Fraud Awareness

Counter Fraud and Anti-Bribery

Fraud and bribery within the NHS is not acceptable. These criminal offences divert valuable resources away from patient care and can put patients at risk. The CCG takes a zero-tolerance approach towards tackling fraud and bribery.

Each NHS organisation must have a Local Counter Fraud Specialist (LCFS) in place, who is responsible for tackling all fraud and bribery offences and risks, to protect valuable NHS resources and ensure they can be used to provide the best possible patient care.

If we are to succeed in reducing fraud and bribery to an absolute minimum, we need the help and vigilance of staff within the CCG. You have a vital role to play in putting a stop to the criminal actions of a dishonest few.

What is fraud?

Fraud happens when someone does something dishonestly to make a gain for themselves, or another; or cause a loss, or a risk of loss to another. According to the Fraud Act 2006, it is not necessary to prove a person has been deceived. The focus is on the individual's dishonest behaviour and intent. Just trying to commit fraud, even if not successful, makes the act complete.

There are three main offences commonly referred to under the Fraud Act 2006:

False representation

Examples of this could be: submitting a false timesheet that is not reflective of hours worked; exaggerating travel expenses or claiming for journeys that have never been undertaken; or claiming sick leave from the CCG but working elsewhere.

Patients are equally as able to make a false representation. The commissioner’s report on economic crime states that 90 per cent of reports involving UK patients relate to prescription misuse and prescription charge evasion.

Failing to disclose information

Common examples of this are: not declaring previous criminal convictions on an application form; or failing to disclose any outside interests as they occur, allowing a conflict of interest to arise.

Abuse of position

Examples of this could be: manipulating statistics to achieve a target; or creating a post for a family member and bypassing recruitment processes.

What is bribery?

Bribery is generally defined as giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly; or to reward that person for having already done so. In other words, bribery involves offering an incentive to someone to do something which they wouldn’t normally do. For example, someone offering a job might be offered tickets to an event by one of the candidates, or someone linked to them, in order for the application to be successful.

Bribery Act 2010

In the context of the Bribery Act 2010, the offence of bribery refers to accepting, as well as offering, a bribe.

The three offences most relevant to the NHS are:

  • Section 1: Offering, promising, or giving a bribe to another person to perform a relevant ‘function or activity’ improperly, or to reward a person for the improper performance of such a function or activity.
  • Section 2: Requesting, agreeing to receive, or accepting a bribe to perform a function or activity improperly.
  • Section 7: Failure of a commercial organisation to prevent bribery (the corporate offence).

How to identify if someone is trying to bribe you

If you believe that someone may be trying to bribe you, ask yourself the following questions:

  • Have you been offered any gifts or hospitality?
  • Is the gift / hospitality reasonable and proportionate?
  • What would you regard as reasonable and proportionate?
  • Do you believe the gift or hospitality may be an attempt to influence you, because of your position?

If you are not happy with any of your answers, report your concerns to your LCFS.

How to report suspected fraud or bribery

Whether you are a member of staff; a patient; a member of the public; a contractor; a supplier; from another government agency; or someone else, your input can make a real difference. If you think that you have identified fraud or bribery:

DO your suspicion to your LCFS immediately
...keep any evidence safe
...make notes on what you heard / saw


...rely on someone else to make the call
...ignore it any suspect yourself
...start an investigation yourself
...discuss your concerns with anyone other than your LCFS, NHS Counter Fraud Authority, Chief Finance Officer, or the CCG’s whistleblowing guardian

Contact Information

  • Local Counter Fraud Specialist: Antony Upton
  • Mobile: 07484 040694
  • Email:

NHSCFA fraud and corruption reporting line

Whistleblowing Guardian: Stuart Rees (CFO)

Last updated: 04/03/2020