COUNTER FRAUD PROGRESS REPORT

Transcription

1 REPORT PREPARED BY:- Len Cozens Lead Local Counter Fraud Specialist REPORT SPONSORED BY:- Paul Gilchrist Acting Director of Finance Audit Committee 16 th March 2017 Agenda Item : Attached Marked : COUNTER FRAUD PROGRESS REPORT 1. PURPOSE 1.1 The purpose of this report is to update the Audit Committee on key areas of work undertaken by the Health Board Local Counter Fraud Specialists since the last meeting. 1.2 Meetings are held on a monthly basis with the Acting Director or Assistant Director of Finance, where progress against the annual work plan and with the LCFS case workload is reported and monitored in detail. 1.3 The following sets out activity under the Key Principles specified within the Fraud, Bribery and Corruption Standards for NHS Bodies (Wales). 2 STRATEGIC GOVERNANCE 2.1 All NHS organisations in Wales are required to complete an annual self-review of their progress in implementing the Fraud, Bribery and Corruption Standards for NHS Bodies (the Standards), the results of which must be forwarded to the NHS Protect Quality & Compliance Team for evaluation. The 2017/18 version of the Standards was issued on 26 th January 2017, and the self-review has commenced. The review process must be finished, and completed documents submitted to NHS Protect by 1 st April A copy of the submission will also be shared with the Audit Committee. 2.2 On 8 th February 2017, the Lead LCFS attended a liaison meeting with the Operational Fraud Manager (NHS Wales) and NHS Protect s Senior Quality and Compliance Inspector (SQCI), during which it was confirmed that ABMU Health Board will this year receive a quality assurance site visit. The exact date of the visit has yet to be confirmed, but is expected to be in April or May A synopsis of the quality assurance process, including self review completion and site visits, has been included at Appendix 1 for information. 3. INFORM AND INVOLVE 3.1 As detailed within the /17 Counter Fraud Work Plan, an on-going programme of work has been put in place to raise awareness of fraud, bribery and corruption 1

2 amongst all staff and practitioners across all sites. To that end, the LCFS Team has delivered 89 fraud awareness presentations so far this year, reaching over 1,700 attendees. 3.2 In addition to the above, the LCFS Team also produce and distribute a biannual Counter Fraud Newsletter, which contains articles on proven fraud cases designed to deter fraud, and promote fraud awareness amongst AMBU staff and primary care contractors. The latest edition of the Newsletter has been completed and will be distributed across the organisation during March A copy has been included at Appendix 2 of this report. 4. PREVENT AND DETER 4.1 The National Fraud Initiative (NFI) is a data matching exercise which has been run on a biennial basis since Electronic data is matched within and between public and private sector bodies in order to identify, prevent and deter fraudulent and erroneous payments. 4.2 The -17 exercise is currently underway. In line with the timetable and specifications set, Health Board payroll and trade creditor data was submitted during October, and confirmation of the matches which require further review was subsequently made available on 26 th January Over the coming months, the Lead LCFS will liaise with relevant key contacts in order to analyse these matches, with the initial emphasis being placed on those identified by the Cabinet Office as being of high priority. 5. HOLD TO ACCOUNT 5.1 The status of the LCFS investigative caseload at the time of reporting is summarised at Appendix 3 for information. This shows that the caseload consists of a total of 39 live cases, 5 of which having reached a stage where the production of preliminary closure reports has commenced. A total of 16 cases have been closed to date during the current year. 5.2 In addition to the cases being directly investigated by the local team, the Counter Fraud Service (Wales) is currently investigating 3 cases on behalf of the Health Board. The LCFS continue to monitor progress and provide assistance where necessary with those investigations, and update reports are received by the Acting Director and Assistant Director of Finance. 6. RECOMMENDATION 6.1 The Audit Committee is asked to note the Counter Fraud Progress Report. 2

3 Appendix 1 THE COUNTER FRAUD QUALITY ASSURANCE PROCESS 1. Background 1.1 The Fraud, Bribery and Corruption Standards for NHS Bodies (Wales) were first produced by NHS Protect in May 2013, and have subsequently been reviewed and updated every year since. The current Standards are applicable to all NHS organisations in Wales, and are designed to ensure that anti-fraud, bribery and corruption measures are implemented in accordance with Health and Social Services Directions, and the service level agreement between the Welsh Government and NHS Protect under Section 83 of the Government of Wales Act There are currently a total of 24 Standards which have been developed to support NHS organisations in implementing appropriate measures to counter fraud, bribery and corruption. They are grouped under the following 4 Key Principles: Strategic Governance which sets out the standards in relation to the organisation s strategic governance arrangements, with the aim of ensuring that anti-fraud, bribery and corruption measures are embedded at all levels across the organisation. Inform and Involve which sets out the requirements in relation to raising awareness of fraud, bribery and corruption risks against the NHS, and working with staff, stakeholders and the public to highlight the consequences. Prevent and Deter which sets out the requirements in relation to discouraging individuals who may be tempted to commit fraud against the NHS, and ensuring that opportunities for it to occur are minimised. Hold to Account which deals with the requirements relating to detecting and investigating fraud, bribery and corruption, prosecuting those who have committed offences, and seeking redress. 2. Self Review 2.1 On an annual basis, NHS organisations in Wales are required to complete a self-review of their progress in implementing these Standards, the results of which must be forwarded to the NHS Protect Quality & Compliance Team. The review utilises a traffic light system, with performance against each of the Standards being assessed as red, amber or green (RAG). This in turn generates an overall RAG rating for each Key Principle, and a final RAG 3

4 rating for the organisation as a whole. Further detail on the red, amber and green ratings can be found at Section Along with the outcome of their self-review, organisations are also required to forward copies of their Counter Fraud Annual Report and Counter Fraud Work Plan. 3. The Assessment Process 3.1 All submitted self-review documents, together with the corresponding annual reports and work plans, are evaluated by the NHS Protect Quality & Compliance Team. Based on this evaluation, a risk-based decision will then be taken on which organisations are to receive an assessment site visit, and the type of assessment to be undertaken. 3.2 Site visits are typically conducted by a Senior Quality and Compliance Inspector. During the course of a visit, one of four types of assessment will be undertaken: Full Assessment This will involve a review of the implementation of most or all of the Standards under all 4 Key Principles Focussed Assessment This will typically involve a review of the implementation of Standards under no more than two of the Key Principles. Thematic Assessment This would typically apply to a number of organisations and may be conducted regionally or across organisations of a similar type. The focus of such assessments is likely to be fairly narrow, focussing on possibly one or two individual Standards rather than a whole Key Principle. Triggered Assessment Organisations not selected for a full, focussed or thematic assessment when the annual assurance is received, may be selected for a triggered assessment at any stage during the year. Triggered assessments are normally driven by emerging areas of risk which have come to the attention of the Quality and Compliance Team during the year, and can be Focussed or Full in nature. 3.3 Prior to any site visit, the SQCI will request information from the organisation in relation to the proposed area(s) of enquiry. This information enables the SQCI to formulate relevant questions in advance, and assist in the review of further evidence collected during the course of the visit. 4

5 3.4 During the course of the visit, the SQCI will speak to the Lead Counter Fraud Specialist in relation to the work conducted. Depending on the area of enquiry and the type of assessment being conducted, the SQCI may also wish to speak to the member of the Executive Board responsible for overseeing anti-fraud, bribery and corruption work, and any other key staff deemed appropriate. 3.5 Based on a review of the assurance provided (self-review documents, together with the corresponding annual reports and work plans), and the evidence gathered and meetings held during the site visit, the SQCI will draft an assessment of the organisation s performance in implementing each of the Standards included in the review, together with any relevant recommendations for the organisation to take forward. The draft ratings and recommendations will then be discussed at a closing meeting. At this stage, it is expected that the rating, recommendations and proposed actions can be agreed. 3.6 A finalised report will follow the site visit within four weeks. The report will outline the findings of the visit in full and include the ratings and recommendations discussed and agreed at the closing meeting. Within another four weeks, the organisation is expected to complete an action plan for the recommendations and return it to the SQCI. 3.7 Depending on the nature and outcome of the assessment, some organisations may be subject to a further assessment between nine and twelve months following the original. This is an integral part of the process for full assessments, and may also form part of a focussed assessment process in some cases. This second review should only focus on the progress made against recommendations following the original, unless there are significant matters which have arisen in the meantime. 4. Performance Levels 4.1 As a result of the assurance and assessment process, organisations are rated as being at a level of red, amber or green depending on how well they have performed in implementing the Standards. 4.2 The definitions for each performance level are as follows: RED Non-Compliance with the Standard A risk has been identified but no action has been taken to mitigate it, or the action taken is insufficient in scope. AMBER Partial compliance with the Standard but little or no impact of work A risk has been identified and action has been taken to mitigate that risk. There is evidence of compliance through outputs. However, the effectiveness 5

6 of the work undertaken has not yet been evaluated, or there is no reduction of the risk. There is therefore little or no evidence of outcomes. GREEN Full compliance demonstrating impact of the work A risk has been identified, work has been carried out and the effectiveness of this work has been measured. The risk has been mitigated, or significant progress has been made in mitigating the risk. Outcomes are therefore present. 4.3 Organisations which fulfil the requirements of a Standard, and can provide evidence of this through evaluation, can determine performance to be green for that Standard. Organisations which can provide evidence of activity carried out, but cannot yet demonstrate that the activity has been assessed for effectiveness will determine performance to be amber for that Standard. Organisations which have carried out no activity or do not have evidence of sufficient activity will need to determine performance at the red rating. Each rating reached for each standard contributes to an overall rating for the relevant Key Principle, as well as an organisational rating for achievement against all of the Standards. 6

7 Counter Fraud Newsletter Winter FORMER ABMU WARD CLERK IMPRISONED AFTER PLEADING GUILTY TO FRAUD A former ABMU employee has pleaded guilty to charges of fraud, false accounting and theft following a joint investigation involving South Wales Police and the Health Board. Kay Morgan, of Brynmenyn in Bridgend, was employed as a Ward Clerk at the Caswell Clinic Medium Secure Unit. Her responsibilities included management of the petty cash on Cardigan Ward, as well as withdrawing money from the Glanrhyd Hospital bank on behalf of some of the patients there. In December 2013 Clinic staff became concerned about a particular withdrawal which had been made by Morgan, and South Wales Police and the Health Board LCFS were immediately informed. A detailed investigation followed involving the analysis of documents relating to thousands of petty cash transactions and cash withdrawals made by Morgan, many of which were reviewed by a forensic handwriting expert. It was found that Morgan had abused her position of trust by making multiple petty cash withdrawals and keeping the money for herself, in a scam which saw her net thousands of pounds over a number of years. On each occasion she would fill out all of the necessary documentation herself, and then falsify the signature of one or more of her colleagues in order to gain access to the money. On one occasion she even withdrew money from a patient s account, having falsified his signature on the request form. Morgan protested her innocence throughout the investigation. However at a hearing held on 24th October at Cardiff Crown Court, she eventually pleaded guilty to one count of theft, one count of false accounting, and seven counts of fraud by abuse of position. She was subsequently sentenced to 21 months imprisonment for each of the fraud and false accounting charges and nine months imprisonment for the theft, all to run concurrently. She was also order to pay a total of 21, in compensation. In a statement made following Morgan s conviction, Detective Sergeant Scott Howe of South Wales Police said This has been a lengthy and complex investigation, which has seen South Wales Police work very closely and determinedly with Abertawe Bro Morgannwg. She [Morgan] repeatedly breached her position of trust by callously targeting not only her employer and her colleagues, but also a vulnerable patient. We hope this case serves as a deterrent to anyone who thinks it is acceptable to take advantage of vulnerable people in this way.

8 Page 2 ABERTAWE BRO MORGANNWG UNIVERSITY HEALTH BOARD DIALYSIS MANAGER AND ACCOMPLICES JAILED FOR NHS FRAUD A former NHS manager, his partner, and three private contractors have been sentenced for fraud offences following an investigation by NHS Counter Fraud Specialists. Fraud against the NHS is not a victimless crime but one that is draining the lifeblood from necessary treatments in hospitals and GPs surgeries Alan Hodge, of Sutton in Surrey, was employed by Epsom and St Helier University Hospitals NHS Trust as a Renal Technical Department Manager, responsible for maintaining the dialysis equipment across three sites. He also visited patients homes to decide what modifications would be needed for them to receive home dialysis, and to procure the works required. As part of his role, Hodge engaged three local companies on contracts to undertake the resulting work on behalf of the Trust. In each case the proprietors of these companies were already known to Hodge, although he did not declare this at the time: Mains Contractors S J Thompson Plumbing TWS (Southern) Ltd Proprietor: Pierre Allen Proprietor: Stephen Thompson Proprietor: Phillip Jones Attention first focussed on Hodge after the Trust suspended him from work for an unrelated matter. The manager of the renal department noticed that while he was away, far fewer invoices were being presented to her for Non-pay related expenditure within his area of work dropped by more than half. Subsequent investigations identified a total of 266 separate invoices submitted by the three contractors for work which was either not done at all, done far more frequently than was necessary, or was greatly overpriced. These included: Modifications to patient s homes for dialysis treatment, even though they did not receive their treatment at home Electrical and plumbing installation work at a local prison, which had actually been undertaken by prison staff Installation of dialysis equipment at a second prison, which had actually been undertaken by Hodge and another member of Trust staff as part of their NHS duties.

9 ABERTAWE BRO MORGANNWG UNIVERSITY HEALTH BOARD Page 3 In addition to the above, a detailed review of text and chat messages between Hodge and the three company proprietors indicated that they were colluding to falsely inflate the invoices they submitted for work they had actually carried out. They would then share the payments received between themselves. Some of the conversations between Hodge, Allen and Thompson even suggested that Hodge was actually generating invoices on behalf of Mains Contractors and S J Thompson Plumbing, despite supposedly engaging these companies as contractors. The investigation found that Pierre Allen made regular payments by cheque, bank transfer and cash totalling over 94,000 to Hodge, after receiving payments from the Trust for work allegedly carried out by Mains Contractors. He also made payments by cheque to Hodge s partner, Lisa Green, totalling over 9,000. Stephen Thompson would receive regular text or chat messages from Hodge, advising him of when payments would be made by the Trust into his company s account. Hodge would then ask Thompson to withdraw large sums in cash, and arrange to meet in order to collect his share. TWS (Southern) Ltd also made regular payments by cheque and bank transfer totalling over 11,000 to the respective accounts of Hodge and Green. All of the payments received by Green were later transferred into Hodge s account. After a seven week trial, Alan Hodge, Pierre Allen and Stephen Thompson were all found guilty of Fraud by Abuse of Position. Hodge was sentenced to 4 years imprisonment, Allen to 3 years imprisonment and Thompson to 2 years imprisonment. Lisa Green was found guilty of a money laundering offence and received a 6 month prison sentence suspended for 12 months, and was ordered to do 100 hours of unpaid work. Phillip Jones, who was the only one of the group to plead guilty to a charge of Fraud by Abuse of Position at an earlier hearing, received a 12 month prison sentence suspended for 2 years, and was ordered to do 250 hours of unpaid work. We press for prosecution of offenders and seek the strongest possible sanctions so public money is not diverted from patient care

10 Page 4 ABERTAWE BRO MORGANNWG UNIVERSITY HEALTH BOARD FORMER NHS ENGLAND EQUALITY LEAD AND HER HUSBAND GUILTY OF NHS FRAUD NHS England s former National Lead for Equality and her husband have both pleaded guilty to fraud against the NHS following an investigation by NHS Counter Fraud Specialists. At the time of the offences, in addition to her national equality role, Paula Vasco-Knight was also employed as the Chief Executive Officer of South Devon Healthcare NHS Foundation Trust. In November 2013 her husband Stephen Vasco-Knight submitted an invoice to the Trust for 11,072. The invoice was allegedly for work carried out by his graphic design business Thinking Caps, on the production of a document about leadership for NHS CEO s. Payment was authorised by his wife in December 2013, however in reality no work had ever been commissioned or undertaken. Anyone who commits fraud against the NHS is taking money away from patient care During the course of the investigation, the Vasco-Knights tried to retrospectively manufacture a 200-page document to justify the payment of the invoice. Entitled Transform they presented it in March during an interview under caution. However investigators were able to establish that the document could not possibly have been originally produced in November 2013 as they claimed, as it contained large passages of text copied straight from a bona fide King s Fund document which was not published until November At a subsequent hearing held at Exeter Crown Court Paula Vasco- Knight, who was awarded a CBE for her work on equality and diversity within the NHS in the January 2014 Honours List, pleaded guilty to a charge of Fraud by Abuse of Position. Her husband pleaded guilty to a charge of Fraud by False Representation. The couple have yet to be sentenced, but have been told that an immediate custodial sentence is a distinct possibility.

11 ABERTAWE BRO MORGANNWG UNIVERSITY HEALTH BOARD Page 5 CONSULTANT RADIOLOGIST PLEADS GUILTY TO 24,000 NHS FRAUD A Consultant Radiologist has pleaded guilty to Fraud by False Representation following an investigation carried out by NHS Local Counter Fraud Specialists. John Coffee, of Chipping in Preston, was responsible for reviewing and reporting on a variety of medical scans. In order to help his department clear a waiting list backlog, he agreed to undertake additional work and study plain film standard x-rays outside his normal working hours (after 5:00pm) at a rate of 4 per film. Coffee had previously claimed that he was far too busy and had no capacity to take on any additional duties. However once extra money was made available to carry out this work, he actually completed most of it within his normal working hours. In an audacious yet simple scam, he would write the reports on the plain film x-rays during his working day when he was supposed to be doing his normal job-plan work, but wait until 5:00pm to re-enter the clinical IT system and hit the submit button. In one day during March 2014 between 11:20am and 5:00pm, The investigation showed that Coffee reviewed and reported on 100 plain film x-rays during a session when he should have been undertaking his normal job-plan work. This represented a loss to the NHS of 400. We can only achieve our aims if we work together Further investigation showed that this was not a one-off; Coffee was routinely and consistently undertaking after hours waiting list work during NHS contracted hours. In just over a year, Coffee s series of frauds increased his earning by 23,916. When interviewed under caution he strenuously denied having been dishonest, but was unable to offer a reason for the fact that he had entered each patient s x-ray record twice - once before 5:00pm, and once after. Coffee, who is awaiting sentence, has already repaid the full amount due to the NHS.

12 Page 6 ABERTAWE BRO MORGANNWG UNIVERSITY HEALTH BOARD HAVE YOU AND YOUR TEAM HAD A FRAUD AWARENESS PRESENTATION? A big part of the Local Counter Fraud Specialist s job involves creating and embedding a real anti-fraud culture within the organisation. Key to this is ensuring that all staff are made aware of the risks posed to the NHS by fraud, and the important role they play in helping to combat it. The Team is always available to come along and deliver fraud awareness presentations anywhere in the Health Board area, and are able to be flexible in accommodating the needs and time constraints of you and your staff. The content of the presentations can also be tailored to specific audiences as required. If you would like to arrange a fraud awareness presentation for your Department, please contact the Team who will be more than happy to help. CONCERNED ABOUT FRAUD? CONTACT US! If you have any suspicions or concerns about possible fraud, bribery or corruption in the NHS we want to hear from you. The Health Board s Local Counter Fraud Specialists can be contacted in a number of ways. You can telephone or us as follows: GWENT NURSE FORGED DRUG PRESCRIPTIONS Name Telephone Len Cozens len.cozens@wales.nhs.uk A Trainee Dental Nurse has pleaded guilty to forging prescriptions and Zoë stealing Whetton from pharmacies in zoe.whetton@wales.nhs.uk order to feed her own drug addiction, following a joint investigation undertaken by NHS Counter Fraud Rhiannon Specialists Evans and South Wales rhiannon.evans2@wales.nhs.uk Police. The Trainee Nurse stole a total of 23 prescription forms from her You can also write to us at: Counter Fraud Services ABMU Health Board Floor 7, Oldway Centre 36 Orchard Street Swansea SA1 5AW You can also contact The National Fraud & Corruption Reporting Line on or on-line at All calls will be treated in the strictest confidence.

13 APPENDIX 3 LCFS INVESTIGATIVE CASELOAD SUMMARY REPORT Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/11/00023 Feb Alleged falsification of Fit to Work certificates. 2. Alleged fraudulent the use of a work colleague s credit card details (Police Enquiry). The subject appeared before Swansea Crown Court in September 2012 and pleaded guilty to 7 counts of Forgery and 11 counts of Fraud, was sentenced to 6 months imprisonment suspended for 12 months and a supervision requirement for 12 months. Agreement has now also been reached on a civil recovery, and monthly payments are being received by the Health Board. WARO/12/00129 Dec 2012 misleading information in respect of claims for childcare allowance payments related to the NHS Wales Bursary. The subject appeared before Bridgend Magistrates and pleaded guilty to 5 charges of Fraud by False Representation. She was sentenced to 120 hours unpaid work and ordered to pay a total of 4, in compensation and costs. At a subsequent hearing, the Fitness to Practice Committee at Cardiff University found that the subject s conduct had breached both the University s Fitness to Practice Procedure and the Nursing and Midwifery Council Code. As a result, her programme of study was terminated with immediate effect. All compensation due to the Health Board has now been received in full, with the final payment being made in September. The case is now closed. 7

14 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/13/00116 Oct 2013 Alleged theft of a salary overpayment. Following enquiries, it was felt that there was insufficient evidence available of the standard required for criminal proceedings. Following significant delays resulting from issues encountered in obtaining the cooperation of the subject s current employer, an attachment of earnings was successfully applied, and payments have been received by the Health Board on a monthly basis. It has been confirmed that all monies due to the Health Board have now been recovered in full, and a preliminary closure report is being drafted for review by the Acting Director of Finance. WARO/13/00117 Oct 2013 misleading information in respect of claims for payment for the dispensing of prescribed medication. As a result of enquiries made, the subject was interviewed under caution. However following the pursuit of further additional lines of enquiry, it was felt that there was insufficient evidence available of the standard required for criminal proceedings. The above notwithstanding, the investigation highlighted a number of inappropriate payments which, following further discussions with the subject and their legal representative, have now been recovered in full. A separate investigation into the subject s conduct, incorporating the findings of the LCFS review, has now been commenced by the General Pharmaceutical Council. The LCFS continue to provide support to that process. 8

15 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/14/00026 Feb 2014 Allegations or theft and fraud relating to inappropriately accessed patient funds and petty cash. The subject appeared before Cardiff Crown Court on 24 th October, and pleaded guilty to seven counts of fraud by abuse of position, one count of false accounting, and one count of theft. On 2 nd December before the same Court, she was sentenced to 21 months imprisonment for each of the fraud and false accounting charges, and 9 months imprisonment for the theft charge, with all sentences to run concurrently. In addition, the Judge made a compensation order in favour of ABMU Health Board to the value of 21, Payment has now been received in full. A preliminary closure report has been prepared and forwarded to the Acting Director of Finance for review and comment. WARO/14/00053 April 2014 misleading information in respect of claims for the provision of dental services (Units of Dental Activity). Enquires are on-going WARO/14/00064 WARO/14/00101 May 2014 July 2014 misleading information in respect of claims for the provision of dental services (Units of Dental Activity). misleading information in respect of claims for the provision of dental services (Units of Dental Activity). Enquires are on-going. Enquires are on-going. 9

16 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/14/00135 NOV 2014 misleading information relating to the completion of attendance and time keeping records. Following enquiries, it was felt that there was insufficient evidence available of the standard required for criminal proceedings. This matter has now been passed back to the Delivery Unit for consideration under the Disciplinary Policy and Procedure. The LCFS continue to provide support to that process. WARO/15/00001 JAN As a result of enquiries made, the subject was interviewed under caution. However following the pursuit of further additional lines of enquiry, it was felt that there was insufficient evidence available of the required standard to progress either criminal or disciplinary action in respect of this matter. The case has therefore been closed. WARO/15/00003 JAN Alleged submission of a false or misleading reference document in support of a job application. As a result of enquiries made, the subject was interviewed under caution and made a full admission. A decision report was received from the Crown Prosecution Service, which concluded that that this matter is suitable for disposal via the administering of a Police Caution. To that end, case files have been prepared and submitted to South Wales Police, and confirmation of the outcome is awaited. WARO/15/00014 FEB misleading information relating to the completion of attendance and time keeping records, and travel claims. In addition to the allegations originally received, the LCFS investigation highlighted further concerns in respect of the subject s failure to declare his second employment. However following the pursuit of several lines of enquiry, it was felt that there was insufficient evidence available of the standard required for criminal proceedings. The matter was passed back to the Delivery Unit for consideration under the Disciplinary Policy and Procedure, as a result of which the subject has received a first written warning. The case has now been closed. 10

17 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/15/00020 FEB As a result of enquiries made, the subject was interviewed under caution. However following the pursuit of further additional lines of enquiry, it was felt that there was insufficient evidence available of the standard required for criminal proceedings. The subject resigned from her post during the course of the investigation, meaning that action under the Disciplinary Policy and Procedure was not an option in this case. A closure report is currently being prepared for review by the Interim Director of Finance. WARO/15/00024 MARCH Alleged falsification of records and theft of medication. Enquires are on-going WARO/15/00029 MARCH Alleged theft of a salary overpayment. Following enquiries, it was felt that there was insufficient evidence available of the required standard to progress either criminal or disciplinary action in respect of this matter. Agreement has been reached on the recovery of all losses, and the case has been closed. WARO/15/00033 APRIL misleading information relating to the completion of attendance and time keeping records Enquires are on-going WARO/15/00042 MAY misleading information in respect of claims for the provision of dental services (Units of Dental Activity). Enquires are on-going WARO/15/00056 JUNE Following enquiries, it was felt that there was insufficient evidence available of the required standard to progress either criminal or disciplinary action in respect of this matter. The case has now been closed. 11

18 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/15/00065 JULY Alleged theft of a salary overpayment. As a result of enquiries made, the subject has been interviewed under caution. Authority to prosecute has been signed by the Director of Finance, and a case file has been passed to the Crown Prosecution Service (CPS) for consideration. The CPS requested that further evidence be sought relating to the subject s bank records. These have now been obtained and forwarded to the CPS, and a charging decision is awaited. WARO/15/00067 JULY Following enquiries, it was felt that there was insufficient evidence available of the required standard to progress either criminal or disciplinary action in respect of this matter. This case has now been closed. WARO/15/00077 JULY misleading information relating to the completion of attendance and time keeping records Following an interview under caution, authority to prosecute was signed by the Director of Finance, and a case file was forwarded to the Crown Prosecution Service (CPS) for consideration. The decision returned was that in this particular instance, it was felt that there was insufficient evidence of the required standard for there to be a realistic prospect of a conviction. This matter has now been passed back to the Delivery Unit for consideration under the Disciplinary Policy and Procedure. WARO/15/00081 AUG misleading information relating to the completion of attendance and time keeping records Following initial enquiries, it was felt that there was insufficient evidence available of the required standard to progress criminal action in respect of this matter. The matter was passed back to the Delivery Unit for consideration under the Disciplinary Policy and Procedure, as a result of which the subject has received a verbal warning. The case has now been closed. WARO/15/00091 SEPT Alleged failure to disclose information in respect of private business interests. Enquires are on-going 12

19 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/15/00101 SEPT Alleged fraudulent amendment of entries made on a FP10 Prescription Form by a member of the public. A case file was passed to the Crown Prosecution Service for consideration. However it was felt that there was insufficient evidence available of the required standard to progress criminal action in respect of this matter. The case has therefore been closed. WARO/15/00126 DEC misleading information in respect of claims for payment for the dispensing of prescribed medication. Enquiries have been concluded, and no evidence of fraud against ABMU Health Board or the wider NHS has been found. The findings of the LCFS investigation were brought to the attention of the General Pharmaceutical Council, who advised that there were no matters arising which warranted further action. The case has now been closed. WARO/15/00128 DEC misleading information relating to the completion of attendance and time keeping records Enquiries have been concluded, and no evidence of fraud against ABMU Health Board or the wider NHS has been found. The case has therefore been closed. WARO/16/00001 JAN misleading information in respect of claims for reimbursement under the Healthcare Travel Costs Scheme. Enquires are on-going WARO/16/00003 JAN Enquiries have been concluded, and no evidence of fraud against ABMU Health Board or the wider NHS has been found. The case has therefore been closed. WARO/16/00014 MARCH misleading information in order to obtain inappropriate access to free NHS care. Enquires are on-going 13

20 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/16/00015 MARCH Enquiries have been concluded, and no evidence of fraud against ABMU Health Board or the wider NHS has been found. The case has therefore been closed. WARO/16/00031 APRIL Alleged theft of a salary overpayment. Following initial enquiries, it was felt that there was insufficient evidence available of the required standard to progress criminal action in respect of this matter. Agreement has been reached on the recovery of all losses. WARO/16/00032 APRIL misleading information relating to the submission of Statement of Fitness to Work forms. Enquiries are on-going WARO/16/00033 APRIL misleading information relating to the completion of attendance and time keeping records Enquiries have been concluded, and no evidence of fraud against ABMU Health Board or the wider NHS has been found. The case has therefore been closed. WARO/16/00034 APRIL Enquiries are on-going WARO/16/00035 APRIL misleading information in order to obtain inappropriate access to free NHS care. Enquiries are on-going WARO/16/00036 APRIL misleading information in order to obtain inappropriate access to free NHS care. Enquiries are on-going 14

21 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/16/00042 APRIL misleading information in order to obtain inappropriate access to free NHS care. Enquiries are on-going WARO/16/00048 MAY Alleged fraudulent amendment of entries made on a FP10 Prescription Form. Following enquiries, it was felt that there was insufficient evidence available of the required standard to progress criminal action in respect of this matter. The case has therefore been closed. WARO/16/00069 JULY Alleged to be undertaking private work during NHS time. Enquiries have been concluded, and no evidence of fraud against ABMU Health Board or the wider NHS has been found. The case has therefore been closed. WARO/16/00075 JULY misleading information in order to obtain inappropriate access to free NHS care. Enquiries are on-going WARO/16/00080 AUG Alleged theft of a salary overpayment. Enquiries are on-going. WARO/16/00087 AUG Alleged theft of a salary overpayment. Enquiries are on-going. WARO/16/00088 AUG Enquiries have been concluded, and no evidence of fraud against ABMU Health Board or the wider NHS has been found. A preliminary closure report has been prepared and forwarded to the Acting Director of Finance for review and comment. WARO/16/00092 SEPT Alleged to be undertaking private work during NHS time. Enquiries are on-going. 15

22 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/16/00094 SEPT Enquiries are on-going. WARO/16/00097 SEPT Alleged abuse of time and attendance systems. Enquiries are on-going. WARO/16/00101 SEPT Enquiries have been concluded, and no evidence of fraud against ABMU Health Board or the wider NHS has been found. The case has therefore been closed. WARO/16/00110 OCT misleading information in respect of claims for payment for the dispensing of prescribed medication. Enquiries are on-going. WARO/16/00112 OCT Alleged to be undertaking private work during NHS time. Enquiries are on-going. WARO/16/00113 OCT Enquiries are on-going. WARO/16/00126 NOV Enquiries are on-going. WARO/17/00002 JAN 2017 Alleged failure to declare a financial interest in a company providing goods and/or services to the Health Board and wider NHS. Enquiries are on-going. 16

23 Case Reference No. Date Case Opened Detail of Allegation Status Closure Report Submitted Prelim Final WARO/17/00010 JAN 2017 misleading information relating to the completion of attendance and time keeping records. Enquiries are on-going WARO/17/00012 FEB 2017 Alleged failure to declare a financial interest in a company providing goods and/or services to the Health Board and wider NHS. Enquiries are on-going WARO/17/00014 FEB 2017 Enquiries are on-going 17