Anti-Fraud Staff Survey NHS Clinical Commissioning Groups. A comparative review of staff survey results

Transcription

1 Anti-Fraud Staff Survey NHS Clinical Commissioning Groups A comparative review of staff survey results

2 The overall purpose of the insight is to enable individual organisations to consider how they compare with others in respect of their staff survey results for anti-fraud. 1. Context A key element of the national anti-fraud strategy is to create an anti-fraud culture, and evaluate the success of the activity undertaken. This is often achieved through assessing, by means of an electronic survey, the level of fraud awareness amongst staff and key stakeholders. In accordance with this requirement to evaluate the effectiveness of the activity undertaken, the survey is considered an important assessment tool to demonstrate both improvement in awareness and an embeddedness of an anti-fraud culture over a period of time. TOP 10 METHODS OF As the undertaking of such surveys is a recurring NHS RAISING AWARENESS OF Protect best practice recommendation, the following processes have been applied by the Anti-Fraud Specialist FRAUD [AFS]. 1. Mandatory Training In April 2017, MIAA AFS s disseminated an anti-fraud staff 2. from AFS survey link to 24 NHS Clinical Commissioning Groups across 3. Awareness Presentation or Event 4. Local Anti-Fraud, Bribery and Merseyside, Lancashire, Cheshire and Manchester regions. Corruption Warnings and Alerts This report sets out the findings from those surveys and 5. CCG Anti-Fraud, Bribery and provides a comparative view of those results for the sixteen Corruption Policy of the twenty four CCGs who provided responses to their 6. MIAA Anti-Fraud Newsletter 'The respective AFS. Sentinel' CCGs are required to take all necessary steps to counter 7. Posters / Leaflets 8. Information on the Intranet / fraud, bribery and corruption. The aim of the survey was to Sharepoint establish a more representative view of anti-fraud 9. E-Learning awareness across a number of CCGs. 10. Payslip Message 2. Key Responses Of the sixteen CCG surveys returned, 609 responses were received from a total of 1,545 staff (39%) who received the survey. Regionally the response rates vary; Lancashire 19%; Manchester 51%; Merseyside 61%; and Cheshire 5%

3 3. Awareness of the Anti-Fraud Specialist The opening questions of the fraud survey gauged staff awareness of their AFS. Figure 1 (below) illustrates the level of awareness and knowledge of the designated AFS across the respective CCGs in a comparative view and from an average regional perspective (Figure 2) % CCG YES NO Figure 1 Awareness of the Anti-Fraud Specialist YES [%] NO [%] 20 0 Cheshire Lancashire Merseyside Manchester Figure 2 Regional awareness of the Anti-Fraud Specialist (average) Q: Does your organisation ensure that anti-fraud awareness activity is set at an appropriate level to ensure sufficient coverage of your staff?

4 4. Awareness of NHS Anti-Fraud work across the CCG Gauging the success of the various activities undertaken by the AFS and others to enhance anti-fraud awareness at the CCGs is an important aspect of the annual survey. Figure 3 (below) outlines the average regional comparative layout for awareness of the various activities undertaken in order to raise fraud awareness across the CCGs. Other I haven't seen or received any anti-fraud, bribery or corruption awareness information Anti-Bribery Workshop / Information (Bribery Act 2010) CCG Anti-Fraud, Bribery and Corruption Policy Payslip Message Information Categories E-Learning Information on the Intranet / Sharepoint Posters / Leaflets Local Anti-Fraud, Bribery and Corruption Warnings and Alerts MIAA Anti-Fraud Newsletter 'The Sentinel' Awareness Presentation or Event Mandatory Training % Average Manchester Merseyside Lancashire Cheshire Figure 3 Methods of raising awareness across the CCG regions

5 Mandatory training (or equivalent) has proven to be a continued successful method of raising fraud awareness amongst staff members supported by additional bespoke fraud awareness and/or events. Enhancing the profile of the AFS across each organisation is essential for ensuring the continued improvement of fraud awareness and staff member s knowledge of the AFS role and contact details. There are now only a very small number of respondents stating that they have not received or seen fraud awareness information. Figure 4 Not received or seen fraud awareness 5. Awareness of CCG s Gifts and Hospitality and Conflict of Interest arrangements The key to having an embedded anti-fraud culture is to ensure that the CCG has key policies and procedures in place. Having strong governance arrangements in respect of Code of Conduct, declaring Conflicts of Interests and Gifts and Hospitality is an essential component and should provide transparency in respect of an individual s compliance with, NHS England guidance, the Bribery Act and Nolan s Principles of Public Life. All staff working within the NHS have a responsibility to identify and manage conflicts of interest and to declare and register gifts, hospitality and sponsorship. Having well-managed and regularly maintained policies helps ensure that there is an organisational culture of transparency and openness. One of the key areas of focus for an AFS is to ensure that staff are aware of the CCGs procedure and policies in respect of gifts and hospitality and conflict of interest arrangements; and that these are readily available and up to date. Figure 5 (below) demonstrates the CCG s surveyed staff s awareness of the location of policies;

6 % CCG YES NO DON T KNOW Figure 5 Awareness of Policies & Procedures 100% of staff within Cheshire and Lancashire regions knew what a Conflict of Interest was Lancashire region (4 CCGs) on average was the highest region with 76% of staff having received training and instruction in relation to the acceptable provision or acceptance of Gifts and Hospitality In respect of staff having received any training or instruction in relation to Declaration of Interests at the CCG; Cheshire region (100%); Lancashire region (91%); Liverpool region (80%); and Manchester region (69%) Liverpool region (6 CCGs) and Manchester region (4 CCGs) on average 88% of their respondents knew who to contact if they had a concern of a potential Conflict of Interest at the CCG

7 Gifts and Hospitality Whilst there is a varied nature to the offers being declared on the CCG s Gifts, Hospitality and Sponsorship Registers, overall staff responding to the survey demonstrated a basic understating as to the types of gifts and hospitality which require declarations in accordance with CCG policies and procedures (Figure 6 below). Site visits to prospective suppliers of goods and services where hospitality, gifts or benefits are provided or loaned National and international conferences/seminars where accommodation and travel has been paid for by the company organising the event or any other company Events where the cost of accommodation is paid by the Suppliers or potential Suppliers to the CCG Gifts or loans of equipment by Medical/Drug companies CCG's policy for acceptance Payment by business contacts to pay for social events (such as Christmas parties) Goods or services provided by a business contact for personal benefit at reduced cost Tickets for a sporting event from an external supplier Lecture trips National/International Conventional personal gifts - such as flowers Low value 'promotional' gifts inscribed with the provider's name Manchester Merseyside Lancashire Cheshire % Average Figure 6 Awareness of Types of Gifts & Hospitality Q: Do your registers of Gifts and Hospitality reflect all staff groups within your organisation? Is there a need for further awareness of the requirements?

8 Conflicts of Interest Personal interests and potential conflicts of interest may come about through any number of routes within the CCG. One element of the Anti-Fraud staff survey was to identify respondents awareness of such potential interests. Figure 7 (below) provides an overview of CCG staff general responsiveness to typical types of interests which may give rise to potential conflicts. Any other employment you have or may undertake Acceptance of gifts and hospitality from current or prospective business contracts Categories Ownership or part-ownership of private companies, businesses or consultancies likely or possibly seeking to do business with the NHS organisation Directorships, including non-executive directorships or memberships, held in private companies/plcs/gp Federations etc Decisions affecting individuals who share the interests of organisation staff i.e. family members Financial interests in the public and private sector % Average Manchester Merseyside Lancashire Cheshire Figure 7 Personal Interest and Potential Conflict of Interests Overall each region indicated good knowledge and awareness of the potential interests; with Lancashire and Cheshire demonstrating 100% in most areas. Across the Merseyside region awareness needs to be enhanced which may develop through the mandatory NHS England proposed e-learning training, as this guidance is introduced. CCG s will need to ensure that there are mechanisms in place to continue to measure this awareness and where gaps are identified, focus these elements in conjunction with their AFS as part of their ongoing awareness and training activities. Q: Does your CCG have in place mechanisms for the management of conflicts within meetings, when making procurement decisions and in relation to contract management? Is there an adequate training programme in place with CCG staff advising them of these requirements?

9 6. Reporting concerns relating to Fraud, Bribery and Corruption The guidance from NHS Protect has been for all fraud concerns to be reported to the Chief Finance Officer and/or AFS and that remains the main focus of the AFS presentation material. This is reinforced and supported via the CCG s Anti-Fraud, Bribery and Corruption Policy. Figure 8 (below) provides a regional overview of the official reporting channels for reporting fraud, bribery and corruption and Figure 9 outlines CCG staff initial responses to If you had a suspicion that fraud, bribery or corruption was happening at work, do you think that you would report your concerns? None of the below CCG Whistleblowing Policy / raising concerns arrangements CCG Chief Finance Officer NHS Protect online reporting form NHS Protect National Fraud and Corruption Reporting Line: Anti-Fraud Specialist (AFS) Manchester Merseyside Lancashire Cheshire Figure 8 Awareness of Reporting Channels

10 Across all regions CCG staff have a knowledge of the official reporting channels namely direct reporting to the AFS and their ability to raise concerns through the CCG s Whistleblowing (or equivalent) policy. This still leaves a small minority who still have no awareness of how or whom to report their concerns to and a lower number of respondents recognising the national reporting phone line or on-line form. Encouraging staff to report any concerns or suspicions has been a key focal point for the AFS s who have worked with their CCGs to foster an open and transparent culture where staff are encouraged to raise concerns and feel supported. Figure 9 (below) identifies the regional numbers of CCG staff who feel if they had a suspicion that fraud, bribery or corruption was happening at work, they would report it. Lancashire region was the highest with 97% average followed closely by Merseyside with a strong 92%. There were a number of not sure responses to this question. The Anti-Fraud survey sought to understand how CCG staff perceive whistleblowing and reporting of their potential concerns or suspicions of occurrences of suspected fraud and why they may be not sure about reporting these concerns. YES NO NOT SURE Figure 9 Regional Reporting Fraud Profile The survey asked CCG staff to identify which of the following they thought may prevent them from reporting suspicions of fraud, bribery or corruption; Fear of repercussions Fear of raising concerns Lack of confidence in the process

11 Not sure my concerns are fraud, bribery or corruption related Lack of evidence to support suspicions Close relationship with the individual/s Sympathy for the individual/s Do not know who to report suspicions to Other When reviewed (in conjunction with the results identified in Figure 9) the responses as outlined in Figure 10 would suggest that is no easy single conclusion as to why individuals may not report their concerns. Regionally, 97% of Lancashire respondents stated they would report concerns; however 66% of the same respondents then stated they would not report their concerns due to lack of evidence to support suspicions and 45% fear the repercussions. Within the Manchester region only 65% would report their concerns, with 31% of respondents unclear as whether their concerns are fraud, bribery or corruption related. This may be reflective of the 18% and 10% of respondents having no knowledge of their AFS and having no sight of anti-fraud materials (Figure 1 and Figure 2). Other Do not know who to report suspicions to Sympathy for the individual/s Close relationship with the individual/s Categories Lack of evidence to support suspicions Not sure my concerns are fraud, bribery or corruption related Lack of confidence in the process Fear of raising concerns Fear of repercussions % Average Manchester Liverpool Lancashire Cheshire Figure 10 Regional Reasons for not reporting concerns

12 7. Conclusion When considering the anti-fraud survey results it is important to consider that the overall responses provide a generally positive view on the awareness and impact of the anti-fraud activity at the CCGs and across the regions. There are always areas for improvement in raising the overall levels of awareness amongst staff however positive messages are evidenced through the responses provided to this survey. Mandatory training, awareness presentations, information alerts and information received directly from the local AFS, are recognised as having the most visibility and impact with staff. Across the regions CCG staff were aware of the role of the AFS and had sight of the CCG Anti- Fraud, Bribery and Corruption Policy (Cheshire 43%; Lancashire 47%; Merseyside 43%; and Manchester 29%). Whilst these figures are not particularly high it may reflect people s reluctance to read policies unless they have a specific need to do so. The responses given as to the reasons for potentially not raising concerns need to be addressed. There has been a lot of attention placed nationally on the importance of raising concerns and the protections that are in place for those who do. The AFS and others within the CCGs have a responsibility to ensure that these messages are reinforced at a local level. In response to the two most frequent options chosen by the respondents it is ultimately the responsibility of the AFS not the referrer to conduct the fraud investigation and gather whatever evidence is available. Secondly all CCGs are committed to an open, transparent culture where any victimisation of those raising concerns will not be tolerated. These messages will continue be reinforced going forward through AFS awareness activity. The overall conclusion of this year s CCGs anti-fraud survey is that anti-fraud arrangements delivered by the AFS are generally effective and assist in supporting a commitment, which is shared by staff, to enhance an embedded anti-fraud culture. The report has highlighted some regional variances in response to certain questions which require further analysis by the respective nominated AFSs and CFOs. Primarily this will be to establish the reasons for certain responses and to decide whether any targeted awareness work is required locally to address these matters. The overall purpose of awareness activity is to support an open, transparent and learning culture within CCGs in relation to the raising of concerns.

13 The Insight provides information to enable individual organisations to consider how they compare with others in respect of their anti-fraud staff survey results. It is intended to prompt and inform discussions on this important aspect of the anti-fraud programme. 1. Does your organisation ensure that anti-fraud awareness activity is at the appropriate level for CCG staff? 2. Does your Gifts and Hospitality policy reflect all staff groups within your organisation? Is there a need for further awareness of the requirements? 3. Does your CCG have in place mechanisms for the management of conflicts within meetings, when making procurement decisions and in relation to contract managements? Is there an adequate training programme in place with CCG staff advising them of these requirements? We would be keen to hear your views on the issues raised and your ideas on how further benchmarking in this or other areas would be of benefit. For more information or to request a benchmarking topic please speak to your Anti-Fraud Specialist or contact: Louise Cobain, Assistant Director r&d@miaa.nhs.uk