Fraud can be defined as ‘dishonestly making a false representation with the intention of gaining, or causing a loss to another’. It can also be where somebody fails to report something where there is a legal duty for them to do so, or where an individual abuses a position of trust to the financial detriment of another. Fraud is a criminal offence.

Fraud against the NHS means that the money intended for patient care ends up in the pockets of those who did not legitimately earn it. It means fewer resources are available to be spent on frontline health services such as patient care, health care facilities, doctors, nurses, and other staff. It costs the NHS billions of pounds every year.

The ICB is committed to maintaining an honest and open approach to best fulfil the objectives of the NHS and this means the ICB operates a zero-tolerance approach to fraud and bribery. Such conduct, at any level, is unacceptable. Throughout the organisation a number of controls are in place including stringent policies and internal systems to prevent and detect bribery, in accordance with the Bribery Act 2010. We also ensure compliance with the NHS requirements to meet Government Functions Standard GovS013: Counter Fraud.

TIAA is the provider for Local Counter Fraud Specialist (LCFS) services and the role of the LCFS is to implement the NHS Counter Fraud strategy within the organisation and to investigate professionally, any suspicions of fraud or bribery that may arise.

The information below explains what actions should be taken should a suspicion of fraud, bribery or corruption arise.

Fraud happens when someone makes a deliberate attempt to dishonestly make a gain for themselves or another, or cause a loss, or risk of 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 the three main fraud offences are provided below.

This is the most common type of fraud investigated within the NHS. This normally involves a false declaration being made, such as working elsewhere whilst on sickness absence from your substantive post. The staff member has made a representation that they are too sick to work, but is then undertaking work elsewhere, whether that is in the NHS or otherwise.

This could be relating to any information where there is a legal duty to disclose.  For example, failing to disclose a criminal record, anything that could affect your Disclosure and Barring Service (DBS) checks or your right to work status. 

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.  The three main offences under the Bribery Act 2010 most relevant to the NHS are:

  • Giving a bribe- offering, promising or giving a bribe to another person to perform a relevant function or activity;
  • Receiving a bribe- requesting or agreeing to receive or accepting a bribe to perform a function or activity improperly; and
  • Corporate offence- failure of a commercial organisation to prevent bribery.

Some common forms of bribery include: cash, facilitation payments, gifts, hospitality, political donations, charitable contributions, enhanced commissions, and employment of friends / family.

Further information about fraud and bribery can be found in our Counter Fraud, Bribery and Corruption Policy and Response Plan. 

The ICB is required by law to protect the public funds it administers.  It may share information provided to it with other bodies responsible for auditing or administering public funds, or where undertaking a public function, in order to prevent and detect fraud.

We participate in the Cabinet Office’s National Fraud Initiative: a data matching exercise to assist in the prevention and detection of fraud.  We are required to provide sets of data to the Minister for the Cabinet Office for matching for each exercise.

Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match.  This is usually personal information. Computerised data matching allows potentially fraudulent claims and payments to be identified.

Where a match is found it may indicate that there is an inconsistency which requires further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.

The processing of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under its powers in Part 6 of the Local Audit and Accountability Act 2014.  It does not require the consent of the individuals concerned under data protection legislation or the General Data Protection Regulation (GDPR), however the Cabinet Office set out how your data will be used and your rights here.

For further information on data matching at the ICB please contact the Local Counter Fraud Specialist, Victoria Dutton; or, telephone 07826 858 746.


Anyone can report concerns of fraud and bribery within the NHS.  Whether you are a member of the public, an NHS employee, a contractor, a supplier, from another government agency or someone else, your input can make a difference.  Counter Fraud provision is provided by TIAA for Buckinghamshire, Oxfordshire and Berkshire West ICB.

Suspicions and concerns can be reported, in absolute confidence, to the ICB’s Local Counter Fraud Specialist:

Victoria Dutton

Telephone: 07826 858 746

Email: or

Alternatively, you can call the NHS Counter Fraud Authority’s 24-hour reporting line anonymously on 0800 028 4060, or confidentially online at  More information about the NHS Counter Fraud Authority can be found here.  Concerns can also be raised with the ICB’s Director of Finance.


The BOB ICB Local Anti-Fraud Bribery Corruption Policy can be found here

A message from the Director of Finance:

The ICB has a zero-tolerance approach towards fraud and bribery and will act against those who commit fraud. There is material available on our pages to help raise awareness and education of fraud within the NHS to help recognise it; report it; and help prevent it. We have a team of Counter Fraud Specialists who are happy to meet with individual staff members; attend team meetings; conduct workshops; and deliver awareness presentations.

If you have any concerns in relation to fraud or bribery at Buckinghamshire, Oxfordshire and Berkshire West Integrated Care Board, or would like to know more, please take the time to view the Counter Fraud and Bribery Policy, Counter Fraud information below or contact your Local Counter Fraud Specialist directly. Alternatively, you can report concerns anonymously to the NHS Fraud and Corruption reporting Line 0800 0284060 or online at .