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FOR THE HEALTH AND SOCIAL CARE SECTOR COUNTER FRAUD
NEWSLETTER
Contents
Former Mental Health Nurse Imprisoned for NHS Fraud
Court Orders Individual to Repay Over £400,000 Defrauded from NHS After Fake Psychiatrist Scam
Four Individuals Imprisoned for £6 Million Bribery and Corruption Offences Against NHS Scotlan
Reminder: Failure to Prevent Fraud Offence Takes Effect 1 September 2025. Are You Ready?
Reporting Fraud
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Introduction
The Strategic Pillars The NHSCFA 2023-2026 Strategy:
Welcome to our Spring Counter Fraud Newsletter. The NHS Counter Fraud Authority (NHSCFA) estimates that the NHS is vulnerable to over £1.3 billion worth of fraud each year. Fraud is deception carried out for personal gain, usually for money. Fraud can also involve the abuse of a position of trust. By ‘NHS fraud’ we mean any fraud where the NHS is the victim. While those who commit fraud against the NHS are a small minority, their actions have a serious impact on us all. Fraud against the NHS could be committed by anyone. This includes members of staff, patients, contractors, suppliers, medical professionals and external parties, such as cybercriminals.
‘Working together to understand, find and prevent fraud, bribery and corruption in the NHS’ focuses on four key pillars: Understand, Prevent, Respond and Assure.
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Understand how fraud, bribery and corruption affects the NHS.
Fraud takes taxpayers’ money away from patient care and into the hands of criminals. Everyone has a part to play in fighting fraud and being aware of the risk and remaining vigilant are the most important first steps, followed by knowing how to report fraud. Contact details for reporting fraud in confidence are included at the end of this newsletter so if you have any suspicions that fraudulent activity may be occurring, please report this at the earliest opportunity.
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We will ensure the NHS is equipped to take proactive action to prevent future losses from occurring.
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When we know that fraud has occurred, we are equipped to respond .
We can assure our key partners, stakeholders and the public that the overall response to fraud across the NHS is robust.
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Former Mental Health Nurse Imprisoned for NHS Fraud
A former NHS mental health nurse from Bradford has been sentenced to 18 months in prison following a conviction for defrauding the Greater Manchester Mental Health NHS Foundation Trust, at a hearing held at Bradford Crown Court in May 2025.
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T he individual was found guilty of Fraud by Abuse of Position after making false claims for 185 shifts, which led to the receipt of £72,632.72 in wages and holiday pay. The defendant had previously pleaded guilty at a court appearance in November 2024. An investigation, conducted by the trust’s Local Counter Fraud Specialist (LCFS) with support from the NHS Counter Fraud Authority (NHSCFA), determined that this person misused their role as both a nurse and ward manager at a mental health facility in Manchester. Due to their position as a manager, the individual had access to the shift booking system, enabling them to create, allocate, and approve extra shifts. Beginning in April 2020, this individual started generating backdated overtime shifts in their own name, subsequently submitting these to the NHS Staff Bank, which permits NHS staff to take on extra shifts beyond their contracted hours, ordinarily to address staffing shortages. The false claims primarily involved night shifts, which attract higher pay rates. As these fraudulent shifts were added retrospectively, they did not appear on standard rotas and therefore did not immediately arouse suspicion. This continued until October 2021.
In November 2021, anomalies were discovered regarding certain additional shifts claimed by this staff member, leading to their suspension and the initiation of a criminal investigation by the trust’s counter fraud specialist. The shifts in question were for a medium secure unit, where biometric data is required for staff access. The investigation cross-referenced work claims with entry and exit records, revealing that the staff member was not present on site during any of the shifts cited for payment. This resulted in dismissal for gross misconduct. The former nurse’s employer referred the case to the Nursing and Midwifery Council (NMC), which has since suspended this individual, prohibiting them from working as a nurse. A representative from the trust’s anti- fraud team welcomed the result and sentence, highlighting the significance of the fraud and its impact on NHS resources. The internal processes have been reviewed with the relevant staffing agency to help prevent similar issues arising.
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Court Orders Individual to Repay Over £400,000 Defrauded from NHS After Fake Psychiatrist Scam
An individual who fraudulently worked as a psychiatrist for 22 years has been ordered by Manchester Crown Court to repay £406,624 to the NHS or face an additional two and a half years in prison. The sum reflects all currently known assets and must be repaid within three months.
I nvestigators from the NHSCFA, using the Proceeds of Crime Act, secured a confiscation order to recover money from this person’s assets, with the returned funds set to be distributed to the affected NHS trusts.
This person was found to have forged medical qualifications and deceived the General Medical Council with fake documents in 1995 to register as a doctor in the UK. Over two decades, they fraudulently obtained more than £1 million from various UK health bodies and were convicted in 2023 of multiple offences, including fraud and forgery. The truth came to light after a local journalist queried the legitimacy of their qualifications, prompted by a previous court case in 2016 involving an attempt to inherit £1.3 million from a ‘patient’ via a forged will. The Police, alongside the NHSCFA, investigated the forged registration documents.
Specialist investigators identified assets including several properties and cash held in UK bank accounts, enabling the repayment order. A spokesperson for the NHSCFA welcomed the decision, highlighting it as a warning that those defrauding the NHS will be pursued and made to pay back what has been stolen. The collaboration between multiple agencies was praised as being key in bringing the matter to justice and recovering funds for the NHS.
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Four Individuals Imprisoned for £6 Million Bribery and Corruption Offences Against NHS Scotland
Four people have been sentenced to a total of 29 years in prison after being found guilty of fraud, bribery, and corruption in connection with NHS Scotland. Two of those convicted were former NHS employees, while the other two held director positions at an external company involved in the offences. Prison sentences ranged from six to eight years for each person.
T he case was led by NHS Scotland Counter Fraud Services, with key support from Police Scotland and the NHSCFA’s Digital Forensic Unit. Investigators compiled more than 4,000 items of evidence, including dozens of mobile phones and laptops, and interviewed over 250 witnesses to build the case.
The investigation originated following an enquiry into missing mobile phones and unaccounted bills for overseas calls. Subsequent enquiries revealed that, between 2010 and 2017, two individuals working for the NHS accepted bribes, hospitality, and cash incentives totalling £100,000. In exchange, they provided sensitive information useful for awarding contracts valued at £6 million. These contracts related to the provision, installation, and maintenance of telecommunications and video conferencing across NHS Scotland. Many incentives and inducements were ultimately found to have been paid for by the NHS itself through fraudulent, inflated, or duplicate invoices. In 2015, search warrants were executed at both NHS and company premises, during which significant physical
and digital evidence was collected. The Digital Forensic Unit created on-site forensic copies of company servers and analysed thousands of text messages and emails, uncovering deliberate efforts to divert and misuse NHS funds for personal benefit, undermining both patient care and public trust. Senior figures from NHS Scotland Counter Fraud Services and the NHSCFA highlighted that this prosecution demonstrates a strong commitment to protecting NHS funds and serves as a clear warning that financial crimes within the health service will be pursued vigorously.
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Strengthening Internal Controls within Healthcare Organisations
Healthcare organisations can significantly reduce the risk of fraud by reflecting on recent cases and embedding robust controls into their daily practice based on lessons learnt. The following provides some examples of key areas of weakness identified, and how these can be improved.
Sickness Absence Documentation When an employee returns from sickness absence, during the return-to-work interview managers should ask about any work, training or study undertaken during the absence, and also ensure that the individual’s response is documented. Relying on verbal confirmation is not sufficient. Action - Require completion and secure storage of self-certification forms for every period of sickness, ensuring all mandatory questions are answered and evidence of the responses provided is retained.
Annual Leave Management Failings in recording and reconciling annual leave entitlements can lead to staff taking more leave than permitted. For example, system errors may result in incorrect annual leave settings or unexpected hours being deducted. This may require recouping leave through salary deductions, which is both time-consuming and potentially contentious. Action - Regularly review electronic rostering systems to confirm annual leave entitlements are correctly set. Managers should double-check that approved leave matches scheduled working hours.
Effective Use of Workforce Information and Declarations A situation occurred where a former employee, under investigation for fraud, was able to secure another role within the same organisation because the hiring manager was not informed of the previous investigation, despite the individual disclosing this information in a standard declaration. Action - Establish a procedure whereby, if a prospective hire declares a prior investigation or similar concern, resourcing or HR teams inform the hiring manager after all checks are completed but before their appointment is confirmed. This can help ensure safer, more informed hiring decisions. Internal controls rely not just on having policies, but on implementing them consistently and communicating clearly between teams. A culture that prioritises documentation, regular system reviews, and open sharing of relevant information between departments can make a real difference in preventing fraud.
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Reminder: Failure to Prevent Fraud Offence Takes Effect 1 September 2025. Are You Ready?
From 1 September 2025, the new UK “failure to prevent fraud” offence will be enforced as part of the Economic Crime and Corporate Transparency Act 2023. This law marks a significant shift in fraud prevention requirements for all large organisations, including those within the NHS and healthcare sector.
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What Does the New Offence Cover? The offence applies to large organisations, holding them criminally liable if an employee, agent, subsidiary, or other associated person commits a relevant fraud offence intending to benefit the organisation. Covered fraud offences include, but are not limited to:
Additional NHS-Specific Advice Use NHSCFA’s resources for NHS bodies and match your procedures to the requirements of the Government Functional Standard. Look to implement continuous improvement. Set a timeline for regular reviews and enhancements of your anti-fraud measures. Why Act Now? Failure to prepare may result in unlimited fines and reputational harm if your organisation is found liable after a fraud occurs. Regulatory leaders and the Serious Fraud Office have made it clear that there will be robust enforcement.
Key Practical Steps to Take Now
1. Review and Update Policies Adapt your policies to incorporate the new failure to prevent fraud offence. This includes whistleblowing, HR, fraud, and communications policies. Ensure sub-contractors are also included in fraud prevention measures. 2. Establish Clear Reporting Pathways Make sure there are straightforward processes for staff to report concerns about fraud. Promote a culture where fraud prevention is everyone’s responsibility. 3. Demonstrate Reasonable Prevention Procedures You must be able to show that you have taken reasonable steps to deter, prevent, and detect fraud. Your procedures should be tailored using guidance from the Economic Crime and Corporate Transparency Act 2023, statutory Home Office advice, and resources from NHSCFA. 4. Map to the Six Principles for Fraud Prevention The Home Office guidance outlines six key principles, as follows
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Fraud by false representation
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Fraud by abuse of position
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Fraud by failing to disclose information
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False accounting
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Participation in fraudulent business
Final Checklist for Healthcare Organisations
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Cheating the public revenue
✓ ✓ Review the statutory Home Office guidance side by side with the NHSCFA’s practical advice.
If prosecuted, an organisation’s main defence will be to demonstrate it had “reasonable procedures” in place to prevent fraud, or that it was not reasonable to expect such procedures. Who Is Affected? In the healthcare sector, the legislation primarily targets large organisations, including NHS trusts and their subsidiaries. It has extra-territorial reach, meaning it applies to organisations based outside the UK if there is a UK connection, such as NHS contracts or affected NHS services.
✓ ✓ Complete a fraud risk assessment.
✓ ✓ Adapt and update all relevant internal procedures and policies.
✓ ✓ Roll out employee and contractor training.
✓ ✓ Establish evidence trails documenting your anti-fraud efforts.
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Top-level commitment: Senior leaders should set the tone and priorities.
If you have any questions regarding the new offence, please do get in touch with our Counter Fraud Team.
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Risk assessment: Regularly identify and understand fraud risks.
What Should NHS Bodies and Large Organisations Do to Comply?
The NHSCFA urges all organisations in scope to act now. Statutory guidance published by the Home Office should be used alongside NHS- specific advice.
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Proportionate procedures: Tailor actions to your risk profile.
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Due diligence: Check backgrounds of employees, agents, and partners.
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Communication and training: Promote awareness and provide targeted training.
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Monitoring and review: Evaluate controls and update them as needed.
5. Tailor Procedures to Your Organisation Assess what is reasonable for your circumstances and ensure procedures are proportionate to the size and nature of your organisation. 6. Prepare Documentation Keep evidence of your policies, risk assessments, communications, and training as this supports your defence if required.
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Reporting Fraud
Everyone has a part to play in fighting fraud. If you work for the NHS and suspect any fraud, bribery, or corruption against the NHS, please contact your Local Counter Fraud Specialist. Alternatively, please contact the NHSCFA 24-hour reporting line by calling 0800 028 4060 , or by completing the online reporting form. All reports are treated in confidence, and you have the option to remain anonymous.
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