Cases of NHS fraud across the UK have risen by over a third in the past four years and GP practices are not immune. All NHS fraud deprives patients of services. Fraud in a GP can also threaten the livelihoods of both GPs and staff.
So what action should practices take to minimise the risk of fraud?
How fraud can take place
GPs place an enormous amount of trust in their staff, particularly the practice manager. This is not surprising. GP training still ill-prepares new GPs for running a business and, in most cases their priority is patient care. But, for some staff, this position of trust gives them an opportunity they cannot resist.
This can particularly be true in smaller practices where, with fewer staff, full control of financial processes will often rest with the practice manager. This means that the manager may be the only person dealing with the following:
- Adding staff details to payroll (or passing them to outsourced payroll service)
- Payroll calculations including overtime
- Payments to bank accounts (drawings and salaries)
- Payments of tax and superannuation
- Invoicing suppliers
- Claims for NHS income and reimbursements
- Inter-account bank transfers
- Setting up payees
- Banking cheques
- Payments to suppliers
- Reconciliation of bank accounts
- Preparation of records for accountants
- All communications internally and externally relating to finances
- Petty cash
Therefore, in a practice which does not use cheques any longer, no GP (or other member of staff) takes part in, or even sees, any financial transaction.
Action to take
Your practice’s accountants will be able to advise you about specific precautions or procedures in your practice. But putting in place measures to minimise the risk of fraud and protect resources need not be complex.
The following are steps you can take.
Involve another staff member (or a partner) at key stages in the payroll system. More than one person should be the contact person for outsourced payroll and have access to the reports. This additional person might also check the following:
- That the names on payroll are all employed staff
- Salaries paid relate to contractual pay rates
- Overtime claims match overtime sums actually paid
- Staff details (payees) and pay details (new rates of pay, overtime, bonuses etc) match those transferred to an outsourced payroll service
- Totals on payroll are those transferred to payee bank accounts
- Increases in salary have backup documentation checked (eg confirm an increment was due).
Partners should have access to the bank account. The practice might need to review bank account access arrangements to ensure that partners can log into the account. Once this is arranged the GP partners need to actually do log into the bank account and see what is happening.
The practice should also consider the following:
- Reviewing levels of authorisation for undertaking bank transfers, setting up new accounts/payees etc and ensure that more than just the practice manager has full rights
- Verifying that the bank account is fully reconciled with the accounts records on a monthly basis
- Reviewing systems for in-house authorisation of inter-account transfers above a certain level
The practice should also make sure that petty cash is recorded and banked on a regular basis and that large amounts of cash are not kept in the surgery.
Remember that the vast majority of practice managers are aware of and value the amount of trust put in them. If you are reviewing financial controls and anti-fraud measures in the practice, you should do this with tact and diplomacy, with full consultation and involvement from your practice manager, who may feel that sudden interest in finances is a reflection on his or her current practice.
Update your Prevention of Fraud Policy
After working through the above, your Prevention of Fraud Policy may require updating. A basic policy will:
- Define principles of honesty, probity, accountability
- Describe the practice’s commitment to elimination of fraud
- Give examples of what you would consider as fraudulent activity
- Describe how to report suspicions and to whom
- State that you will investigate cases of possible fraud and involve the police if necessary
- Clarify that fraud would be considered Gross Misconduct
Reviewing your Bribery Act Policy and Whistleblowing Policy will also help ensure that you have covered everything.
NHS fraud prevention
In England, fraud prevention is undertaken by the NHS Counter Fraud Service. If you are suspicious that fraud might be occurring in your practice or elsewhere in the NHS, your concerns should be directed to your local counter fraud specialist.
- Fiona Dalziel is a practice management consultant.www.dlpracticemanagement.co.uk