Fraud and bribery in the NHS

Anti-Fraud, Bribery and Corruption, Money Laundering and Economic Crimes Statement

NHS Surrey and Sussex ICB is committed to implementing and enforcing effective systems to eliminate fraud, bribery and corruption, money laundering and other economic crimes within the NHS to protect public resources for health and care. 

Fraud

Fraud is an act of deception that is intended to make a financial gain or to cause a loss to another party.

Under the Failure to Prevent Fraud offence which came into force on 1 September 2025, an organisation will be criminally liable where a fraud offence is committed by an employee, agent, or other ‘associated’ person, with the intention of deriving a benefit for the organisation or a related body; and, the organisation did not have ‘reasonable’ fraud prevention procedures in place. It does not need to be shown that managers ordered or knew about the fraud. The ICB falls within the scope of the offence as a large organisation.

The ICB has worked with its counter fraud provider to ensure that reasonable fraud prevention procedures are in place in line with the government guidance that outlines six key principles.

Bribery

Bribery is generally defined as the giving or receiving of a financial or other advantage in exchange for improperly performing a relevant function or activity.

To minimise the risk of unfounded allegations of bribery or corruption, if staff are offered hospitality or gifts or are considering offering any to another person, they should refer to the Conflicts of Interest Policy. This provides details of the circumstances in which this would be acceptable and the level which can be given or received. Staff are reminded all hospitality and gifts received, offered or declined should be declared using the form accessible from the policy.

Money laundering

Money laundering is defined as the process by which the proceeds of crime are converted into assets that appear to have a legitimate origin, allowing them to be retained or recycled into further criminal enterprises.

The ICB has a zero-tolerance approach to fraud, bribery and corruption, money laundering and other economic crimes which extends beyond internal fraud and includes commissioning, contracting, procurement and supplier-related risks. The ICB is committed to applying the highest standards of ethical conduct and behaviour, as well as having robust controls in place to prevent these. As well as staff, the ICB also expects its suppliers and contractors and any associated persons to adhere to the same high standards. 

Our dedicated policies and procedures set out our expectations and guidance for staff, contractors and anyone else working with or for the ICB with regards to preventing fraud, bribery and corruption, money laundering and other economic crimes and raising concerns. 

We ask all who have dealings with the ICB, as employees, agency staff, trading partners (contractors/suppliers), stakeholders and patients, to help us in our fight against fraud, bribery and corruption and to contact us immediately if any concerns arise. No individual will suffer any detrimental treatment as a result of reporting reasonably held suspicions. The success of the ICB’s anti-fraud, bribery and corruption measures depends on everyone playing their part.

Contact

The ICB contracts TIAA Ltd to provide its counter fraud service and you can contact our Counter Fraud Specialist, Leanne Burns, Anti-Crime Specialist in confidence:

All genuine suspicions of fraud, bribery or corruption can also be reported in confidence to the NHS Fraud and Corruption Reporting Line on free phone 0800 028 40 60 or at: cfa.nhs.uk/reportfraud

Clare Stafford

Chief Finance Officer

 

What is fraud?

Fraud happens when someone makes a deliberate attempt to dishonestly make a gain for themselves or another or cause a loss to another.

This may include any person who makes a false  representation or dishonestly fails to disclose to another person information which they are under a legal duty to disclose, or commits fraud by abuse of position, including any offence as defined in the Fraud Act 2006. Examples of NHS fraud offences are provided below. Further information can be found in our Fraud, Bribery and Corruption Policy (CORP06).

Bribery refers to the giving or receiving of an inducement, in return for a person committing an improper function. It is an offence to give or receive a bribe, or even offer or accept, even if the briber is never paid. A bribe is any inducement, financial or not, to encourage or reward someone to do something they should not do.

What does NHS fraud look like?

  • By health professionals: Fraud by NHS professionals includes claiming for treatment or services not provided (e.g. Medicines Use Reviews at pharmacies, dental treatment or optical services not carried out) and working elsewhere while on sick leave.
  • By managers and staff: Fraud by NHS managers and staff includes submitting fraudulent claims for grants and payments (e.g. false or inflated travel or subsistence claims, and fraudulent applications for funding and training).
  • By contractors and suppliers: Contractor and supplier fraud includes charging for items of a higher quality or greater quantity than those supplied and using inappropriate tendering processes.
  • By patients: Patient fraud includes claiming for free or reduced cost treatment and services when not entitled and using aliases to get prescription drugs.

Reporting fraud

The first steps are being aware of the risk and remaining vigilant. You should also know how to report any suspicions or concerns you may have about fraud and/or bribery.

You can report fraud against the NHS in England and Wales by using the NHS Counter Fraud Authority online reporting form or calling freephone line 0800 028 4060 (available 24/7).

Visit the NHS Counter Fraud Authority website for more information and examples of recent cases.