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1 Health Finance Directorate abcdefghijklmnopqrstu T: F: E: Dear Colleague REVISED FORM SFR 18: ENHANCED REPORTING OF NHS FRAUDS AND ATTEMPTED FRAUDS 1. This letter announces enhanced, anonymised, statistical reporting by NHS bodies of NHS frauds and attempted frauds from 1 April 28, using revised form SFR 18. A copy of this form and accompanying instructions on its completion are attached as an Annex. Background 2. At present, there are varied ways of reporting NHS fraud and other financial irregularities. For example, NHS bodies report to the Scottish Government any losses due to theft, fraud or arson in the SFR 18 form; auditors employed or engaged by NHS bodies must make submissions to Audit Scotland of instances of fraud and irregularity; and NHSScotland Counter Fraud Services (CFS) provides reports to NHS s and special Health s, and statistics, as required, to the Scottish Government, on NHS fraud cases they have investigated. None of these reports is completely comprehensive and it is difficult to compare information since the reports/returns are compiled according to different rules/timescales and in differing formats. The level of detail in most fraud reporting is therefore insufficient for any meaningful analysis. 3. A more coherent fraud reporting policy is required which will lead to enhanced recording and reporting of all frauds and attempted frauds. The format of the SFR 18 form has been changed to accommodate this and to improve reporting of all relevant items. This will be used for reporting purposes from 1 April 28. NHSScotland Counter Fraud Services will complete the SFR 18.1(c) as it relates to NHS frauds/attempted frauds for each, i.e. the SFR 18.1(c), to streamline reporting procedures and ensure as far as possible that reporting is uniform, all cases are recorded and there is no doublecounting. The purpose of enhanced recording and reporting will be to enable the Scottish Government and NHS bodies to better understand the scale and types of identified NHS frauds, the categories within which these fall, the amounts involved, where applicable (since not all frauds/attempted frauds reported will have an attributable cost), and recoveries made. The reporting of attempted frauds will allow a better estimate of identified fraud losses and potential losses to the NHS to be made. Enhanced reporting will also provide evidence as to the effectiveness of actions being taken to counter fraud. CEL 44 (28) 9 October 28 Addresses For action Finance and HR Directors, NHS and Special Health s, NHS National Services Scotland For information Audit Committee Chairs, Chief Internal Auditors, Fraud Liaison Officers, Employee Directors NHS and Special Health s and NHS National Services Scotland Auditor General NHSScotland Counter Fraud Services Scottish Partnership forum S.W.A.G. Enquires to: Senga Robertson Primary Care Division Floor 1ER St Andrew s House Regent Road Edinburgh EH1 3DG Tel: Fax: senga.robertson@scotland. gsi.gov.uk

2 4. Audit Scotland have indicated that they are content with the proposed way forward and will therefore no longer require separate independent reporting of frauds by external auditors. The Technical Accounting Group has reviewed and approved the changes. Action 5. Directors of Finance and Directors of Human Resources in NHSScotland bodies are asked to: ensure that arrangements are put in place, where not already available, to gather and record in full the information required on frauds/attempted frauds for the SFR 18.1 ( C) forward information covering the period 1 April - 3 September 28 to NHSScotland Counter Fraud Services by end November; thereafter forward information to NHSScotland Counter Fraud Services on a quarterly basis to enable completion of form SFR 18.1 (C ) for each ; note that the statistics will be presented in anonymised form; and note that completed SFR 18 forms should accompany the annual health accounts when forwarded to the Scottish Government Health Directorates rather than forming part of these. 6. The Head of Service, CFS is asked to: complete SFR 18.1(c) on behalf of each based on the returns from s on frauds/attempted frauds actioned internally and on the CFS s own fraud action; forward the completed SFR18.1(c) to the Director of Finance at each in accordance with the Annual Accounts timetable; and forward all completed SFR 18.1(c)s to Audit Scotland along with all covering letters for circulation to auditors. Yours sincerely JOHN MATHESON Director of Health Finance

3 [Insert Name] SFR 18.1a Details of Delegated Athroity of NHS For Losses and Special Payments For the Year Ended 31 March 29 Item No. Category Delegated Authority (per case) Category 1 Category 2 Category 3 Theft / Arson / Wilful Damage 1 Cash 2, 15, 1, 2 Stores/procurement 4, 3, 2, 3 Equipment 2, 15, 1, 4 Contracts 2, 15, 1, 5 Payroll 2, 15, 1, 6 Buildings & Fixtures 4, 3, 2, 7 Other 2, 15, 1, Fraud, Embezzlement & other Category 1 Category 2 Category 3 irregularities (inc. attempted fraud) 8 Cash 2, 15, 1, 9 Stores/procurement 4, 3, 2, 1 Equipment 2, 15, 1, 11 Contracts 2, 15, 1, 12 Payroll 2, 15, 1, 13 Other 2, 15, 1, 14 Nugatory & Fruitless Payments 2, 15, 1, 15 Claims Abandoned (a) Private Accommodation 2, 15, 1, (b) Road Traffic Acts 4, 3, 2, (c) Other 2, 15, 1, Stores Losses 16 Incidents of the Service - Fire 4, 3, 2, - Flood 4, 3, 2, - Accident 4, 3, 2, 17 Deterioration in Store 4, 3, 2, 18 Stocktaking Discrepancies 4, 3, 2, 19 Other Causes 4, 3, 2, Losses of Furniture & Equipment And Bedding & Linen in circulation: 2 Incidents of the Service - Fire 2, 15, 1,

4 - Flood 2, 15, 1, - Accident 2, 15, 1, 21 Disclosed at physical check 2, 15, 1, 22 Other Causes 2, 15, 1, Compensation Payments - legal obligation 23 Clinical * 25, 25, 25, 24 Non-clinical * 1, 1, 1, Ex-gratia payments: 25 Extra-contractual Payments 2, 15, 1, 26 Compensation Payments - Ex-gratia - Clinical * 25, 25, 25, 27 Compensation Payments - Ex-gratia - Non Clinical * 28 Compensation Payments - Ex-gratia - Financial Loss * 1, 1, 1, 25, 25, 25, 29 Other Payments 2,5 2,5 2,5 Damage to Buildings and Fixtures: 29 Incidents of the Service Fire 4, 3, 2, - Flood 4, 3, 2, - Accident 4, 3, 2, - Other Causes 4, 3, 2, 31 Extra-Statutory & Extra-regulationary Payments Nil Nil Nil 32 Gifts in cash or kind 2, 15, 1, 33+ Other Losses 2, 15, 1, Category 1 s - NHS Greater Glasgow and Clyde and NHS Lothian Category 2 s - Remaining Regional s, NSS and Scottish Ambulance Service Category 3 s - Island s and Remaining Special Health s All frauds and attempted frauds must be detailed on form SFR 18.1(c) * This delegated limit was revised as at 1st August 21 HDL (21)65 + those losses which do not broadly fall within the definitions of theft, arson, wilful damage, fraud, embezzlement and attempted fraud and would have fallen within the previous item 2 Cash Losses overpayments of salaries, wages and allowances and the previous item 3 Cash Losses Other should be included within this heading

5 [Insert Name] SFR 18.1 (b) DETAILS OF LOSSES AND SPECIAL PAYMENTS ABOVE DELEGATED AUTHORITY OF NHS BOARD FOR THE YEAR ENDED 31 MARCH 28 Item No. Brief Description of Each Case Value of Loss or Payment ** Date of Authority by SEHD *** * * Please complete additional lines/pages as required. *** Use format //

6 [Insert Name] SFR 18.1 (c) DETAILS OF FRAUD, EMBEZZLEMENT AND OTHER IRREGULARITIES (INC. ATTEMPTED FRAUD) FOR THE YEAR ENDED 31 MARCH 28 Case No. Definition No. (see Notes page) Loss Area No. (see Notes page) Value of Loss/Potential Loss Sanctions / Actions Taken / Recoveries (type/outcome)

7 SFR 18.1 (c) (Notes) DETAILS OF FRAUD, EMBEZZLEMENT AND OTHER IRREGULARITIES (INC. ATTEMPTED FRAUD) Notes 1 Completion NHSScotland Counter Fraud Services will complete Form 18.1 (c) on behalf of s based on the returns from s on frauds actioned internally and on CFS' own fraud actions. The completed form will be forwarded to s in accordance with Annual Accounts timetable. 2 Recording Where a fraud or attempted fraud has no attributable monetary value (e.g. in the falsification of job references uncovered before employment commences) the case will be recorded with a value of n/a. 3 Definitions 1 Fraud 2 Attempted Fraud 3 Embezzlement 4 Attempted Embezzlement 5 Corruption 6 Attempted Corruption 7 Theft (where documentation has been falsified) 8 Attempted Theft (where documentation has been falsified) 4 Loss Area 1 Cash 2 Stores/procurement 3 Equipmen t 4 Contracts 5 Payroll 6 Other 5 General The Scottish Government Health Directorates (SGHD) wish to obtain as full a picture as possible of frauds committed or attempted against the NHS. Consequently, where an unusual fraud or attempted fraud is identified, a description should be listed in the "Definition" column of SFR 18.1(c), alongside the definition itself. It is accepted that certain frauds can only be measured on a national basis. For this reason, CFS will supply SGHD with such national data separately from individual SFR forms

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