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AS Report – The National Fraud Initiative in Scotland 2024.

Renfrewshire Council · 4 November 2024
Back to Audit, Risk and Scrutiny Board — 4 November 2024 and its agenda

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1 
___________________________________________________________________
To: Audit, Risk and Scrutiny Board
On: 4 November 2024
___________________________________________________________________
Report by: Interim Chief Auditor
___________________________________________________________________
Heading: Audit Scotland Report – The National Fraud Initiative in Scotland
2024. 
___________________________________________________________________
1. Summary
1.1 Audit Scotland’s report on the National Fraud Initiative (NFI) 2022/23
was published in August 2024 and is attached at Appendix 1. 
1.2 The report highlights that Scottish public bodies have recorded
outcomes of £21.5 million arising from the 2022/23 exercise. The
2022/23 figure has increased by approximately £6.6 million since the last
exercise and the increase has been across most data match areas. The
NFI outcome figures include amounts for fraud and error detected as well
as an estimate for those future losses that have been prevented.
However it is not clear whether underlying levels of fraud have increased
since the reports states that there have been improvements in the
recording of the results by participating bodies and there has also been
a change in the estimation methodologies which has contributed to
higher outcomes in some areas. 
1.3 Renfrewshire Council’s approach and outcomes for the 2022/23
exercise is attached at Appendix 2. 
1.4 Our self-assessment of our arrangements in preparation for the 2024/25
exercise is also included in Appendix 3.
___________________________________________________________________

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2 
2. Recommendations 
2.1 It is recommended that the Audit, Risk and Scrutiny Board: 
• note the report from Audit Scotland, and 
• note Renfrewshire Council’s current arrangements, outcomes
and self-assessment to support the 2024/2025 NFI exercise.
_________________________________________________________
3. Background
3.1 The NFI aims to detect and prevent fraud and error through a national
data matching exercise across public bodies carried out by the Cabinet
Office and overseen, in Scotland, by Audit Scotland, with the aim of
identifying instances of possible fraud or error.  Overpayments that are
identified through the initiative allow public bodies to take appropriate
action to recover the money.
3.2 The initiative, which is co-ordinated in this council by internal audit,
operates biennially with the data downloaded and electronically matched
in year one and the results issued, investigated and reported in year two. 
In relation to this report data was downloaded from our systems in
September 2022 and uploaded onto the secure NFI web portal in
October 2022, to be matched against other council data or other
participant data.  
3.3 The Audit Scotland report highlights 3 recommendations for councils to
consider in relation to counter fraud activities and their response to the
National Fraud Initiative.  These are summarised below along with the
current arrangements in Renfrewshire Council and any identified
improvement actions: 
1. Maximise the benefits 
All participants should ensure that an appropriate level of resource is
available to deliver NFI follow-up activities in an efficient and effective
manner, in line with local priorities. 
The Interim Chief Auditor co-ordinates the NFI exercise in Renfrewshire
Council.  Time is included in the counter fraud work and audit plan and
there is regular engagement with services throughout the National Fraud
Initiative. If any issues are identified in progressing the matches, these 
are highlighted to Senior Management for action. Revenues and Benefit
services have included NFI match investigation in their work plan.

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3 
2. Self-appraisal 
The NFI self-appraisal checklist is used as part of planning for the
2024/25 exercise. 
The Interim Chief Auditor completes the NFI self-appraisal checklist as
part of the planning arrangements for each NFI exercise and the
completed checklist for the 2024/25 exercise is attached in Appendix 3
of this Report.  Only one improvement action has been identified and that
is to include reference to the National Fraud Initiative in the Council’s
Code of Corporate Governance.
3. Follow-Up Activity Arrangements
Participants should put in place arrangements for monitoring follow-up
activity, and where it is necessary seek to understand reasons for low or
nil outcomes.
Internal Audit is responsible for co-ordinating the exercise and regularly
review outcomes.   Where any control issues are identified, meetings are
held with the appropriate parties to highlight them and determine any
action required.  Processes followed to investigate matches are also
reviewed where low and nil outcomes are recorded.
3.4 The Council has made financial savings of £401,199 as a result of
investigative work on the 2022/2023 NFI matches and further future
estimated savings of £810,056 have also been noted. Non-financial
outcomes relate to 2 housing properties being recovered, 11 housing
applications being amended or cancelled and 152 blue badges being
cancelled.   
___________________________________________________________________

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4 
Implications of the Report
1. Financial - The Council has in place arrangements to recover any
financial overpayments identified through the National Fraud Initiative.   
2. HR & Organisational Development - None 
3. Community Planning – 
Wealthier and fairer – The National Fraud Initiative (NFI) exercises
make a significant contribution to the security of public sector finances
by confirming that services are provided to the correct people and by
eliminating fraud and error.
4. Legal – None 
5. Property/Assets - None 
6. Information Technology - None
7. Equality & Human Rights - None
8. Health & Safety - None
9. Procurement - None
10. Risk – Priority is given to investigating matches with a higher risk of
fraud and error.
11. Privacy Impact – There is a requirement to take best reasonable
attempts to notify people of the NFI exercise as part of the preparation
for the exercise.  This requirement has been complied with.
12. Cosla Policy Position – None
13. Climate Risk – None
14.  Children’s Rights - None
___________________________________________________________________ 
Author:           Karen Campbell, Interim Chief Auditor

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Prepared by Audit Scotland
August 2024
The National Fraud
Initiative in
Scotland 2024

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2The National Fraud Initiative in Scotland 2024
Contents
Key messages 3
Recommendations 4
1. Introduction 5
2. Overall outcomes  7
3. NFI delivery 11
4. Specific match areas 14
5. Pilot exercises and future developments 25
Appendix 26
Accessibility
You can find out more and read this report using assistive
technology on our website www.audit.scot/accessibility.
Audit team
The core audit team
consisted of: 
Tim Bridle, under the
direction of Cornilius
Chikwama.

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3Key messages
Key messages
Key messages
Key messages
1 Fraud against the public sector costs the taxpayer money and
can undermine both confidence in government and the delivery
of public services. The proactive detection and prevention of
fraud using the National Fraud Initiative (NFI) remains vitally
important to public sector financial management as public bodies
continue to recover from Covid-19 and to deal with the impact of
the cost-of-living crisis.
2 NFI savings and outcomes have increased from £14.9 million
in 2020/21 to £21.5 million in 2022/23, with increases across
most data match areas. However, savings from council tax single
person discounts are slightly reduced and additional outcomes
in some areas are attributable to changes in estimation
methodologies. Overall, it is not clear whether underlying levels
of fraud have increased since 2020/21.
3 NFI governance and follow-up arrangements remained sound
for most participating bodies over the period covered by the
2022/23 exercise. However, when compared to previous
exercises, slightly fewer bodies have been assessed by their
auditors as having fully satisfactory arrangements, and there
remains scope for some bodies to follow up on data matches
more effectively.

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4Recommendations
Recommendations
Participating bodies should:
• Ensure that an appropriate level of resource is available to deliver NFI
follow-up activities in an efficient and effective manner, in line with
local priorities.
• Use the NFI Self-Appraisal Checklist as part of planning for the 2024/25
exercise.
• Put in place arrangements for monitoring follow-up activity, and where
it is necessary seek to understand reasons for low or nil outcomes.

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5
1.
1. Introduction
1. Introduction
The proactive detection and prevention of fraud using the
National Fraud Initiative (NFI) remains vitally important to
public sector financial management as public bodies
continue to recover from the Covid-19 pandemic and to deal
with the impact of the cost-of-living crisis.
1. Fraud against the public sector costs the taxpayer and can undermine
both confidence in government and the delivery of public services.
The National Fraud Initiative (NFI) is a proactive data matching exercise
designed to identify and prevent fraud. It remains vitally important during
a time of ongoing financial pressure as public bodies continue to recover
from the Covid-19 pandemic and to deal with the impact of the cost-of-
living crisis.
2. The Public Sector Fraud Authority (PSFA) oversees the NFI across
the UK, and Audit Scotland leads the exercise in Scotland, working with a
range of Scottish public bodies and their external auditors. The NFI takes
place every two years, and this report considers the outcomes from the
2022/23 exercise.
Statutory basis for NFI
3. We carry out the NFI under powers introduced by the Criminal
Justice and Licensing (Scotland) Act 2010 and incorporated in Part 2A
of the Public Finance and Accountability (Scotland) Act 2000. It is
important for all parties involved that this exercise is properly controlled,
and that data is handled in accordance with the law. The Audit Scotland
Code of Data Matching Practice includes a summary of the key
legislation and controls governing the NFI data matching exercise.
Participating bodies
4. In 2022/23, 110 public sector bodies in Scotland participated in
the NFI, submitting data and following up on matches. The Scottish
Government also submitted data for another 17 central government
bodies who share their systems for payroll and/or creditors. Many
councils also submit payroll data for their Arm’s-Length External
Organisations (ALEOs). Across the UK there are over 1,100 participating
bodies and data matching takes place across them all.

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1. Introduction 6
Main data match areas in 2022/23
5. The main data match areas for the 2022/23 NFI exercise were:
• Payroll
• Creditor payments
• Council Tax (Single Person Discounts and Reduction Scheme
reliefs)
• Pensions
• Housing Benefit
• Housing Tenancy and waiting lists
• Blue Badges (disabled parking)
• Adult concessionary bus travel (new in 2022/23 exercise).
6. The 2022/23 NFI exercise matched new data from His Majesty’s
Revenue and Customs (HMRC) using powers under the Digital Economy
Act (2017).
7. Non-Domestic Rates Small Business Bonus Scheme (NDR SBBS)
matching was postponed for the 2022/23 exercise due to the national
NDR revaluation exercise in 2023. Results will be reported as part of the
2024/25 exercise.
Basis for reported outcomes
8. All monetary outcomes included in this report are on a cash basis,
prior year totals have not been adjusted to reflect inflation or changes in
estimation methodologies since amounts were originally reported. Details
of estimate methodologies used can be found at Appendix.

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72. Overall outcomes
2. Overall outcomes
Overall outcomes from the NFI have increased from 
£14.9 million in 2020/21 to £21.5 million in 2022/23.
Overall outcomes by type
9. The value of outcomes from the NFI, recorded since our last report,
total £21.5 million (up from the £14.9 million in 2022). The cumulative
value of outcomes from the NFI in Scotland since participation started
in 2006/07 now stands at around £180 million. Exhibit 1 shows NFI
outcomes by type for 2022/23 and the previous three exercises.
Exhibit 1. 
NFI outcomes by exercise and type, 2016/17 to 2022/23
Reported outcomes have increased to £21.5 million in 2022/23.
Source: Audit Scotland analysis of NFI outcomes
0
10
25
2022/232020/212018/192016/17
£ million
£17.8m 
£15.3m  £14.9m 
£21.5m
3.1
2.7 4.2
6.8
9.2 7.0
6.2
8.9
5.5 5.6 4.5 5.7
Actual savings:
overpayments and
additional income
Forward savings
estimates: from
overpayments,
additional income and
prevented fraud
Notional outcome
estimates: not directly
linked to actual
overpayments or
additional income, eg
blue badges, housing
tenancy and waiting lists
10. Increased outcomes reported in 2022/23 partly reflect improvement
in recording of results as bodies continue to recover from Covid-19. There
have also been changes to estimation methodologies which contribute to
higher outcomes in some areas (details of methodologies can be found
in the Appendix). It is not possible to extrapolate from these figures that
underlying levels of fraud have increased.

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2. Overall outcomes 8
Outcomes by data match area
11. Most monetary outcomes from the NFI accrue to councils, the Scottish
Public Pensions Agency and the Department for Work and Pensions (DWP)
in the form of savings arising from council tax, pensions and housing
benefits matches.
12. Many participating bodies only submit payroll and creditors datasets
for matching, and this limits the monetary outcomes available to them.
However, overpayments associated with duplicate creditor payments and
payroll matches are not insignificant. NFI outcomes analysed by main data
match area, are shown for the last three exercises in Exhibit 2 (page 9).

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2. Overall outcomes 9
Exhibit 2. 
NFI outcomes by area and exercise
Most savings arise from Council Tax, Pensions and Housing Benefits matches.
Notional outcome
estimates
Forward savings
estimates
Overpayments and
additional income
0 1 2 3 4 5 6
Care Home Payments
Payroll
Concessionary Bus Travel
Creditors
Housing waiting lists
Council Tax Reduction Scheme
Housing Tenancy
Housing Benefit
Pensions
Non-Domestic Rates
Blue Badges
Council Tax SPD
Care Home Payments
Payroll
Concessionary Bus Travel
Creditors
Housing waiting lists
Council Tax Reduction Scheme
Housing Tenancy
Housing Benefit
Pensions
Non-Domestic Rates
Blue Badges
Council Tax SPD
Care Home Payments
Payroll
Concessionary Bus Travel
Creditors
Housing waiting lists
Council Tax Reduction Scheme
Housing Tenancy
Housing Benefit
Pensions
Non-Domestic Rates
Blue Badges
Council Tax SPD
£ million
2020/21
2018/19
2022/23

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2. Overall outcomes 10
Notes:
1.  Non-Domestic Rates Small Business Bonus Scheme data was first submitted for the 2020/21
exercise but did not form part of the 2022/23 exercise due to the revaluation exercise taking place
in 2023.
2.  Care home payments have not been matched since 2018/19 due to legislative constraints.
3.  Adult concessionary bus travel was a pilot exercise in 2020/21 and has been mainstreamed in
2022/23.
Source: Audit Scotland analysis of NFI outcomes
Wider benefits of NFI
13. The NFI also delivers benefits which are more difficult to quantify.
These include its fraud deterrent effect and the financial governance
assurance it provides to bodies where no issues are identified (Exhibit 3).
Exhibit 3. 
Non-monetary benefits of NFI
Source: Audit Scotland
Acts as a deterrent to 
potential fraudsters
Can provide assurance that
systems are operating well
Can identify where system
improvements are required

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113. NFI delivery
3. NFI delivery
NFI governance and follow-up arrangements remain sound
for most participating bodies. However, when compared to
previous exercises, appointed auditors assessed slightly
fewer bodies as having fully satisfactory arrangements.
Auditor assessments
14. NFI governance and follow-up arrangements remain sound for most
of the 110 bodies in Scotland that participated in the 2022/23 exercise.
However, several bodies have struggled with delivery and there remains
some scope for improvement.
15. We asked auditors to assess participating body NFI arrangements,
and rate them as Green (satisfactory), Amber (mostly adequate) or Red
(unsatisfactory). Auditor returns for 2022/23 included a slightly increased
number of amber and red ratings Exhibit 4 (page 12).
16. In most cases amber or red assessments reflect deficiencies with
follow-up activity. Participating bodies routinely cited the lack of 
adequate resources as the main reason for delay or lack of progress 
with follow-up activity.
17. Our NFI Self-Appraisal Checklist includes requirements for
participating bodies to consider Leadership, Commitment and
Communication. The checklist also asks NFI key contacts and users
to consider potential improvements to the efficiency and effectiveness
of follow-up activity. The checklist can be found on our Counter Fraud
webpage and has been updated for the 2024/25 exercise.

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3. NFI delivery 12
Exhibit 4. 
Auditor assessments of NFI delivery arrangements
Amber and red assessments were up slightly in 2022/23.
Source: Audit Scotland analysis of Auditor Returns
Percentage
Satisfactory
Mostly adequate
Unsatisfactory
0 10 20 30 40 50 60 70 80 90 100
Colleges 2022/23
Colleges 2020/21
Colleges 2018/19
CG 2022/23
CG 2020/21
CG 2018/19
NHS 2022/23
NHS 2020/21
NHS 2018/19
LG 2022/23
LG 2020/21
LG 2018/19

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3. NFI delivery 13
18. Exhibit 5 shows the main determinants of successful NFI delivery that
participating bodies should be focusing on to strengthen their arrangements.
Exhibit 5. 
NFI participation – main determinants of success
Successful delivery of NFI requires a clear commitment to a well-thought-out
approach that optimises the use of available resources to follow up matches
appropriately.
Source: Audit Scotland
19. Audit Scotland will continue to work with bodies to support effective
and efficient delivery of NFI through its ongoing engagement activities.
Knowledge Resources
Leadership
Effective
NFI delivery

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144. Specific match areas
4. Specific match areas
NFI outcomes have increased in most data match areas in
2022/23. However, savings from council tax single person
discounts decreased slightly, and increases in some areas
are partly due to changes in estimation methodologies.
Payroll
20. The number of payroll and multi-contract working frauds identified
as a result of the NFI has increased. There were 12 cases identified in
2022/23. This is the highest number since 2016/17, which is the last
exercise for which immigration data was matched. Overpayments and
case numbers for the 2022/23 exercise are shown alongside those for
the three previous exercises at Exhibit 6.
Exhibit 6. 
Payroll outcomes and case numbers by NFI exercise
There has been an increase in the level of identified fraud in 2022/23.
Note. Notional outcomes of £5,685 per case are allocated where staff resign or have been 
dismissed (Appendix).
Source: NFI management information
0
80
140
2022/232020/212018/192016/17
0
8
16
2022/232020/212018/192016/17
Number of cases
Overpayments
£ thousand
13
8
3
12
£20,000
£129,000
£27,000
£100,000
Notional outcomes

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4. Specific match areas 15
Creditor payments
21. Participating bodies submit details of payments made to people or
organisations supplying them with goods and services. Data is matched
by the NFI to identify potential duplicate payments. Bodies identifying
duplicate payments often refresh procedures and tighten controls to
reduce future risk.
22. In 2022/23 outcomes worth £0.75 million were identified from 146
duplicate payments across 31 bodies. This is broadly in line with previous
exercises as shown in Exhibit 7.
Exhibit 7. 
Duplicate creditor payment savings and case numbers by NFI exercise
£0.75 million of recoverable duplicate creditor payments was identified in 2022/23.
Source: NFI management information
0
0.6
1.2
2022/232020/212018/192016/17
Number of duplicate
payments
Overpayments
£ million
168
147 144 146
£0.6m
£1.1m
£0.5m
£0.75m
130
150
170
2022/232020/212018/192016/17

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4. Specific match areas 16
Adult Concessionary Bus Travel
23. Following a successful pilot exercise in 2020/21, adult concessionary
bus travel mortality screening was rolled out to councils in 2023. The
National Entitlement Card Project Office, working in partnership with
councils, submitted details of all live travel passes for matching.
24. The NFI identified 99,600 travel passes that belonged to holders who
had died. Transport Scotland was able to check usage of these passes
and identified that 1,075 had been used after the date of death.
25. The full fare value of fraudulent bus trips associated with these
passes amounted to £0.31 million, with a cost to Transport Scotland of 
around £0.18 million, based on the applicable reimbursement rates to 
bus companies.
26. The cancellation of these passes will prevent future fraudulent use
with an estimated value of £0.45 million (based on £420 per travel pass
used fraudulently, see Appendix (page 26). The resultant saving to
Transport Scotland is estimated at around £0.25 million based on current
reimbursement rates.1
Council Tax Single Person Discounts
27. People living on their own, or in some cases with adults who can
be ‘disregarded’, are eligible for a 25 per cent single person discount
(SPD) on their annual council tax bill. The NFI matches SPD recipients to
the electoral register and to other datasets to identify where other adult
residents have not been declared on applications, have subsequently
turned 18 or have moved in.
28. Councils withdrew £1.8 million worth of SPDs because of the NFI.
The additional income, based on a forward projection of annual savings
for two years, in line with the Cabinet Office methodology, equates to an
additional £2.7 million. These amounts are shown together and alongside
savings for the previous three exercises in Exhibit 8 (page 17).
29. Only 19 councils recorded NFI activity in relation to SPDs, as more
councils are now making use of third party providers for data matching
and follow-up. Seven councils using third-party providers now record no
NFI outcomes (an increase of two from the previous exercise).
1   Total outcomes for this area (Exhibit 2) includes a notional amount
of £0.91 million relating to the pilot exercise in 2020/21 (based on the
Cabinet Office methodology at the time which applied £550 to each
travel pass cancelled).

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4. Specific match areas 17
Exhibit 8. 
Council Tax SPD savings and case numbers by NFI exercise
Case numbers and savings from single person discounts decreased in 2022/23.
Source: NFI management information
Thousand
4,846 4,588
3,720 3,419
1.8
2.6 2.7
Case numbers0
3
6
2022/232020/21 2018/19 2016/17 
0
3
6
2022/232020/212018/192016/17
£4.4m 
£4.9m 
£4.6m  £4.5m
3.1
1.8
2.8
1.5
2.9
1.7
2.7
1.8
Forward savings estimate
Discounts removed
£ million
Council Tax Reduction Scheme (CTRS)
30. Council tax reduction is available to low-income households in
Scotland. The NFI matches CTRS data to other datasets, such as payroll
and pensions, for example, to identify undeclared income.
31. In 2022/23, additional council tax income of £0.92 million was
identified because of follow-up on NFI matches (up from £0.65 million
in 2020/21). Savings and case numbers are shown alongside those from
the previous three NFI exercises in Exhibit 9 (page 18).

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4. Specific match areas 18
32. Actual additional income from the removal of council tax reductions
has increased, as have forward savings estimates. The forward savings
estimate methodology has, however, changed with savings now based
on 33 weeks, compared to the 21 weeks previously used.
Exhibit 9. 
Council Tax Reduction Scheme savings and case numbers by NFI exercise
Total potential savings from CTRS have increased to £0.92 million in 2022/23.
Source: NFI management information
115
280
772
395
Case numbers0
400
800
2022/23 2020/212018/192016/17
0.0
0.5
1.0
2022/232020/212018/192016/17
£0.48m 
£0.30m 
£0.65m 
£0.92m
0.08
0.23
0.09
0.38
0.12
0.53
0.23
0.69
Forward savings estimate
Reductions removed
£ million
33. Only 18 councils identified savings from CTRS, with most savings
arising from matches to pensions (around 40 per cent) and payroll (around
30 per cent), where income had not been declared.

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4. Specific match areas 19
Housing Benefits
34. Housing benefits (HB) help people on low incomes pay their rent.
HBs in payment continues to decrease as more benefit recipients move
on to universal credit.
35. The DWP’s Verify Earnings and Pensions alerts service has also
impacted HB savings from NFI as alerts are sent directly to councils for
investigation, allowing them to follow up outside the NFI process. We no
longer match HB to payroll and pension as part of the NFI.
36. There has, however, been an increase in reported savings in
2022/23 due to the inclusion of late DWP savings from the 2020/21
exercise which was affected by Covid-19. Exhibit 10 shows the HB
overpayments and forward savings reported for the current and previous
three NFI exercises.
Exhibit 10. 
Housing Benefit savings by NFI exercise
2022/23 includes significant late DWP savings from the 2020/21 exercise.
Source: NFI management information
0.0
1.5
3.0
2022/232020/212018/192016/17
£2.1m
£2.8m 
£1.2m
£2.2m
2.1
0.7
1.4
0.7
0.3
0.9
0.4
1.8
Forward savings estimate
Overpayments
£ million
37. HB matches involving suspected fraud are referred to the DWP for
investigation and resultant savings are not attributed back to councils.
In 2022/23 almost £2 million of savings arose from these referrals. £0.2
million of savings was identified locally by 17 councils, largely from the
follow-up of matches to student loans.

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4. Specific match areas 20
Exhibit 11.
Pensions savings by NFI exercise
Follow-up activity and recording of outcomes in 2020/21 was impacted by Covid 19.
Source: NFI management information
0
3
6
2022/232020/212018/192016/17
£5.4m
£3.2m 
£1.5m
£5.6m
2.8
0.40.7
4.8
0.1
1.4
5.1
0.5
Estimated forward savings
Actual overpayments
£ million
Pensions
38. The NFI is an efficient and effective way for the Scottish Public
Pensions Agency (SPPA) and councils that administer pensions to check
that they are only paying pensions to people who are alive.
39. The follow-up of matches has led to the identification of actual
overpayments of £0.5 million as at 31 March 2024, with projected
forward savings amounting to a further £5.1 million. These savings are
shown along with those reported for previous exercises in Exhibit 11.
40. Forward savings are estimated based on a potential payment period
from the date overpayments are identified until the date the deceased
pensioner would have reached the age of 85 (consistent with actuarial
assumptions used to value public sector pension schemes).
41. In 2022/23 we have seen improved follow-up of pensions matches.
However, not all overpayments identified had been recorded by 31 March
2024. Late savings will be reported as part of the 2024/25 exercise as 
a result.

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4. Specific match areas 21
Exhibit 12.
Blue Badges outcomes and case numbers by NFI exercise
There have been higher levels of recorded cancellation in 2022/23 than for 
recent exercises.
Source: NFI management information
0.0
2.0
4.0
2022/232020/212018/192016/17
Badges cancelled
Notional outcomes
£ million
Thousand
4,505
3,215
4,616 5,140
£1.8m
£2.6m £2.7m
£3.3m
0
3
6
2022/232020/212018/192016/17
Blue Badges
42. The Blue Badge scheme allows individuals with mobility problems
to park for free at on-street parking meters, in ‘pay and display’ bays, in
designated Blue Badge spaces, and on single or double yellow lines in
certain circumstances. Badges are sometimes used by unauthorised
persons after the badge holder has died. Not only is this an offence under
the Disabled Persons’ Parking Badges (Scotland) Act 2014, but it may also
result in parking spaces being denied to people who legitimately use the
Blue Badge scheme.
43. The NFI matches Blue Badges issued to records of deaths, enabling
badges to be cancelled. The number of badges cancelled in 2022/23 has
gone up to 5,140, as shown at Exhibit 12.

Page 26

4. Specific match areas 22
44. The increased number of cancellations, together with a new estimate
multiplier, has resulted in a higher notional outcome value. The Cabinet
Office estimation methodology now applies £650 per badge cancelled
(compared to £575 per badge in 2020/21).
Housing Tenancy
45. With reported housing shortages and high levels of homelessness,
tenancy fraud is increasingly an issue for councils. Where fraudulent
subletting exists, it means that properties are not available to house
people who are in most need and this can be costly to councils.
46. The NFI uses council housing tenancy data to identify possible cases
where tenants may have sublet their property. It also helps identify cases
where the tenant has died, and the property is either empty or has other
individuals living in it.
47. As a result of the 2022/23 exercise, councils were able to identify and
recover ten properties. A housing association property was also identified
and made available for social housing. The numbers of properties
recovered along with the notional outcome estimates for the last four
exercises are shown at Exhibit 13 (page 23).
48. Notional outcomes of £78,300 are allocated per property recovered
(£93,000 in 2020/21). This is based on an average four-year fraudulent
tenancy and includes estimated costs of temporary accommodation for
genuine applicants; legal costs to recover property; re-let cost; and rent
foregone during the void period between tenancies.
49. In addition to recovery of properties, NFI has enabled several councils
to update tenancy details where there has been legitimate succession
following a bereavement.

Page 27

4. Specific match areas 23
Exhibit 13.
Housing Tenancy outcomes and case numbers by NFI exercise
Tenancies recovered as a result of NFI have remained in double figures in 2022/23.
Source: NFI management information
0.00
0.50
1.00
2022/232020/212018/192016/17
£ million
2 1
10 11
£0.09m
£0.19m
£0.93m £0.86m
Notional outcomes
Tenancies recovered0
6
12
2022/232020/212018/192016/17
Housing Waiting Lists
50. Councils maintain waiting lists for council housing, and in some
cases for all social housing in their area. The NFI matches waiting list
data to housing tenancy data and other data sets, enabling undisclosed
changes in circumstances to be picked up. This enables removal of
ineligible applicants from the waiting list, stops inappropriate allocations,
and accelerates allocations to people in genuine need of social housing.
51. In 2022/23 we have seen an increase in the number of applicants
removed from waiting lists as a result of NFI. Notional outcomes have
also increased as shown in Exhibit 14 (page 24).

Page 28

4. Specific match areas 24
52. Notional outcomes are attributed to applicants removed from the
waiting list on the basis that social housing could have been allocated
inappropriately. The estimation methodology allocates £4,283 per case
removed from the waiting list (an increase from £3,240 per application in
2020/21).
Exhibit 14.
Housing Waiting List outcomes and case numbers by NFI exercise
More applicants have been removed from the waiting list in 2022/23 than in 
previous exercises.
Source: NFI management information
0.0
0.8
1.4
2022/232020/212018/192016/17
£ million
90
230
187
280
£0.7m
£0.3m
£0.6m
£1.2m
Notional outcomes
Applicants removed
from waiting list0
150
300
2022/232020/212018/192016/17

Page 29

255. Pilot exercises and future developments
5. Pilot exercises and future
developments
Social Security Scotland took part in a pilot data-matching
exercise which identified limited fraud and error. We 
are also exploring the possibility of involving wider 
public sector bodies in the 2024/25 NFI exercise on a
voluntary basis.
Social Security Scotland – benefits pilot 2022
53. In 2022 a pilot exercise was undertaken with Social Security Scotland
(SSS) to identify any instances where claimants received support but
were not residing in Scotland, or where claimants appear to have claimed
benefits more than once (eg, from more than one Scottish address). The
pilot exercise included payments made in the three-month period from
April to June 2021.
54. Around 45,000 lines of data relating to benefit payments were
submitted for matching, resulting in the identification of 367 claimants
who appeared to be residing outwith Scotland. Following review and
corroboration of addresses by SSS there were just 17 cases where
claimants were not entitled to benefits. Overpaid benefits of £16,450
were identified, a further £20,000 could have been paid out in relation to
these claims, over the remaining eligibility periods.
55. Despite the identification of fraud and error, the number and value
of cases was not deemed sufficient to justify the inclusion of this match
type in the main biennial NFI exercise in 2022/23. The intention is to
run another pilot in 2024/25 which may also include Adult Disability
Payments for the first time.
Inclusion of bodies on a voluntary basis
56. There are potential benefits from expanding the NFI to include 
more public sector bodies in Scotland. We invited Scottish housing
associations and universities to participate in the 2024/25 NFI on a
voluntary pilot basis.
57. While no universities have volunteered for participation, we are
working with several interested housing associations. At this time, it is
unclear how many of those interested will actually participate.

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26Appendix
Appendix
Estimated outcomes methodologies
In some cases NFI outcomes include an estimated
element for forward savings or for where no
monetary value can be recovered
The NFI uses the term ‘outcomes’ to refer to the financial value of fraud,
error and overpayment that can be attributed to NFI data matching. In
some cases NFI outcomes include an estimated element which seeks 
to capture:
• The value of loss from a fraud or error detected because of an NFI
match, in instances where no monetary value can be recovered -
such as the value of recovering a property from a tenant who has
fraudulently obtained that tenancy. We have called these ‘notional
outcome estimates’ in our report.
• The value of any future losses that may have been incurred without
intervention as a result of an NFI match. For example, the value
of future overpayments prevented through detecting and stopping
a fraudulent or erroneous housing benefit claim. We have called
these ‘forward savings’ in our report.
Most NFI datasets have a methodology to calculate estimated outcomes.
These methodologies account for:
• data relevant to the fraud problem, including national published data
and data from previous NFI cases
• the policy context relative to the fraud problem
• any regional variances that may result in the generation of estimate
methodologies specific to a region or area
• alignment where possible with relevant estimated savings
methodologies used in other central government departments.
All methodologies are reviewed prior to the start of each new NFI
exercise. Any changes are reviewed by the Cabinet Office NFI
Governance Board and approved by the Cabinet Office Fraud Prevention
Panel. This panel consists of cross government counter fraud experts
(including representatives from DWP, HMRC, NHS, MOD, BEIS, DFID,
NAO, etc.) who review and challenge, where necessary, methodologies
for calculating the estimated value of fraud prevention initiatives across
government departments.

Page 31

Appendix 27
Once approved, these methodologies are built into the NFI web
application to enable the estimated outcomes element to be
automatically generated.
A summary of the outcomes methodology calculations applied to NFI
datasets is set out in the following table:
Data match 
Basis of calculation of forward savings and 
estimated outcomes 
Council tax single 
person discount 
Forward savings – Annual value of the discount cancelled
multiplied by two years. 
Council tax 
reduction scheme
Forward savings – Weekly change in council tax discount
multiplied by 33 weeks (increased from 21 weeks in 2020/21).
Housing benefit  Forward savings – Weekly benefit reduction multiplied by 
21 weeks. 
Pensions  Forward savings – Annual pension multiplied by the number of
years until the pensioner would have reached the age of 85.
Housing Tenancy Notional outcomes – £78,300 per property recovered, based
on average four–year fraudulent tenancy. Includes: temporary
accommodation for genuine applicants; legal costs to recover
property; re–let cost; and rent foregone during the void period
between tenancies (reduced from £93,000 in 2020/21).
Housing waiting lists Notional outcomes – £4,283 for each case based on the annual
estimated cost of housing a family in temporary accommodation,
the duration a fraud may continue undetected and the likelihood a
waiting list applicant would be provided a property (increased from
£3,240 in 2020/21).
Blue Badges  Notional outcomes – Number of badge holders confirmed
as having died multiplied by £650 to reflect lost parking and
congestion charge revenue (increased from £575 in 2020/21).
Concessionary bus travel Forward savings – Number of bus passes used fraudulently
multiplied by £420. Based on average fraudulent use and
reflecting two years forward use.
Payroll   Notional outcomes – £5,685 for each employee dismissed or
resigns as a result of NFI matching. (up from £5000 in 2020/21).

Page 32

The National Fraud
Initiative in Scotland
2024
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500 Email: info@audit.scot
www.audit.scot
ISBN 978 1 915839 46 6

Page 33

Appendix 2
National Fraud
Initiative
2022/2023 
Renfrewshire Council
Summary of arrangements and outcomes

Page 34

1. INTRODUCTION 
The National Fraud initiative is a biennial data matching exercise run by the UK Cabinet
Office and overseen in Scotland by Audit Scotland. It supports the Council’s commitment
to protecting public funds and preventing and detecting fraud.
Each local authority across the UK alongside other government organisations such as the
NHS and Department for Work and Pensions participate under the relevant Public Finance
legislation, which in Scotland is the Public Finance and Accountability (Scotland) Act 2000.
Information Security
Participation in the exercise is communicated across the Council’s social media platforms
to inform our customers and staff.  All information is shared and stored in line with the
Council’s privacy policy.

Page 35

2. PROCESS 
All matches generated from the data matching exercise require an outcome.  To
allow Audit Scotland and the Cabinet Office to report accurately across all
organisations involved the outcomes available are prescribed and used by all
organisations. 
Possible outcomes 
Updates for 2022/24
The Cabinet Office have included 1 new area for investigation – Adult concessionary
bus travel (not our responsibility to investigate) and postponed Non-Domestic Small
Business Bonus Scheme matching due to the national NDR revaluation exercise in
2023.
External Auditor Assessment of Arrangements
Our external auditors have stated in their Renfrewshire Council Group Annual
Accounts 2023/24 in relation to 2023/24 NFI exercise that :- 
The most recent NFI exercise was for 2022/23. There has been a good level of follow-up activity at
Renfrewshire Council  with 100% of Very High Risk matches processed in most areas. As of March
2024, all reports have been closed except for two which the Council is waiting for further information
from.
The audited body has engaged well with the NFI exercise. The Council had a good level of follow up
activity, meaning that most matches have been closed down. In addition, the body has strong
governance arrangements in relation to communication and transparency of NFI. 
No savings identifiedClosed - Already known
•These are matches that after investigation it is identified that the information available in the match
has already been reported and acted on within the time of the data being uploaded and the match
being released.
No savings identifiedClosed - No Issue
•After investigation the information received from the match has no impact on the benefit or service
received.
Savings identifiedClosed - Error
•Savings are identified however the cause is considered to have been error and not fraud. 
Savings identifiedClosed - Fraud
•A full investigation is carried out and evidence is identified to indicate that a material benefit was
gained by the failure of the subject to declare information
No savings identfiedClosed - Not selected for investigation
•The match details do not offer sufficient evidence to allow for an investigation
No savings identifiedClosed - referred to DWP
•The match information relates primaily to state benefits that require to be investigated by the DWP.

Page 36

2. PROCESS 
All required datasets were exported in September 2022 and submitted to the
National Fraud Initiative web portal.
The National Fraud Initiative data matching cases were released on the web portal in
January 2023.
The matches are categorised by the fraud risk area and risk score.  The risk score
matrix has been designed by the Cabinet Office and is established to assist
organisations to prioritise the resources required to carry out the match investigation
to those most likely to identify savings and error or fraud.
Renfrewshire Council process 
2022 
All
Matches
2022
High
Risk
2020
All
Matches
Housing Benefit claimants 67 51 85
Payroll 103 52 105
Housing Tenants 828 369 316
Blue Badge Parking Permit 524 524 522
Housing Waiting List 79 55 191
Council Tax Reduction Scheme 770 405 1326
Creditors 822 74 2160
Procurement 92 31 66
Business Rates 183 183 127
Business Grants N/A N/A 3    
cumulative total 3468 1744 4901
Analysis of Renfrewshire council NFI matches 2022/24 
Matches allocated ‘high risk’ status are prioritised for investigation.  
Blue Badge Parking Permit matches and Creditor matches are passed to the service
to assess and any suspected fraud escalated to the Counter Fraud team to pursue.
Housing Tenant matches saw the most significant increase in total number of
matches from the previous exercise in 2020/21 and this was as a result of new
matches to the data supplied by HMRC.

Page 37

3. RESULTS 
2022/23 Fraud and error identified by Renfrewshire Council Staff
Fraud Area No. of
cases
Actual
Overpayment
Estimated
Savings
CTRS1 40 £55,711 £13,753
HB2 1 £16,527 £3,925
Housing Tenancy 2 N/A3 £156,600
Waiting List 11 N/A £46,753
Procurement 0 0 N/A
Payroll 0 0 N/A4
Blue Badge 152 N/A £98,800
Creditors 0 0 N/A
NDR5 16 £104,117 £83,451
CT Discount6 534 £224,843 £406,414
All 756 £401,199 £810,056 
Overall outcomes are down slightly from the previous exercise. The main reason for
this is that for the matches that the Counter Fraud Staff investigate, a lot of work was
undertaken during the previous exercise to investigate and close down a lot of the
lower risk matches to prevent them from being listed again in this exercise.  We were
able to undertake this work as it was during the pandemic and some of our other
work could not be undertaken as a result of the restrictions in place. 
The financial savings in excess of £401,000 are set to be recovered following the
Council’s usual debt recovery processes.
Our participation in the 2022/23 NFI exercise is estimated to have prevented further
financial loss to Renfrewshire Council in excess of £810,000. 
1 Council Tax Reduction Scheme
2 Housing Benefit
3 There are no Actual Overpayments recorded for Housing Tenancy, Waiting List and Blue Badge fraud and error cases
4 There are no Estimated Savings recorded for Payroll and Creditors fraud and error cases
5 Non-Domestic Rates / Business Rates
6 Council Tax Discounts

Page 38

Self-Appraisal for NFI 2024/25 – Appendix 3
Part A: For Those Charged with Governance:
Leadership, Commitment and Communication Yes/No/Partly Is Action
Required?
1. Are we aware of emerging fraud risks and have we taken
appropriate preventative and detective action?
Yes - National Anti-Fraud Network and other anti-fraud network alerts are
subscribed to and monitored for emerging fraud risks. Attendance at regular
SLAIG/SLACIAG meetings provide opportunity for the sharing of best
practice across local authorities to improve and develop preventative
controls and detective methods.
No
2. Are we committed to NFI? Has the council/board, audit
committee and senior management expressed support for
the exercise and has this been communicated to relevant
staff?
Yes - Counter Fraud Team work jointly with operational services to
investigate matches. Training is provided to operational teams and NFI
outcomes reported to the CMT and the Audit, Risk and Scrutiny Board.
No
3. Is the NFI an integral part of our corporate policies and
strategies for preventing and detecting fraud and error. And
do we make reference to NFI in our governance codes and
statements?
Partly - There is a Counter Fraud Policy in place, and it is incorporated into
the Counter Fraud Business Plan.
Reference to NFI will be added to Corporate Code of Governance.
Yes:
Interim
Chief
Auditor -
31/03/25
4. Does our Key Contact have sufficient authority and time
to ensure that NFI is delivered effectively?
Yes. No
5. Has the approach to follow up of different NFI match
types been clearly set out and reported as part of the bodies
NFI planning process?
Yes - We review high risk matches in the first instance and then undertake a
risk analysis to decide what our approach will be for the remainder of the
matches.
No

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Self-Appraisal for NFI 2024/25 – Appendix 3
6. Are NFI progress and outcomes reported regularly to
senior management and elected/board members (eg, the
audit committee or equivalent)?
Yes - Counter fraud activity outcomes, including NFI results are reported
quarterly alongside the outcome and performance report presented to the
Audit, Scrutiny and Risk board.  Audit Scotland's NFI reports are shared with
Senior Management.  The overall NFI outcomes and results are reported at
the end of the biennial exercise.
No
7. Where we have not submitted data or used the matches
returned to us (eg, council tax single person discounts), are
we satisfied that alternative fraud detection arrangements
are in place and that we know how successful they are?
Yes - Risk based assessment of matches, high risk matches given priority. We
have established regular data matching exercises in regard to Housing
Waiting List, Licensing and Council Tax discounts and Reductions.  Revenues
and Benefits have recently established a Review Team which will carry out
checks and reviews aimed at ensuring accuracy in Council Tax discounts and
reductions.  The effectiveness of data matching exercises is demonstrated in
the outcomes and corrections identified; these are reported as part of the
quarterly reports to board.
No
8. Does internal audit, or equivalent, monitor our approach
to NFI and our main outcomes, ensuring that any
weaknesses are addressed in relevant cases?
Yes - Internal Audit is responsible for co-ordinating the exercise and
regularly review outcomes identified.   The findings from the NFI are
considered as part of Internal Audit annual planning.
No
9. Do we review how frauds and errors arose and use this
information to improve our internal controls?
Yes - This is considered in the annual audit planning.  Meetings are held with
the appropriate parties where issues are identified to improve internal
controls.
No
10. Do we need and have access to fraud investigation
officers to enable frauds to be followed up fully?
Yes - Counter Fraud officers are part of the Internal Audit Team. No
11. Do we publish, as a deterrent, internally and externally
the achievements of our fraud investigators (e.g. successful
prosecutions)?
Yes - Report to members of the Audit, Risk and Scrutiny Board. Other
publicity is considered on a case-by-case basis.
No

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Self-Appraisal for NFI 2024/25 – Appendix 3
Part B: For NFI Key Contacts & Users
Leadership, Commitment and Communication Yes/No/Partly Is Action
Required?
1. Are we aware of emerging fraud risks and taken
appropriate preventative and detective action?
Yes - NAFN and other anti-fraud network alerts are subscribed to and
monitored for emerging fraud risks. Service departments are made aware of
any fraud risks we are alerted to. Attendance at regular SLAIG/SLACIAG
meetings provide opportunity for the sharing of best practice across local
authorities to improve and develop preventative controls and detective
methods.
No
2. Are we investing sufficient resources in the NFI exercise? Yes - Time is included in the counter fraud work and audit plan and regular
engagement with services through counter fraud team monitoring.
Revenues and Benefit services have included NFI match investigation in their
work plan.
No
3. Do we plan properly for NFI exercises, both before
submitting data and prior to matches becoming available?
This includes considering the quality of data and being clear
about the approach to follow up of different match types.
Yes - Full planning process and detailed action plan in place. Resource made
available within the Counter Fraud Team to prepare for the upload of data
to the NFI portal this includes a quality check of the data prior to upload.
No
4. Where NFI outcomes have been low in the past, do we
recognise that this may not be the case the next time, that
NFI can deter fraud and that there is value in the assurances
that we can take from low outcomes?
Yes - Considered as part of risk-based assessment and consideration given to
the deterrence our involvement has in the NFI exercise on potential fraud.
No
5. Do we confirm promptly (using the online facility on the
secure website) that we have met the fair processing notice
requirements?
Yes - Deadline met. No
6. Do we plan to provide all NFI data on time using the
secure data file upload facility properly?
Yes - Detailed action plan in place to ensure compliance, this has been
successfully fulfilled in previous exercises.
No

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Self-Appraisal for NFI 2024/25 – Appendix 3
Part B: For NFI Key Contacts & Users
Effective Follow Up of Matches Yes/No/Partly Is Action
Required?
7. Do all departments involved in NFI start the follow up of
matches promptly after they become available?
Yes - Monitored by Internal Audit and any resource difficulties are discussed
with the service and the Director of Finance & Resources.
No
8. Do we give priority to following up high-risk matches,
those that become quickly out of date and those that could
cause reputational damage if a fraud is not stopped quickly?
Yes - Risk based assessment of matches. High risk matches are prioritised,
consideration is also given to matches that may cause increased hardship if
further delay in correction.
No
9. Are we investigating the circumstances of matches
adequately before reaching a ‘no issue’ outcome, in
particular?
Yes. No
10. Are we drawing appropriately (in health bodies) on the
help and expertise available from NHS Scotland Counter
Fraud Service?
N/A N/A
11. Are we taking appropriate action in cases where fraud is
alleged (whether disciplinary action, penalties/cautions or
reporting to the Procurator Fiscal)? Are we recovering funds
effectively?
Yes - All relevant actions are considered. No
12. Do we deploy resources in proportion to risks, and scale
down work on match reports where early work has not
found any fraud or error?
Yes - Risk based assessment of matches, where high risk matches show no
fraud or error low risk matches are not considered for investigation. 
However, this is reviewed on a report-by-report basis and where there is a
potential for hardship or reputational damage consideration is given to
deploying resources to investigate low risk matches.
No
13. Where the number of high-risk matches is very low, are
we adequately considering the medium and low-risk
matches before we cease our follow-up work?
Yes - We will undertake a small sample of medium and low risk matches to
determine if we are likely to get any outcomes.
No
14. Overall, are we deploying appropriate resources on
managing the NFI exercise?
Yes - Any resourcing issues are discussed with the Service and Director of
Finance & Resources as appropriate. Counter Fraud resources are
committed within the workplan to the NFI exercise.
No

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Self-Appraisal for NFI 2024/25 – Appendix 3
Part B: For NFI Key Contacts & Users
Effective Follow Up of Matches Yes/No/Partly Is Action
Required?
15. Are we recording outcomes properly in the secure
website and keeping it up to date?
Yes - Monitored by Internal Audit No
16. Do staff use the online training modules and guidance on
the secure website, and do they consult the Cabinet Office
NFI team if they are unsure about how to record outcomes
(to be encouraged)?
Yes - Training is provided to staff responsible for following up matches,
training includes notifying of online training modules and videos available on
NFI web application.
No
17. If, out of preference, we record some or all outcomes
outside the secure website, have we made arrangements to
inform Audit Scotland and the Cabinet Office NFI team about
these outcomes?
Yes - This is included in the Report notes. No