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continually scan for potential fraud . In stark contrast to this , many NHS bodies are reliant upon suspected fraud being reported and , while there are some governance measures in place , without standard processes , better technology and integrated IT systems , fraud prevention and detection remain a challenge .

The recently formed ICBs in England , which have replaced Clinical Commissioning Groups ( CCGs ), have members drawn from NHS primary and secondary care , along with local authorities and partner organisations . This provides the opportunity for these organisations to join forces in the fight against fraud .

However , the potential for systems to be defrauded has never been greater , as criminals continue to find new and sophisticated ways to exploit immature control mechanisms and governance processes , which are an inevitable consequence of organisations amalgamating .

This also increases the potential for unintended fraud . Take an example of a well-meaning staff member whose focus is , in order to provide the best service to their patients , a quick contract setup . Now imagine the already long procurement processes within each underlying organisation being layered on top of each other , without the correct processes and safeguards being put in place . Despite the best of intentions , the risk of fraud is increased . It will take time for each ICB to standardise procurement processes and digital systems , leaving them exposed to fraud during this period . Instead of remaining vulnerable , work to secure it . Infrastructure needs to be prioritised and resourced just as it would in the financial sector .

10-point action plan to tackle fraud

How can the risk of fraud be kept front of mind and processes safeguarded during this transition phase ?

1 . Review processes to identify pain points and potential failure points . Understand the issues with your current processes and what you need to design out of them . 2 . Review processes through a fraud lens . Think how criminals could potentially defraud your processes ; this will identify weaknesses and vulnerabilities . Involve experts who understand implicitly how to design and implement fraud detection systems . 3 . Simplify processes . Our world is complex , but the simpler our processes , the easier it is for staff and managers to understand , remember and manage them . 4 . Eliminate duplication and combine . When amalgamating organisations , you are likely to duplicate processes that ultimately do the same thing . Define the best practice and remove the processes that you don ’ t need . 5 . Redesign . Process redesign should only commence once you understand your current processes . 6 . Design a fraud assurance regime . Overlay the necessary fraud prevention controls over your processes , ensuring they prevent or identify fraudulent activity . Back them up with exception analysis designed to spot fraud that has bypassed the controls . Audit the control framework regularly , looking for ways to simplify and improve effectiveness . 7 . Ensure ownership . Every process and digital platform requires an assigned owner , responsible for regularly reviewing and ensuring processes remain fit for purpose . Ensure your Information Asset Owners

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