Policy for the prevention of fraud and illegal acts



One of the most fundamental principles governing any organisation, whether in the private or public sector – is the proper use of funds, however these are derived. This document sets out the procedures that apply with regard to reporting any detected or suspected fraud or other illegal act determined within or outside of the Solihealth Limited (the “Company”), and any GP practice or PCN grouping that engage with the Company.


There are three fundamental principles that govern everyone working in the Company:

    1. Accountability – everything done by those who work in the Company must be able to stand the test of public and parliamentary scrutiny, and judgements on propriety and professional codes of conduct.
    2. Probity – absolute honesty and integrity should be exercised in dealing with suppliers, patients, staff and contracts.
    3. Openness – the Company’s activities will be sufficiently transparent at all times so as to promote confidence between the Company, the GP Practices and PCN groups. All financial records will be available and accessible by more than one person at all times. 

Not only must these principles be followed, they must be seen to be followed – and all staff must be made fully aware of the details behind the use of funds.

It is therefore important that all those who work within the practice are aware of our commitment to the elimination of fraud and other illegal acts involving dishonesty or damage to property. For simplicity, all such offences are referred to as “fraud”, except where the context indicates otherwise.

Fraud in the NHS

It is estimated that the NHS is vulnerable to £1.198 Billion worth of fraud each year.

The CFA website provides information about this. https://cfa.nhs.uk

What is NHS Fraud

Fraud is a deception carried out for personal gain, usually for money. Fraud can also involve the abuse of a position of trust. By ‘NHS fraud’ we mean any fraud where the NHS is the victim. While those who commit fraud against the NHS are a small minority, their actions have a serious impact on us all. For a more detailed definition of NHS fraud, please visit the What is NHS fraud? page.

The website includes details of 13 key areas of fraud (with examples and advice) and over 120 known types of fraud committed against the NHS

Only a small percentage of the cases relate to Primary Care, but the importance of the issue remains, and the Company is committed to expose fraud.

The Policy

Solihealth Limited is committed to the elimination of any fraud within the activities and services offered through Solihealth.

To this end:

    1. Every case of suspected fraud will be rigorously investigated.
    2. The police will be called in whenever it appears that a criminal offence may have been committed.
    3. The Company’s disciplinary procedures will be rigorously followed.
    4. Action will be taken to recover any loss to Solihealth Limited.
    5. Fraudulent activity will be considered as Gross Misconduct and may be subject to summary dismissal.
    6. The Company has the right to suspend an employee pending the outcome of any investigation.

Internal Reporting

If a member of staff has reason to suspect a colleague, provider or other person including the GP Practices and PCN groupings of committing a fraudulent offence, or other offence involving a serious infringement of the Company or the NHS, for example:


      • Theft of practice property
      • Abuse of practice property
      • Deception or falsification of records
      • Fraudulant claims

The member of staff should, in the first instance, report their concerns to their line manager. If it is suspected that the line manager may be involved in the fraud, the report should be made to a more senior person.

The person receiving the report will make a written record of the discussion and immediately inform the senior executive or Chair of the Solihealth Limited board before taking any action. The member of staff reporting the fraud will be kept informed as to the outcome of the investigation.

“No Detriment” Policy

All members of staff have a responsibility to protect the assets of Solihealth and the GP practices and PCN with whom they will be working closely.

The Company wishes to encourage anyone having reasonable suspicions of fraud to report them. Therefore the Company will rigorously enforce the principle that no employee will suffer in any way as a result of reporting reasonably held suspicions providing these are genuinely held and considered, and have evidence supporting such a claim.

Any member of staff who raises suspicions that they are unable to justify as being “reasonably held” or with malicious intent will be dealt with through the Practice disciplinary procedures.

The Company also has a Whistleblowing Policy which will provide for circumstances as these principles and procedures will apply.

Reporting Fraud to the NHS

The Company encourages staff to follow the internal reporting process outlined above. However the NHS CFA offers a reporting line.

Below is an extract from the site. Following principles of whistle blowing, there is a distinction between “linked” and “separated” regarding your details.

Can I report my suspicions of fraud in confidence to the NHSCFA?

All information you provide will be treated in complete confidence.

There are two ways of reporting that determine how your personal details are handled.

Linked – If you have no concerns about your personal details being linked to the information you are providing (or if you are reporting something in an official capacity as a part of your job). This means that your details will be held with the information and made available to the investigating officer. This will allow us to contact you easily if anything needs to be clarified.

Separated – If you are happy to provide your personal details to NHS Counter Fraud Authority but would like your personal details separated from the information you are providing. Measures will be taken on receipt to ensure that the information that you have provided does not reveal your identity. Your personal details will not be disclosed to anyone including the investigating officer without your permission unless we are obliged by law, or it is in the wider public interest.