Counter fraud

All organisations providing NHS services are required to put in place appropriate counter fraud arrangements. For practical purposes fraud is defined as:

"The use of deception with the intention of obtaining an advantage, avoiding an obligation or causing loss to another party. Generally, the term fraud is used to describe such acts as deception, bribery, forgery, extortion, corruption, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of material facts and collusion".


Local Counter Fraud Specialist

Each Local Counter Fraud Specialist (LCFS) works for several NHS clients with the key aim of combating fraud in the NHS. LCFS work in partnership with colleagues in the NHS, NHS Protect and other bodies such as Internal Audit. This provides the NHS with an integrated and professional counter fraud service, and helps create an anti fraud culture. The LCFS work includes the planning, development, and promotion of effective counter fraud arrangements as well as providing:

  • professional advice
  • publicity
  • reports
  • assurance on counter fraud issues

A significant proportion of LCFS work is devoted to investigating suspected NHS fraud. The LCFS manages each case and is able to investigate to police standards all reported instances of potential fraud.

All LCFS work and duties are performed in accordance with relevant policies and procedures including:

  • The Trust’s Anti-Fraud and Bribery Policy
  • The Trust’s Anti-Fraud and Bribery Policy
  • Secretary of State's Directions
  • NHS Counter Fraud and Corruption Manual
  • Standing Financial Instructions
  • Trust Disciplinary Procedures
  • Trust Fraud Response Plans
  • Relevant Legislation including PACE & Human Rights Act

Inform and involve

The LCFS ensures there is an ongoing programme of work to raise awareness of fraud, bribery and corruption and create an anti-fraud, bribery and corruption culture among all staff, across all sites, using all available media. This may include (but is not limited to) presentations, newsletters, leaflets, posters, intranet pages, induction materials for new staff and emails.

Prevent and deter

Information on all frauds investigated by the LCFS is used to review and revise Trust procedures to reduce the risk of similar frauds arising in future.

The LCFS proactively searches for fraud occurrence. This work will include checks on areas of high risk such as payroll and expense claims, payments, sickness absence and procurement.

Hold to account

All suspected fraud is investigated professionally and objectively by trained LCFS staff in accordance with recognised procedures, statutory legislation, and the requirements of the NHS Counter Fraud and Corruption Manual.

A key aim of the new counter fraud arrangements is to raise the profile of anti-fraud measures within the NHS and generate positive publicity so that fraudulent activity is deterred.

Fraud against the NHS is never acceptable. All appropriate legal, civil, and disciplinary action will be taken against those responsible.

The government and the NHS are determined that the fraudster will not benefit and have instructed that, where public money has been defrauded, this will be the subject of recovery procedures in every case.


Bribery can be defined as the giving someone a financial or other advantage (does not have to be cash) to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.

For example, this may involve a party seeking to influence a decision maker by giving them some kind of extra benefit to that individual rather than by what can be legitimately be offered as part of a tender process.

It is an offence to offer, give, request or accept a bribe. It is also an offence for a commercial organisation for failing to prevent bribery, which means that a commercial organisation, such as Hertfordshire Community NHS Trust (HCT), can commit an offence if a person associated with it bribes another person for that organisation’s benefit.

However, the Act states that the organisation will have a defence for failing to prevent bribery if it can evidence they have put in place ‘adequate procedures’ designed to prevent persons associated with it from bribery others on their behalf.


How to report fraud

If you suspect a fraud may be taking place within or against the Trust, or in the wider NHS, please contact the Trust’s counter fraud team in absolute confidence. Hannah Wenlock is our designated Local Counter Fraud Specialist (LCFS).

Information can also be given to a confidential NHS Fraud and Corruption Reporting Line 0800 0284060 (Freephone Monday - Friday 8am - 6pm).

Calls to the National Fraud and Corruption Reporting Line are treated in confidence by trained staff and information given will be professionally assessed and evaluated.

Callers have the option to remain anonymous should they wish to do so.

Alternatively, you can report fraud online here.