fraud  An NHS Continuing Care Manager invented a care home  31 invoices were submitted for the care of patients whose details were taken from a register of real NHS patients receiving continuing care (including palliative care)  Invoices were checked and verified for payment by the Continuing Care Manager  Payments were made into an accomplice’s bank account  The fraud totalled £117,  Both the NHS Manager and the accomplice were prosecuted.  £46,000 was recovered from the perpetrator’s bank accounts. Case Study 4

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy Pharmacy—Repeat Prescriptions  A patient asked for a repeat prescription from their GP only to find that their repeat prescription had already been obtained by their pharmacy  The prescriptions had been endorsed as dispensed when no drugs had been given to the patient  After investigating repeat prescriptions, it was found that there were multiple patients in the same situation  A Police search at the Pharmacist’s home found £60k+ in sterling, £2k US dollars and a considerable sum of Indian Rupees  The subject was sentenced to 12 months imprisonment and an order was made to confiscate assets to the sum of £45,000 Case Study 5

Internal Audit Consultancy Security Post Payment Verification IT Audit & Forensics Consultancy You may now exit the module by using the escape key and closing the window. If you did not submit a questionnaire prior to reading the case studies, please go back and do this now or your completion of this module will not be recorded. Thank you for completing this eLearning module