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NHS Resolution Annual report and accounts 2021/22 79

The Head of Internal Audit gave MODERATE Anti-fraud, bribery and corruption
assurance to the Accounting Officer that NHS
As with all NHS organisations, the risk of fraud is a
Resolution has had adequate and effective systems
significant consideration. The nature of NHS Resolution's
of control, governance and risk management
work inevitably focuses our attention on the risk of
in place for the reporting year 2021/22.
fraudulent claims being brought against our members,
Performance and financial controls and we take a zero-tolerance stance towards fraud
and bribery. We have established controls in place to
NHS Resolution's financial and operational performance
mitigate the risk of fraud as far as possible, including
is reported regularly to the Senior Management
an up-to-date Anti-fraud, bribery & corruption policy
Team, to the Board and to me. Our financial
and procedure, as well as annual training. These
position, together with operational KPIs, is reported
provide guidance for all staff, enabling them to
quarterly to DHSC to demonstrate that performance
recognise and deal with potential instances of fraud
is being managed in line with expectations.
and bribery. Counter fraud services are provided by
There are policies and procedures for the management GIAA who work in accordance with the NHS Counter
of finances and resources, including a scheme of Fraud Authority Standards for Providers to prevent,
delegated authorities for the approval of expenditure. deter, detect and investigate fraud and bribery. During
The internal audit programme routinely covers key 2021/22 we have worked closely with our colleagues
financial controls to provide assurances to management in the NHS Counter Fraud Authority, DHSC and the
and the Board. Governance arrangements through the Cabinet Office in the adoption of the Government
Reserving and Pricing Committee for the valuing of Counter Fraud Functional Standard GovS013.
provisions for claims are set out earlier in this statement.
We continue our membership of the Claims and
Timing of cashflows - known claims provisions Underwriting Exchange (CUE), a database of non-clinical
claims reported to insurers. This enables us to share
The known claims provision calculation uses the
expected settlement date (ESD) from individual information with other indemnifiers, so as to identify
claims recorded in the Claims Management System potentially fraudulent claims. We are fully alive to the
(CMS) to apply inflation and discounting to reach a information governance risks entailed in such an initiative
valuation. However, for the disclosure of the expected and ensure that due legal process is adhered to.
timing of cashflows, this has historically been based Information security and governance
on an actuarial view of settlement patterns.
NHS Resolution has maintained ISO 27001 Information
An adjustment to the 2021/22 known claims Security certification which provides evidence that we
provision has been applied to the estimate have an effective information security management
technique as there has been a significant divergence system. The surveillance audit carried out in December
between the two views, most likely as a result 2021 reviewed a range of governance and technical
of the impact of the Covid-19 pandemic. security controls. The audit identified zero major non­
conformances and two minor non-conformances. As a
As part of this reassessment, we have concluded that
this approach should have been applied to prior periods, result of this the audit recommended the certification
drawing on the information that was available at the for NHS Resolution be continued. We have also
time, as it results in a better estimate of the known claims achieved Cyber Essential Plus certification which is a UK
provision. The prior period financial statements have Government scheme of good practice in information
security. NHS Resolution is committed to minimising
therefore been restated as required by IAS 8 Accounting
the risks associated with information handling and
Policies, Changes in Accounting Estimates and Errors.
Further details of the adjustments to the financial to ensuring that all staff are fully aware of their
statements are provided at Note 7.4 to the accounts. responsibilities in relation to information governance.

We are identifying potential improvements to the
process to estimate the expected timing of cash-flows.