Counter-Fraud Benchmarking Club 2014

Transcription

1 Counter-Fraud Benchmarking Club 214 Welcome to the CIPFA Counter-Fraud Benchmarking exercise 214 The aim of the exercise is to support public sector managers involved in managing counter-fraud and running investigations teams by enabling them to share good practice, information about each other's structures and their experiences. For the purpose of this exercise a broad definition of counter-fraud should be taken encompassing all activities related to investigation and prevention of potential criminal activity. For example, investigations into both theft and bribery should be included. Links to specific guidance - throughout the questionnaire there are white question marks to the right of the question number, these are hyperlinks to specific guidance notes below. Several organisations have taken part in helping develop this second year of the questionnaire and CIPFA would like to thank the members of the London Public Sector Counter Fraud Partnership and CIPFA's Better Governance Forum who made this exercise possible. Comments Please use these boxes to record any difficulties you have in completing the questionnaire or other general points about your service that you feel would be of interest to other members. Please do not use these cells to update contact information or ask any questions that require a quick response. any such amendments/queries to us at benchmarking@cipfa.org. Counter-Fraud Page 1 of 18 Copyright CIPFA 214

2 1. Organisational Background (Including Housing Benefits/CTRS investigations) (a) Size of organisation 31/3/214 Number of staff (Full Time Equivalents) directly employed by your organisation 213/14 Organisation gross revenue expenditure Organisation gross revenue income FTE 'k (b) Location Are you an international, national, regional or local organisation? Is the area in which you work predominately rural, urban or mixed? Is Counter-Fraud work being done as part of a shared service arrangement? 2. SERVICE DELIVERY Service Structure Please read the guidance notes on this section. (a) IN-HOUSE delivery (b) OUTSOURCED to a Shared Service Arrangement (SSA) (c) (with other LA's and/or with other public sector organisations) Name(s) of SSA partner(s)? OUTSOURCED to an External Contractor (Inc. legal entities partly/wholly owned by your organisation) Name(s) of External Contractor(s)? Total % Delivered should equal 1% To what extent is your Counter-Fraud function outsourced during the period being benchmarked and what percentage of the function was delivered by each method? % Delivered % Delivered % Delivered % Delivered? (d) Comments regarding your service delivery Counter-Fraud Page 2 of 18 Copyright CIPFA 214

3 3. Structure of Counter-Fraud Function(s) (Including Housing Benefits/CTRS investigations) (a) Structure / Teams involved in investigating potential criminal activity? Please include all teams that investigate potential criminal activity. Centralised teams: Does your organisation have a centralised investigations / counter-fraud team that: Co-ordinates investigations / counter-fraud activities across the organisation Undertakes the majority of investigations If you have a centralised investigations / counter-fraud team, is it a stand alone team? (Answer no if it is part of another section, e.g. Internal Audit) If you have a centralised investigations / counter-fraud team, please describe who it reports to. Specialist teams: Do the organisation's internal auditors carry out investigations? How many teams/sections undertake investigations work? (Enter 1 if you only have a single centralised function) If multiple teams undertake investigations, briefly describe how responsibilities are split between teams. (b) Joint working between Counter-Fraud Teams If more than one team has responsibility for investigations, how do you ensure joint working and liaison between different teams? SLA or protocols Regular meetings between investigators Fraud panel (or similar) As appropriate on a case-by-case basis Risk management processes Other (please specify)* Not applicable *Details of other Counter-Fraud Page 3 of 18 Copyright CIPFA 214

4 4. Resourcing of counter-fraud function(s) (Excluding Housing Benefits/CTRS investigations) (a) Size and direct cost of Counter-Fraud/Investigation Functions? 213/14 - Best Estimate STAFF NUMBERS FTE How many people are employed in investigation work across your organisation? Of which, how much time (FTE) is spent on supervision. STAFF COSTS Please give your best estimate of staff costs (see guidance sheet for definitions). 'k Employee staff costs (including agency staff) Bought-in staff costs (e.g. specialists) Total Staff Costs. k INCOME Income for work for other bodies/third sector organisations Other Income, e.g. government grants STAFF COSTS MINUS INCOME. k (b) Estimation of Available Days for Counter-Fraud/Investigations work? 213/14 - Best Estimate Days Total number of 261 weekdays in 213/14 - Annual 25. days per FTE, per annum - Bank 7. bank holidays per FTE - 5. days per FTE, per annum - days per FTE, per annum - Other days per FTE, per annum = Work days from Counter-Fraud/Investigations Staff - Time spent on non-counter-fraud/investigations work (See part d) + Bought-in days (e.g. specialists) = Days spent on Counter-Fraud/Investigations Work - Time spent on Counter-Fraud work for other bodies/third sector organisations (To match the income for other bodies/organisations collected above) = Available days for Counter-Fraud/Investigations Work for your organisation (c) Estimated Breakdown of Counter-Fraud/Investigations Time? 213/14 - Best Estimate What is the split of the counter-fraud functions' time (days) between different types of work? If you cannot estimate this information in days, please give approximate percentage split and the days will calculate. Prevention Detection Investigation Other (including management & strategic/corporate work) Total 1% % Days Should match total available days from 4(b) Counter-Fraud Page 4 of 18 Copyright CIPFA 214

5 (d) Time spent on non-counter-fraud/investigations Work If the investigation team(s) included in 4(b) carry out non-fraud investigation work, please list the 5 main areas (e) Resourcing Decisions Should match from 4(b) How did you calculate the resources that your organisation needs for counter-fraud work for 214/15? Assessing previous year's caseload Using current caseloads External targets/comparisons Manage within given resources Assessment of your fraud risk exposure Other (please specify)* *Details of other Days Counter-Fraud Page 5 of 18 Copyright CIPFA 214

6 5. Staffing (Including Housing Benefits/CTRS investigations) (a) Pay-band? 31/3/214 What is the pay structure of the staff numbers given in 3(a) (Please see guidance for how to treat part time members of staff.) < 2, 2, - 3, 3, - 4, 4, - 5, 5, - 6, 6, - 7, 7, - 8, > 8, Total Staff (b) Qualifications 31/3/214 How many of the staff have Counter-Fraud related qualifications? Please show the highest qualification held. Professionalism in Security (PinS) Certificate in Investigative Practice (CIIP) Fraud Diploma Other Fraud Specialist qualifications Degree in Counter-Fraud Certified Counter-Fraud Specialist Accredited Counter-Fraud Specialist BTEC No qualifications Total Staff with Fraud Qualification Should match figures from 5(a) If other fraud specialist qualifications please specify: How many staff were currently undergoing training for Counter-Fraud related qualifications at 31/3/214? Total Staff no. FTE. FTE Staff no. FTE. FTE. FTE Counter-Fraud Page 6 of 18 Copyright CIPFA 214

7 (c) Secondments Do you have seconded in staff within the investigations team? Have you included staff FTE and costs for seconded in staff at 4(a)? Please describe your use of seconded staff: Do you second staff out of the investigations team? Have you excluded FTE and costs for seconded out staff at 4(a)? Please describe: 6. Sources of Investigation (Excluding Housing Benefits/CTRS investigations) (a) Initial Contacts 213/14 What was the source of your initial contacts with regards to potential frauds? Members of the public Internal referrals NFI Other bodies (e.g. Government, Police) Total (b) Management of Fraud 'Hotlines' For each question please select the option that best fits your standard arrangements: When a caller calls the hotline will they: Are your hotlines: Do you use any other reporting methods? Text Online Number? Counter-Fraud Page 7 of 18 Copyright CIPFA 214

8 7. Investigations & Prosecutions/Sanctions (Excluding Housing Benefits/CTRS investigations) (a) Actions? 213/14 How many investigations did your counter-fraud team(s) work on last year (by type)? This breakdown is based on Audit Commission 21/11 survey types. Housing fraud (excluding Housing Benefit) Council tax fraud National non-domestic rates fraud Procurement fraud Fraudulent insurance claims Social services fraud Economic and third sector support fraud Debt fraud Pension fraud Investment fraud Payroll & employee contract fulfilment fraud Expenses fraud Abuse of position Disabled parking concessions (Blue Badge) Recruitment fraud Theft/loss of equipment Internal computer misuse and cyber fraud External computer threats e.g. phishing Other Investigations* Total Brought forward at 1/4/213 Number Number + - = referred completed Carried forward at 31/3/214 Counter-Fraud Page 8 of 18 Copyright CIPFA 214

9 Of the number of investigations completed in , please show break down below: Housing fraud (excluding Housing Benefit) Council tax fraud National non-domestic rates fraud Procurement fraud Fraudulent insurance claims Social services fraud Economic and third sector support fraud Debt fraud Pension fraud Investment fraud Payroll & employee contract fulfilment fraud Expenses fraud Abuse of position Disabled parking concessions (Blue Badge) Recruitment fraud Theft/loss of equipment Internal computer misuse and cyber fraud External computer threats e.g. phishing Other Investigations* Total *Details of other (if significant) (b) Internal/External 213/14 Of the number of investigations referred in 213/14 how many involved: Members of Public? Employees? Members? Suppliers? Other parties?* Total *Details of other (if significant) Number completed Number not proven Number proven Should match total number referred from 7(a) Number prosecuted in 213/14 Counter-Fraud Page 9 of 18 Copyright CIPFA 214

10 8. Recovery (Excluding Housing Benefits/CTRS investigations) (a) Recovery What recovery methods are used? POCA Civil recovery, CCJs, other debt recovery processes Fidelity insurance Payroll/pension deductions Voluntary repayments Other (please specify)* *Details of other What is included in the calculation of the loss to be recovered? Proven loss Estimated loss (extrapolating forward/backwards) Cost of investigation Legal costs Other (please specify)* *Details of other (b) Value of losses recovered 213/14 What was the value of losses recovered? How many cases of fraud did this relate to? 'k No. Counter-Fraud Page 1 of 18 Copyright CIPFA 214

11 9. Prevention (Including Housing Benefits/CTRS investigations) (a) Pre-appointment Staff vetting When answering these questions, please only answer relating vetting for counter-fraud. Please do not answer in response to vetting relating to safeguarding of children and vulnerable adults. Does your organisation carry out pre-appointment vetting? -- If yes, is this for all staff or some staff? If you selected some staff above, please highlight which staff. Staff who deal with finances Staff who deal with confidential information Staff who have access to vulnerable persons Staff who have the capacity to allocate resources Other (please specify)* *Details of other What checks are undertaken? Extended references External database searches (Experian etc.) Open source (free publicly available sources e.g. LinkedIn, Facebook etc.) Credit reference agencies CRB checks Other (please specify)* *Details of other All/Some -- Yes / No / n/a Yes / No / n/a Counter-Fraud Page 11 of 18 Copyright CIPFA 214

12 (b) Conflicts of interest Organisation staff Does your organisation require completion of conflict of interest declarations?? If yes, how often? On appointment Annually Periodically As necessary, when an interest occurs Yes / No / Sometimes Who is required to complete them? Executive directors and senior managers Middle managers (e.g. assistant directors / heads of service etc.) Lower middle managers / group managers / team leaders All permanent staff Temporary and interim staff Contractors and partners By Managers - informal procedure No action would be taken What does your policy or practice require you to do with completed declarations of interest? File them Audit them annually/periodically Spot checks Report to committee Nothing Other (specify below) *Details of other Members/Non-Executives Are members/non-execs required to complete declarations of interests? Are member/non-execs declarations publicised? (c) Anti-fraud culture What does your organisation do to create and enforce an anti-fraud culture? Fraud awareness training Publicity (successful outcomes, fraud drives, fraud flashes etc.) Yes / No / Sometimes How does your organisation deal with non-compliance, e.g. failure to declare an interest? Yes / No / Sometimes Disciplinary By Human Resources - formal procedure By Managers - formal procedure Yes / No Yes / No Policies and procedures Set tone from the top (zero tolerance, high-level engagement etc.) Hotlines and whistle-blowing What other tools does your organisation use to foster an anti-fraud culture? E.g. use of counter-fraud champions? Counter-Fraud Page 12 of 18 Copyright CIPFA 214

13 1. IT (Including Housing Benefits/CTRS investigations) (a) IT Techniques What, if any IT techniques do counter-fraud specialists use to aid prevention and detection? Data matching Data mining Internet / open source analysis Text mining Network intrusion detection Log, monitor, audit employee online actions Automatic alerts Automatic risk assignment and prioritisation Case management tools Incident recording-themes / linked to crime / intelligence Other (please specify)* *Details of other (b) IT Software What Fraud Management Information System software do you use? What Risk Management software do you use? What Counter-Fraud software do you use? Software Yes / No Version --- please select --- Counter-Fraud Page 13 of 18 Copyright CIPFA 214

14 11. Governance and Strategy (Including Housing Benefits/CTRS investigations) (a) Risk Registers? Is fraud included in your organisation's strategic/corporate risk register? Is fraud included on operational/service risk registers? Is there a separate fraud risk register? (b) Reporting Counter-Fraud How often do those responsible for Counter-Fraud report to the audit committee or similar governance body? What is reported to the committee? (c) Annual Governance Statement / Statement on Internal Controls Frequency per annum If your organisation prepares an Annual Governance Statement or Statement on Internal control what assurance on counter fraud arrangements is provided annually to support the statement? Counter-Fraud Page 14 of 18 Copyright CIPFA 214

15 (d) Policies and strategies What policies or strategies does your organisation have in relation to counter-fraud work and how often are they reviewed? Corporate strategy Anti-Bribery Fraud response plan Whistle blowing (PIDA) RIPA Anti-Money laundering Sanctions, including prosecutions etc. Pre-employment checking Liaison protocols, internal & external Counter-fraud policy Codes of conduct, e.g. gifts & hospitality, IT use etc. Other How does the organisation publicise these strategies and policies? Do not publicise Internet Intranet Team brief/staff newsletters/staff s Posters Local press Training, including induction Other (please specify)* *Details of other Does the counter-fraud function or another team audit/monitor adherence to the policies listed above? If no, who monitors the above? Yes / No Frequency of review Yes / No / Sometimes Does your organisation as a policy undertake parallel sanctions? e.g. double and/or triple (criminal, civil, disciplinary) Counter-Fraud Page 15 of 18 Copyright CIPFA 214

16 12. Partners / Contractors / Volunteers (Including Housing Benefits/CTRS investigations) (a) Ensuring contractor compliance with counter-fraud principles This question relates to how your organisation makes sure that contractors have adequate approaches to counter-fraud. Please answer firstly in relation to the Bribery Act and then for counter-fraud in general. Do you enforce your organisation's principles and approaches in relation to counter-fraud and bribery on outsourced areas (i.e. partners & contractors)? Bribery Act Counter-fraud How do you enforce these principles? (please tick all that apply) Standard clauses in contracts Training Financial penalties Joint working agreements How is compliance checked? (please tick all that apply) Contract monitoring teams Audit work Open work accounting Annual statements Sample testing Bribery Act Bribery Act How many third sector organisations does your authority work with? In which areas are these third sector organisations operating in (e.g. ALMOs, Adult Social Care) Counter-fraud Counter-fraud No. Counter-Fraud Page 16 of 18 Copyright CIPFA 214

17 13. Additional questions (Including Housing Benefits/CTRS investigations) (a) Counter-Fraud work in partnership with other organisations Public sector bodies often work with a wide variety of other organisations, to either share good practice, data or to work in an integrated way. Please briefly describe any relationships your organisation has with other bodies (or groups of bodies) to: (a) Exchange good practice and knowledge (e.g. London Public Sector Counter Fraud Partnership, BGF) (b) Exchange data (c) Joint Working (e.g. Joint investigations, or shared services type arrangements with other bodies) (b) Council Tax arrangements What has been the impact on your workload from the changes to Council Tax arrangements from 1/4/213? (c) Social Fund What has been the impact on your workload from the introduction of the Social Fund? (d) Bribery Act How has the Bribery Act 212 impacted on your Counter-Fraud work? (e) Money laundering What impact have you seen on your workload in regards to money laundering? Counter-Fraud Page 17 of 18 Copyright CIPFA 214

18 (f) Public Health What impact have you seen on your workload from the introduction of LA delivery of Public Health? (g) Software Please list here any IT packages that you use and would recommend (and why): (h) Third Sector Organisations If your organisation works with third sector organisations, what expectations do you have about their counter-fraud practices? (i) Localism Bill How do you see the Localism Bill impacting on your Counter-Fraud work? (j) Universal Credit What changes are you considering in preparation for Universal Credit? E.g. staffing, recruitment, contracts etc. (k) New fraud What type of newer fraud are you experiencing and how are you managing this? E.g. mandate fraud. Counter-Fraud Page 18 of 18 Copyright CIPFA 214