PHB Fraud – Financial Governance – Page 6

Strong and effective financial audit arrangements are essential and are key to highlighting suspected PHB fraud, particularly where these arrangements are outsourced to local authorities.

Financial audit arrangements and the roles and responsibilities of the staff involved should be clearly defined to ensure that the a robust system of checks is in place that operates effectively. All staff responsible for making these checks must be able to recognise PHB fraud and know what to do if they find it or suspect it.

Checks made must be capable of identifying PHB fraud, as it is often this routine analysis of how a PHB is being managed and used that first highlights potential fraud concerns. If financial governance and audit arrangements are weak then PHB fraud will neither be prevented nor detected it when it occurs.

It is important that all identified concerns are followed up and acted upon promptly, and that complete and proper records are kept of all actions taken and decisions made. If actions are not taken or not properly followed, PHB fraud may continue over several years resulting in significant financial loss to the NHS.

Part of the Local Counter Fraud Specialist (LCFS) role is reviewing policies and procedures to ensure they are fraud proof. The LCFS is able to advise on PHB protocols, procedures and documentation and should be involved in the review of audit and governance arrangements.