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Countering Fraud, BRibery and corruption

All NHS organisations are required by the NHS Counter Fraud Authority (the NHS body responsible for tackling all forms of crime against the NHS), to have in place a Local Counter Fraud Specialist (LCFS) to combat fraud, bribery and corruption, and help safeguard NHS resources. Our provider is CW Audit, whose LCFS’s are accredited and are suitably qualified to carry out this work to the required national standard.
Any UHCW employee, agency staff, contractors or members of the public who have suspicions of fraud within the Trust can approach the LCFS confidentially and anonymously.

The activities of the LCFS include:
• Carrying out an agreed programme of preventative counter fraud and corruption activity
• Deciding whether internal/external referrals or matters raised through the whistleblowing process need to be investigated
• Investigating cases in accordance with the NHS Standard Contract (Service Condition 24) and the NHS Fraud and Corruption Manual; ensuring a full and fair investigation
 Reporting to the Executive Director of Finance (DoF) to ensure he/she is kept appraised of all cases
• Reporting to the Audit Committee on all counter fraud work undertaken at the Trust
• Reporting any case to the police where necessary, in consultation with the Executive DoF, the Chief Accountable Officer and the NHS Counter Fraud Authority.

Fraud is the deliberate or reckless intent to permanently deprive an employer of money or goods through false representation, failing to disclose information or abuse of position. Corruption is the deliberate use of bribery or payment of benefit-in-kind to influence an individual to use their position in an unreasonable way to help gain advantage for another.
The Bribery Act 2010 came into force on 1 July 2011. The Bribery Act has become the primary piece of anti-corruption legislation in the UK and is arguably one of the most far reaching Acts of its kind in the world. For further key information, please click on the following summary of the Bribery Act 2010.
The Fraud Act 2006 is the primary piece of anti-fraud legislation in the UK and it has been in force since January 2007. In contrast to the previous legislation that it replaced, the Fraud Act established a clear legal definition and offence of fraud for the first time in the UK, and for the main offences established by the Act it removed the element of deception as a characteristic of this kind of criminality.
Section 1 of The Fraud Act sets out provisions for a general offence of fraud. There are several offences created, the main three being sections 2, 3 and 4. The act also creates new offences of obtaining services dishonestly and of possessing, making and supplying articles for use in fraud, as well as containing a new offence of fraudulent trading applicable to non corporate traders.
Click here for a summary of the Fraud Act 2006.
UHCW is taking part in the Cabinet Office’s National Fraud Initiative exercise. This mandatory exercise takes place every two years and includes all NHS bodies and Councils in England.
The National Fraud Initiative (NFI) is an exercise that matches electronic data within and between public and private sector bodies to prevent and detect fraud. These bodies include police authorities, local probation boards, fire and rescue authorities, the NHS as well as local councils and a number of private sector bodies. Data for the NFI is currently provided by some 1,300 participating organisations coverings millions of transactions.
The Trust is required to provide particular sets of data to the Minister for the Cabinet Office for matching for each exercise. The use of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 1998.
Data matching by the Cabinet Office is subject to a Code of Practice.
For further information see the NFI Privacy Notice in full here.
If you have any queries about the NFI, the key contact for the Trust is Cathy Hughes, Local Counter Fraud Specialist, who can be contacted by email via
Where a report of a suspicion of fraud, bribery or corruption, against the NHS is being made, please provide as much information as possible. Advice will also be given where an individual has a concern but is not sure whether the matter is a fraud against the NHS.
To assist your understanding of the process, please look at this fraud reporting flowchart.
The Local Counter Fraud Specialist for UHCW is: Cathy Hughes
You can also report any concerns via the referral form.
UHCW’s own Fraud Champion is Sharon Naylor who can be contacted directly via the Trust switchboard or internally via:
Other members of team are:
Paul Westwood:
Malcolm Taylor:
Richard Loydall:
Fiona Dwyer: