Recognising fraud and bribery


Local Counter Fraud Specialist

Each NHS organisation must have a Local Counter Fraud Specialist (“LCFS”) in place who is responsible for tackling all fraud and bribery-related matters including referrals and risks. This is to protect valuable NHS resources, ensuring they can be used to provide the best possible patient care.

Northamptonshire ICB’s (the “ICB”) LCFSs are Sannan Khan, Katie Alldrit-Rose, and James Shortall who work for accountancy firm BDO LLP. They have extensive experience of the NHS and counter fraud work and are Accredited Counter Fraud Specialists. For any fraud or bribery related concerns or questions, please contact Sannan, Katie or James via email or their direct line:

Sannan Khan (Lead LCFS)

Partner - Forensic Accounting and Valuation Services

Telephone: 0121 265 7283 (DDI) 07583 023 392 (mobile)



Katie Alldrit-Rose (Support LCFS)

Senior Manager - Forensic Accounting and Valuation Services

Telephone: 0121 265 7249 (DDI) 07581 304 401 (mobile)



James Shortall (Support LCFS)

Senior Manager - Forensic Accounting and Valuation Services

Telephone: 02380 881 767 (DDI) and 07815 000 289 (mobile)


NHS Counter Fraud Authority

The NHS Counter Fraud Authority (NHSCFA) has overall responsibility for preventing, detecting and investigating fraud and bribery within the NHS. The aim is to protect NHS staff and resources from activities that would otherwise undermine their effectiveness and their ability to meet the needs of patients and professionals. Ultimately, this helps to ensure the proper use of valuable NHS resources and a safer, more secure environment in which to deliver and receive care.

NHS Counter Fraud Authority

Tel: 0800 028 40 60



What is fraud and bribery?


Fraud is committed when a person deliberately makes a dishonest representation in order to make a gain for themselves, or another, or to cause a loss, or a risk of loss to someone else. According to the Fraud Act 2006, the focus is on the individual’s dishonest behaviour and intent, rather than to prove a person has been deceived.  It is not necessary for the gain or loss to materialise. Just trying to commit fraud, even if not successful, makes the act complete.  There are three main offences commonly referred to under the Fraud Act 2006:

1.       False representation

Examples of this could be: submitting a false timesheet that is not reflective of hours worked or; exaggerating travel expenses or claiming for journeys that have not been undertaken.

Patients are also able to make a false representation, for example by obtaining free NHS prescriptions or care to which they are not entitled to.

2.       Failing to disclose information

Common examples of this are failing to declare any previous criminal convictions on an application form when legally required to do so, and failing to share any outside interest as they occur, which could allow a conflict of interest to arise.

3.       Abuse of position

This relates to management override of controls for personal gain, for example creating false invoices or abuse of the procurement or recruitment processes.

The maximum penalty that can be imposed for someone who has committed fraud is ten years imprisonment.


The Bribery Act 2010 reformed the criminal law to provide a new, modern and comprehensive scheme of bribery offences that enables courts and prosecutors to respond more effectively to bribery committed within the UK or abroad. The Bribery Act applies to individuals who are British citizens or ordinarily resident in the UK, and corporate bodies based or operating in the UK. There are offences for individuals, as well as a corporate offence, and penalties for non-compliance are serious.

The Bribery Act 2010 is split into four main offences:

  • Offering, promising or giving a bribe;
  • Requesting or agreeing to receive a bribe;
  • Bribing a foreign public official; and
  • Failure to prevent bribery.

Bribery is generally defined as giving someone a financial or other advantage to encourage that person to act inappropriately, or to reward that person for having done so. It is, therefore, offering an incentive to someone to do something which they wouldn’t normally do. For example, someone on a recruitment panel might be offered tickets to an event by one of the candidates, or someone linked to them, in return for that panel member selecting the candidate.

There are various penalties that can be applied upon a bribery conviction. Bribery and corruption is also damaging to an organisation’s reputation.

The penalties include:

  • A criminal prosecution which can carry a sentence of up to ten years imprisonment;
  • Organisations can receive an unlimited fine; and
  • Disbarment from EU contract tenders.

Staff should familiarise themselves with the ICB’s Counter Fraud and Bribery Policy, and the Conflicts of Interest Policy  Staff could be held individually accountable for acting against these policies or the Acts themselves. This could lead to disciplinary and / or criminal investigation and sanctions.

Reporting fraud of bribery concerns

Please direct any concerns or queries regarding fraud matters to the LCFS team in the first instance. Alternatively, you may contact the Chief Finance Officer. Please do not contact the police directly.

If you don’t feel comfortable speaking to the LCFS or Chief Finance Officer, you may also report concerns to NHS Counter Fraud Authority directly, via the following methods:

The reporting line on 0800 028 4060 or online at  

For more guidance on what and what not to do when reporting fraud, visit

If you believe a fraud or bribery is being committed, please follow the guidance below:

If you believe a fraud or bribery is being committed, please follow the guidance
Do Don't

Report your concerns to:

  • Local Counter Fraud Specialist, Sannan Khan, Katie Alldrit-Rose or James Shortall
  • Chief Finance Officer


  • NHS Counter Fraud Authority
Confront the individual, or report your suspicions to anyone other than those person listed

Make a note of your concerns.

This will help ensure that there is sufficient information when making a report

Try to investigate the matter yourself, or undertake surveillance

Note all relevant details of the offence being committed.


  • Who?
  • What?
  • Where?
  • When?
  • Why?
  • How?
Contact the police directly

Make sure you report any suspicions you may have.

If possible, retain copies of relevant documentation.

For example, anything that aroused your suspicions and support your allegation.

Do nothing!


Suspected fraud or bribery should be reported to an appropriate individual who has the authority to investigate such matters – they should not be reported to a friend, colleague, or line manager.

Please use the following lines of reporting:

  • Sannan Khan (Lead LCFS)
    Partner - Forensic Accounting and Valuation Services
    Telephone: 0121 265 7283 (DDI) 07583 023 392 (mobile)
  • Katie Alldrit-Rose (Support LCFS)
    Senior Manager - Forensic Accounting and Valuation Services
    Telephone: 0121 265 7249 (DDI) 07581 304 401 (mobile)
  • James Shortall (Support LCFS)
    Senior Manager - Forensic Accounting and Valuation Services
    Telephone: 02380 881 767 (DDI) and 07815 000 289 (mobile)
  • NHS Counter Fraud Authority: 0800 028 4060 / Report through their online form 

If you require independent advice at any stage, you can also contact the charity Protect (formerly Public Concern at Work), on 020 3117 2520. Their lawyers can give you free, confidential advice on raising concerns about serious malpractice.


Training and Awareness

One key aim of the Local Counter Fraud Specialist is to develop a counter fraud culture. This is done through the provision of various fraud and bribery presentations and awareness sessions. The sessions can be tailored to suit your needs, ranging from short and informative sessions to more formal presentations or workshops. These sessions help to increase employee awareness of the ICB’s zero tolerance approach to fraud and bribery.

If you would like to arrange a training and awareness session, please contact one of our Local Counter Fraud Specialists: Sannan Khan, Katie Alldrit-Rose or James Shortall.




National Fraud Initiative

We are required by law to protect the public funds we administer. We may share information provided with other bodies responsible for auditing or administering public funds, in order to prevent and detect fraud.

The Cabinet Office is responsible for carrying out data matching exercises. Data matching involves comparing computer records held by one body against other computer records held by the same or another body to determine the extent of the 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. 

We participate in the Cabinet Office's National Fraud Initiative, a data matching exercise to assist in the prevention and detection of fraud.

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).  

For further information on data matching at the ICB contact ICB’s NFI Administrator.

You can read further information and cases studies on how the National Fraud Initiative has assisted the NHS and other public sector organisations online.