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AS Report - National Fraud Initiative

Renfrewshire Council · 14 November 2022
Back to Audit, Risk and Scrutiny Board — 14 November 2022 and its agenda

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___________________________________________________________________
To: Audit, Risk and Scrutiny Board
On: 14 November 2022
___________________________________________________________________
Report by: Chief Auditor
___________________________________________________________________
Heading: Audit Scotland Report – The National Fraud Initiative 2020/2021 
___________________________________________________________________
1. Summary
1.1 Audit Scotland’s report on the National Fraud Initiative (NFI) 2020/21
was published in August 2022 and is attached at Appendix 1.
1.2 The report highlights that Scottish public bodies have recorded outcome
of £14.9 million arising from the 2020/21 exercise. Cumulative outcomes
from NFI since 2006/07 in Scotland have risen to £158.5 million and £2.4
billion across the UK. The NFI outcome figures include amounts for fraud
and error detected as well as an estimate for those future losses that
have been prevented.
1.3 Renfrewshire Council’s approach and outcomes for the 2020/21
exercise and how this compares to the 2018/19 exercise is attached at
Appendix 2. Our self-assessment of our arrangements in preparation for
the 2022/23 exercise is also included within appendix 2.
___________________________________________________________________
2. Recommendations
2.1 It is recommended that the Audit, Risk and Scrutiny Board:
• note the report from Audit Scotland, and

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• note Renfrewshire Council’s current arrangements, outcomes
and self-assessment to support the 2022/2023 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 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 2020 and uploaded onto the secure NFI web portal in
October 2020, 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 in the NFI exercise should ensure that they maximise the
benefits of their participation. They should consider whether it is possible
to work more efficiently on the NFI matches by reviewing the guidance
section within the NFI secure web application. 
The Chief Auditor co-ordinates the NFI exercise in Renfrewshire Council. 
All officers involved in the submission of the data sets and investigation
of matches are provided with guidance, including being made aware of
the guidance section of the NFI web application. 
2. Self-appraisal 
The NFI self-appraisal checklist should be reviewed by the audit
committee, or equivalent, and staff leading the NFI process. This is to
ensure that their organisation’s planning, approach, and progress during
the next NFI exercise is appropriate.

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The Chief Auditor reviews the NFI self-appraisal checklist as part of the
planning arrangements for each NFI exercise. The result of the appraisal
are included in section 5 of the report summarising the council’s
arrangements and outcomes attached as Appendix 2 of this report, No
identified improvements in approach are considered necessary.
3. Take improvement action
Where local auditors have identified specific areas for improvement,
participants should act on these as soon as possible.
No specific areas of improvement in relation to the councils NFI 
3.4 The Council’s has made financial savings of £410,735 as a result of
investigative work on the 2020/2021 NFI matches and a further future
estimated savings of £1,640,731 have also been noted. Non-financial
outcomes relate to 9 housing properties being recovered, 92 housing
applications being amended or cancelled and 207 blue badges being
cancelled.  
___________________________________________________________________
Implications of the Report
1. Financial - The Council has in place arrangements to recover the any
financial overpayments payments 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

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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
___________________________________________________________________ 
Author:           Andrea McMahon, Chief Auditor

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The National 
Fraud Initiative
in Scotland 
2022
Prepared by Audit Scotland
August 2022

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Key messages
The National Fraud Initiative (NFI) is a counter-fraud exercise which aims to prevent and detect fraud. 
The exercise operates across the UK public sector and includes 132 public bodies in Scotland. The NFI
shares and matches data held by public bodies and helps confirm that services and payments are provided
to the correct people. See Appendix 1 for more information about the NFI exercise.
1 The 2020/21 NFI exercise has identified outcomes valued at £14.9 million (see page 4).
2 The cumulative outcomes from the NFI in Scotland since 2006/07 are now £158.5 million.
Across the UK, the cumulative total of NFI outcomes are now £2.4 billion (see page 4).
3 The overall level of fraud identified by the NFI has fallen since our last report. Outcomes from
the Scottish NFI exercise fell by £0.4 million in 2020/21, from £15.3 million in 2018/19. The
reduction in outcomes could be due to less fraud and error in the system, strong internal
controls or due to some key data sets from previous exercises not being included in the
latest exercise (see page 4).
4 Data sharing enables matches to be made between bodies and across national borders. Data submitted by Scottish bodies 
for the 2020/21 NFI exercise helped other organisations in Scotland and across the UK to identify outcomes of £1.2 million 
(see page 17).
5 Most bodies that participate in the NFI continue to demonstrate a strong commitment to counter fraud and the NFI 
(see page 18–19). However, a lower percentage of participating public bodies managed their roles in the 2020/21 NFI exercise
satisfactorily compared to the 2018/19 NFI exercise.
6 Pilot work to look at potential data matches for future NFI exercises identified £2.2 million in incorrect non-domestic rates relief.
The pilot work also identified one £25,000 fraudulent Covid-19 grant payment and 1,737 national entitlement travel cards which
should have been cancelled (see pages 20–23).
An NFI outcome 
describes the overall 
amounts for fraud,
overpayments and error
that are detected by the
NFI exercise as well as an
estimate of future losses that
it prevents (see Appendix 3).
The National Fraud Initiative in Scotland 2022 | 2 |

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Recommendations
1. Maximise the benefits
All participating bodies in the NFI exercise should ensure that they maximise the benefits of their participation.
This includes reviewing matches timeously and prioritising high-risk matches.
NFI users should review the guidance within the NFI secure web application, to help ensure the most effective
use of limited resources when reviewing and investigating NFI matches.
2. Self-appraisal
The NFI self-appraisal checklist should be reviewed by the audit committee, or equivalent, and staff leading
the NFI process. This is to ensure that their organisation’s planning, approach, and progress during the next NFI
exercise is appropriate.
3. Take improvement action
Where local auditors have identified specific areas for improvement, participating bodies should act on these as
soon as possible.
The National Fraud Initiative in Scotland 2022 | 3 |

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Outcomes from 2020/21 National Fraud Initiative
Trends in overall outcomes between 2018/19 and 2020/21 NFI exercises
4 cases
referred for prosecution
in Scotland 
NFI outcomes
UK NFI outcomes
£14.9 million
NFI outcomes in Scotland from
the 2020/21 exercise
£158.5 million
NFI outcomes cumulatively in
Scotland since 2006/07
£442.6 million
from the 2020/21 exercise
£2.4 billion
cumulatively since 2006/07
20/21 06/07
Since
20/21 06/07
Since
NFI participants include all councils, NHS bodies, colleges and all larger central government bodies,
for example, the Scottish Government, Revenue Scotland and Transport Scotland. In addition, 
14 councils include data from Arm’s-Length External Organisations (ALEOs), joint boards or
subsidiaries within their NFI submissions. A list of all participating bodies is available on our website.
Reduced levels of outcomes could be due to less fraud and error in the system, strong internal controls
or some key datasets from previous years not being included in the latest exercise. Residential care
home data, direct payments and social care customers’ data were not matched in the 2020/21 exercise
due to a legal question being raised around the definition of patient data. Immigration data was also not
included in the 2018/19 and 2020/21 exercises due to restrictions placed on it by the Home Office.
NFI participants have identified pressures on staffing and services particularly because of the 
Covid-19 pandemic, and the strengthening of controls where previous fraud or error has been
identified, as contributing to reduced outcomes in the 2020/21 exercise.
The number of public bodies
participating in the NFI
exercise has increased by
eight since the last exercise,
to 132 bodies.
The number of matches
generated has fallen by
over 73,000 since the last
exercise, to 507,354.
Outcomes in Scotland have
fallen by £0.4 million since
the last exercise, from 
£15.3 million to £14.9 million.
The National Fraud Initiative in Scotland 2022 | 4 |

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Having fewer outcomes provides some assurance there does not appear to be significant
problems in the areas covered by the exercise. However, participants still benefit from the
deterrent effect the NFI creates.
The fall in the number of matches is mainly due to the matches between housing benefit and
payroll or pensions not being included in the matches returned to councils during the 2020/21
NFI exercise. Instead, this data was matched in Department for Work and Pensions (DWP)
systems (see page 11). In addition, the removal of immigration, residential care home, direct
payments and social care customers’ data has also reduced the number of matches.
Four cases were referred to the Crown Office and Procurator Fiscal Service for prosecution. 
One resulted in Police Scotland issuing a caution and the offender is now repaying the money.
The outcomes from the other three cases are not yet known.
Although the main purpose of the NFI is to ensure funds and services are provided to the
correct people, the review of NFI matches may also identify that a customer is entitled to
additional services or payments.
A breakdown of the recorded outcomes for Scottish participants is on our Counter-fraud hub.
The National Fraud Initiative in Scotland 2022 | 5 |

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Results
Overall outcomes
How the latest outcomes compare to the last exercise
The areas with significant changes are:
NFI outcomes in Scotland have fallen
by £0.4 million, to £14.9 million in the
2020/21 exercise
Housing benef it Pensions
£ m
illion
Council tax Creditors Blue badges Housing Council tax
reduction scheme
Waiting lists
2018/19
2020/21
0
1
2
3
4
5
Housing
benefit
£1.6m
Pensions
£1.7m
Council tax
£0.3m
Creditors
£0.1m
Blue
badges
£0.9m
Housing
£0.8m
Council tax
reduction
scheme
£0.4m
Waiting
lists
£0.1m
The National Fraud Initiative in Scotland 2022 | 6 |

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NFI participants have cited the following reasons as to
why outcomes are less in the 2020/21 exercise:
• staff have had less time available to commit to NFI because of the
added pressures on services caused by the Covid-19 pandemic
• external agents were used instead of the NFI to carry out certain data
matching such as the council tax single occupant discounts
• new controls were introduced because of previous errors identified
through the NFI
• a new system was introduced for reporting the death of customers.
More information about the outcomes for each category is provided on
pages 8 to 15.
A full breakdown of outcomes for each participating body is available on
our Counter-fraud hub.
Once overpayments have been identified, public bodies can take
appropriate action to recover the money.
How NFI matches help to identify areas for improvement
The NFI exercise has helped participants to identify system weaknesses
and to make improvements. These include the introduction of:
• a more robust control environment in the creditors system. This
includes monthly purchase ledger reviews, improved checks on
new suppliers, and controls to identify duplicate payments and
duplicate suppliers
• revised procedures when setting up new suppliers
• a review and cleansing of data held in systems
• strengthened controls in the blue badge system
• improved controls around the change of bank details
• a review of policies aimed at supporting good governance such as
declaring interests, registering of conflicts of interest and checks for
identifying potential related parties.
(95%) of cash overpayments
were being recovered
At 31 March 2022
£4.3 million31
March
The National Fraud Initiative in Scotland 2022 | 7 |

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Council tax discounts
People living on their own, or with no countable adults in the household,
are eligible for a 25 per cent single person discount (SPD) on their annual
council tax bill.
Council tax data is matched to:
Electoral register
2014/15 2016/17 2018/19 2020/21 2014/15 2016/17 2018/19 2020/21
£5.6m
£4.4m
£4.9m
£4.6m
4,846 4,802 4,588
3,720
Outcomes
2014/15 2016/17 2018/19 2020/21 2014/15 2016/17 2018/19 2020/21
£5.6m
£4.4m
£4.9m
£4.6m
4,846 4,802 4,588
3,720
Cases
£4.6 million £1,248 3,720
Total outcomes 
in 2020/21 exercise
Average outcome Cases
The 2020/21 NFI exercise found that the total
council tax discount incorrectly awarded across
Scottish councils totalled £4.6 million.
Four councils reported that they did not use the
NFI and instead used alternative data matching
or verification arrangements to review SPD
cases during 2020/21. The graphs below include
outcomes from the other 28 councils.
Note. Due to an error with the data deletion
schedule in the Cabinet Office, some
supporting evidence for 11 councils was
inadvertently deleted. Therefore, full supporting
documentation is not available for these
councils. The Cabinet Office has taken steps 
to prevent this error from re-occurring.
The National Fraud Initiative in Scotland 2022 | 8 |

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Blue badges
The blue badge parking scheme allows people 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.
Blue badge data is matched to:
Deceased
persons
Amberhill
data1
1. Amberhill is a system used by the
Metropolitan Police to authenticate
documents presented for identity
£2.7 million 4,616 1,401
Total outcomes 
in 2020/21 exercise
Total number of blue
badge outcomes in
2018/19 exercise
Increase from NFI
2018/19 exercise
2014/15 2016/17 2018/19 2020/21 2014/15 2016/17 2018/19 2020/21
3,073
4,505
3,215
4,616
£1.8m
£2.6m
£1.8m
£2.7m
Outcomes
2014/15 2016/17 2018/19 2020/21 2014/15 2016/17 2018/19 2020/21
3,073
4,505
3,215
4,616
£1.8m
£2.6m
£1.8m
£2.7m
Badges
The 2020/21 NFI exercise identified 4,616 blue 
badge outcomes, an increase of 1,401 (44 per cent)
since the last exercise. The estimated value of 
these outcomes is £2.7 million.
Blue badges are sometimes used or renewed
improperly by people after the badge holder has
died. It is an offence for an unauthorised person 
to use a blue badge.
The National Fraud Initiative in Scotland 2022 | 9 |

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Pensions
The NFI provides both councils that administer pensions and the Scottish
Public Pensions Agency (SPPA) with an efficient and effective way of
checking that they are only paying people who are alive.
Pension data is matched to:
Deceased
persons Payroll Housing
benefit
Injury
benefits
Amberhill
data
In total, pension outcomes for the 2020/21 
NFI exercise are £1.5 million, down £1.7 million
(53 per cent) from the 2018/19 NFI exercise.
This includes two outcomes identified through
the pre-application screening (AppCheck)2 part 
of the NFI system.
Pension outcomes may have fallen due to the
‘tell us once’3 reporting process and to controls
working effectively within pension bodies.
Case study
An NFI match identified one
fraud with a gross annual pension
amount of £10,560 which was
stopped and resulted in an overpayment
of £6,601. The fraudster had notified
Fife Pension Fund of a change of bank
details for receipt of the pension after the
pensioner had died. The council reported
the fraud to Police Scotland which identified
the person who submitted the fraudulent
bank mandate. Following a police caution,
the full amount was repaid. This case was
reported as part of a 2020/21 NFI Progress
Update to both the council’s Standards and
Audit Committee and the Superannuation
Fund & Pensions Committee in December
2021 for their consideration.
2. AppCheck is an NFI data matching service
used at point of applications for a service
or benefit.
3. ‘Tell us once’ is a service that lets you report
a death to most government organisations
when registering the death.
£1.5 million £1.7 million
Total outcomes in 2020/21 exercise Reduction on the 2018/19 NFI exercise
2014/15 2016/17 2018/19 2020/21
£1.5m
£3.2m
£5.4m
£4.6m
Outcomes
The National Fraud Initiative in Scotland 2022 | 10 |

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Housing benefit
Housing benefit helps people on low incomes pay their rent. The NFI
provides councils and the DWP with the opportunity to identify a wide
range of benefit frauds and errors.
Housing benefit data is matched to:
Student loans Housing
benefit
Housing
tenants
Right to buy
(in England) Licences
Deceased
persons
Amberhill
data
2014/15 2016/17 2018/19 2020/21 2014/15 2016/17 2018/19 2020/21
£3.0m
£2.1m
£2.8m
£1.2m
868
710
1,238
177
Outcomes
2014/15 2016/17 2018/19 2020/21 2014/15 2016/17 2018/19 2020/21
£3.0m
£2.1m
£2.8m
£1.2m
868
710
1,238
177
Cases
The value and number of housing benefit cases
recorded with overpayments has significantly
reduced, from £2.8 million from 1,238 cases in the
2018/19 NFI, to £1.2 million from 177 cases in the
2020/21 NFI. Over the same period, the average
individual value of overpayments has risen from
£2,292 in 2018/19 to £6,663 in 2020/21.
The fall in outcomes is mainly due to the
matches between housing benefit and payroll or
pensions not being included in the 2020/21 NFI
exercise. These matches historically identified
significant outcomes.
These matches were not included in the
2020/21 NFI exercise as similar data matching
is undertaken by the DWP’s Verify Earnings and
Pensions (VEP) Alerts service which identifies
discrepancies between payroll and pension
details held by HM Revenues & Customs and
council benefits services. Alerts from VEP are
sent to councils to investigate discrepancies.
£1.2 million £6,663 177
Total outcomes 
in 2020/21 exercise
Average individual
value of overpayments
Cases
The National Fraud Initiative in Scotland 2022 | 11 |

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Housing tenancy
The NFI uses housing tenants’ data to identify possible cases of tenancy
fraud. This may happen when a tenant has 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.
Housing tenancy data is matched to:
Waiting list Housing benefit Housing tenants Right to buy 
(in England)
Deceased 
persons Amberhill data Council tax
reduction
NFI matches resulted in councils recovering ten
properties as part of the 2020/21 NFI exercise,
compared to one property in 2018/19.
The estimated value of these cases is 
£0.93 million, based on a calculation of the
average four-year fraudulent tenancy.
£0.9 million 10
Total outcomes in 2020/21 exercise Cases
Outcomes
Cases
2016/17 2018/19 2020/212016/17 2018/19 2020/21
2
1
10
£0.2m
£0.1m
£0.9m
Case study
An NFI match identified a
Midlothian Council tenant who
had failed to disclose that they
had purchased a property within another
council area at the same time they had
been allocated a council house. Enquiries
established the tenant moved into the
owned property ten years ago and sublet
their council house to a family member.
The council has recovered the property.
Outcomes Cases
The National Fraud Initiative in Scotland 2022 | 12 |

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Council tax reduction
Council tax reduction helps people on low incomes to pay their council tax
bills. The NFI provides councils with the opportunity to identify a range of
council tax reduction frauds and errors.
Council tax reduction data is matched to:
Council tax
reduction Payroll Pensions
payroll
Housing
benefit
Housing
tenants
Right to buy
(in England) Licences Deceased
persons Amberhill data
This is a relatively new match which has been
included in the NFI since 2016/17.
Outcomes of £0.7 million were identified in the
2020/21 NFI, an increase of £0.4 million from
the £0.3 million reported in 2018/19.
Councils have identified 772 cases in 2020/21,
more than 2.5 times the number of cases in
2018/19 (280).
One council advised that the increase in
outcomes was directly caused by the Covid-19
pandemic. For example, an increase in mortality
rates for those with underlying health conditions
disproportionately impacted on people in receipt
of disability benefits, council tax reduction and
blue parking badges. In addition, there was an
increase in the number of un-notified increases
in the hours worked by those in lower paid
service jobs who are more likely to be in receipt
of council tax reduction.
2016/17 2018/19 2020/21 2016/17 2018/19 2020/21
115
280
772
£0.5m
£0.3m
£0.7m
Outcomes
Cases
£0.7 million 772
Total outcomes in 2020/21 exercise Cases
Case study
An NFI match identified that a
council tax reduction claimant in
Renfrewshire Council had failed to
declare their company pension and pension
lump sum. This resulted in the claimant
fraudulently receiving £14,450 council tax
reduction. This amount is being recovered by
the council.
The National Fraud Initiative in Scotland 2022 | 13 |

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Housing waiting lists
The NFI uses housing waiting list data to identify possible cases of waiting
list fraud. This may happen when a person has registered on a council’s
waiting list but there are possible undisclosed changes in circumstances
or false information has been provided. Social housing provides affordable
accommodation, allocated according to need. It usually provides a more
secure, long-term tenancy when compared to private renting.
Housing waiting list data is matched to:
Waiting list Housing benefit Housing tenants Right to buy
(in England)
Deceased
persons Amberhill data
Councils identified 187 cases in 2020/21 
where applicants were removed from waiting
lists (230 in 2018/19).
The estimated value of these cases is 
£0.6 million. This is based on a calculation of
the annual estimated cost of housing a family
in temporary accommodation and the likelihood
a waiting list applicant would be provided a
property (see Appendix 3).
£0.6 million 187
Total outcomes in 2020/21 exercise Cases
2016/17 2018/19 2020/21 2016/17 2018/19 2020/21
90
230
187
£0.3m
£0.7m
£0.6m
Outcomes
2016/17 2018/19 2020/21 2016/17 2018/19 2020/21
90
230
187
£0.3m
£0.7m
£0.6m
Cases
The National Fraud Initiative in Scotland 2022 | 14 |

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Creditors
2014/15 2016/17 2018/19 2020/21 2014/15 2016/17 2018/19 2020/21
£0.7m
£1.1m
£0.6m
£0.5m
139
168
147 144
2014/15 2016/17 2018/19 2020/21 2014/15 2016/17 2018/19 2020/21
£0.7m
£1.1m
£0.6m
£0.5m
139
168
147 144
The NFI provides an efficient way to check for duplicate payments and that
payments are only made to appropriate creditors. A creditor is a person or
an organisation that a public body pays money to for a good or service.
Creditor data is matched to:
Creditor data Payroll
The 2020/21 NFI exercise identified 144 creditor
outcomes of £0.5 million, a fall of three outcomes
and £0.1 million from 2018/19. Recovery action is
taking place for these overpayments.
£0.5 million 100% 144
Total outcomes 
in 2020/21 exercise
Recovery action 
is taking place
Cases
Outcomes
Cases
The National Fraud Initiative in Scotland 2022 | 15 |

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Other data matches
Payroll
The NFI also matches all participating bodies’ employee payroll
data as well as those of MSPs and councillors to identify cases of
potential payroll fraud. The 2020/21 NFI exercise identified three
outcomes valued at £27,000 compared to eight outcomes valued 
at £20,000 in the 2018/19 exercise.
Past NFI exercises have identified larger outcomes for payroll. 
This fall in outcomes is partly due to immigration data not being
included in the 2020/21 exercise due to restrictions placed on it by
the Home Office.
2018/19
£20,000 £27,000
2020/21
three outcomes valued ateight outcomes valued at
Case study
An NFI match identified an employee who left Fife Council
in September 2019 and who continued to be paid their
salary until February 2021. The council overpaid a total of £20,288 to
the ex-employee. Recovery of the overpayment is in progress and
internal audit services have investigated the circumstance surrounding
the overpayment. Recommendations for improvements have been
discussed with management and an audit on the council’s leavers
process is part of the 2022/23 Internal Audit Plan. This case was
reported as part of a 2020/21 NFI Progress Update to the council’s
Standards and Audit Committee in December 2021 for consideration.
Case study
New NFI matching of non-domestic rates small business
bonus scheme (SBBS) in East Dunbartonshire Council
identified a case where a ratepayer had failed to declare other business
premises in another council area. This resulted in almost £11,000 in
SBBS relief being claimed from April 2018. The case is being referred
to the Crown Office and Procurator Fiscal Service for prosecution.
We understand this is the first business rates case to be reported for
prosecution in Scotland.
The National Fraud Initiative in Scotland 2022 | 16 |

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Councils Central 
government NHS Colleges Total
£601,591 £483,943 £100,456 £0 £1,185,990
2018/19 2018/19 2018/19 2018/19 2018/19
£854,760 £759,879 £120,408 £12,672 £1,747,719
Matches benefiting other public bodies
A key benefit of a UK-wide data matching exercise is that it enables matches to be made between bodies and across
national borders. For those public bodies taking part in the NFI which may not always identify significant outcomes from
their own matches, it is important to appreciate that other bodies and sectors may do so.
Most of these outcomes relate to housing benefits, housing waiting list
and council tax reductions where, for example, payroll data from an NHS
board may allow a council to identify a council tax reduction fraud or error.
Data provided by Scottish participants for the 2020/21 NFI exercise
helped other public bodies, both within and outwith Scotland, to identify
outcomes worth £1.2 million (a reduction of £0.5 million from 2018/19).
The National Fraud Initiative in Scotland 2022 | 17 |

Page 22

How bodies worked with the NFI in 2020/21
How bodies work with the NFI
Auditors reviewed each participating body’s planning and progress with the
NFI and provided recommendations for improvement where appropriate.
Overall rating of NFI arrangements by year
Local
government
2016/17
Local
government
2018/19
Local
government
2020/21
Central
government
2016/17
Central
government
2018/19
Central
government
2020/21
NHS
2016/17
NHS
2018/19
NHS
2020/21
Colleges
2016/17
Colleges
2018/19
Colleges
2020/21
Percentage
0
20
40
60
80
100
Satisfactory Mostly adequate Unsatisfactory
The National Fraud Initiative in Scotland 2022 | 18 |

Page 23

Most participating bodies continue to demonstrate a strong commitment
to counter fraud and the NFI. However, across all sectors, a smaller
percentage of participating bodies managed their roles in the 2020/21
NFI exercise satisfactorily compared to the 2018/19 NFI exercise.
Auditors identified that some bodies could be more pro-active in their
approach to the NFI. One central government body was unable to review
matches due to a cyber-attack, one council did not review matches
citing resource issues as the reason, and a central government body was
unable to action matches due to the impact of reallocating resources to
the provision of Covid-19 grant funding to organisations.
Six key contacts felt they did not have sufficient time and/or resources 
to allow them to oversee the NFI exercise. In four bodies, the key contact
considered that they lacked sufficient authority to seek action across the 
relevant departments.
The Covid-19 pandemic created additional pressures for public bodies
and impacted upon the resources available to support the NFI exercise.
Auditors reported that 15 bodies reduced their participation in the NFI
exercise due to resourcing issues including staff vacancies, sickness
absences or changing priorities as a result of Covid-19.
We recommend that all bodies use our checklist to self-appraise their
involvement in the NFI before and during the 2022/23 NFI exercise. 
For the 2020/21 NFI exercise, 64 per cent of bodies completed the
checklist, although not all presented it to their audit committee; 
ten per cent reviewed it but did not complete it; and just over a quarter
did not review it. This was reported as being because either the key 
NFI contact had changed and was unaware of the checklist, staff had
prior experience of the NFI process, and Covid-19 pressures.
A key contact is appointed by the NFI
participating body. They are responsible
for coordinating and monitoring the
overall NFI exercise, ensuring outcomes
from investigations are accurately recorded and
nominating appropriate users of the NFI system.
64%
26%
10%
completed the checklist
did not review it
reviewed it but did not complete it
Public bodies usage of our NFI checklist
20/21
The National Fraud Initiative in Scotland 2022 | 19 |

Page 24

Pilots help identify the value 
of extending the NFI exercise
Audit Scotland undertakes new areas of data matching on a
pilot basis to test their effectiveness in identifying fraud.
Only pilots which achieve matches that demonstrate a significant level
of success are extended nationally and included in the main NFI exercise
going forward. A small number of serious incidents of fraud or a larger
number of less serious ones may both be considered successful.
The NFI pilots undertaken or under way over the last two years are
shown on the following pages.
Exemptions for NHS dental
and ophthalmic charges
Data matching was undertaken to help identify NHS patients who have
claimed to be exempt from NHS dental and ophthalmic charges, when they
are not entitled. Patient exemption claims were matched to payroll data
to ensure that dental and ophthalmic exemptions, eg for glasses or dental
treatment, are only awarded to those patients qualifying for exemptions. 
NHS Scotland Counter Fraud Services (CFS) received the matches in the
second half of 2019. It worked to identify the highest-risk matches and
then started verifying payroll details before undertaking investigations. 
As part of this investigative work, CFS asked dentists and opticians to
supply the original exemption claim signed by the patient. However, CFS
was unable to progress this part of the investigation due to dentists,
opticians and the CFS being required to close down due to Covid-19
lockdown restrictions. CFS then decided not to use the matches as
originally intended but instead use them as intelligence, for example, as
an alert if the same people claim again. CFS considered it not worthwhile
re-doing the pilot in 2021 as there were very few exemptions claimed
between April to December 2020. This was due to opticians and dentists
initially being closed and then only able to do emergency treatment
which was free of charge. CFS intends to re-run the exercise after new
payroll data goes into NFI in autumn 2022.
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Page 25

Covid-19 grants
for businesses
Following a Covid-19 grants data matching pilot exercise in
England in the summer of 2020, it was decided to expand
the English pilot to cover Covid-19 business grants paid to 
Scottish businesses.
These grants were paid under the Small Business Grant Fund (SBGF)
and the Retail, Hospitality and Leisure Grant Fund (RHLGF). Scottish
councils submitted data from early in 2021. Initial matches were released
in April 2021, however, match numbers were low. The Scottish schemes
were more complex than similar schemes in other parts of the UK, eg 
in respect to second and subsequent properties held by each ratepayer.
As a result, the algorithms were rechecked and additional matching 
was undertaken.
Additional matches were released in September 2021. Despite the data
having been rematched, only one fraudulent grant payment of £25,000
was identified. Due to Covid-19 grant payments having stopped, it is not
expected that this matching will be required again. However, the systems
are in place should the matching be required for any similar grants or
payments in the future.
Additional counter-fraud
measures introduced by NFI
participants in respect of
Covid-19 grant funding
Auditors identified that around 43 per cent of NFI participating bodies
awarded Covid-19 funding during the pandemic.
Almost three-quarters of these bodies introduced additional counter-
fraud measures such as new internal controls. This included actively
working through national networks, such as the Scottish Local Authority
Investigators Group, the Institute of Revenues Rating and Valuation,
the National Anti-Fraud Network, and with Police Scotland as well as
strengthening internal controls. This resulted in, for example, Dundee
City Council preventing 143 attempted fraudulent applications valued at
£381,500 from being paid in 2020/21. It also resulted in Aberdeenshire
Council identifying eight fraudulent grants totalling £107,000 plus 
14 attempted frauds totalling £151,000. The bodies that did not take
additional counter-fraud measures reported these were not necessary as
for some, payments were made to existing customers using the existing
controls whereas others relied on existing controls around the setting up
of new suppliers and associated payments.
Only one fraudulent grant
payment of £25,000 was identified Aberdeenshire Council identified eight
fraudulent grants totalling £107,000
The National Fraud Initiative in Scotland 2022 | 21 |

Page 26

Non-domestic rates – Small
Business Bonus Scheme
In 2019/20, a pilot was undertaken with the Scottish
Government and seven Scottish councils to help identify businesses
inappropriately claiming Small Business Bonus Scheme (SBBS) relief. 
The SBBS provides rates relief to owners of non-domestic properties
with rateable values under certain thresholds.
The seven participating councils provided 81,827 ratepayer records to
the NFI system, which were then matched across the councils and with
data from Companies House in order to identify SBBS fraud. The pilot
identified £412,974 in incorrect awards.
Due to the success of this pilot, a national roll-out of this data matching
exercise was carried out in 2021/22.
The 2021/22 pilot identified 17,676 matches which resulted in £2.2 million
in incorrect SBBS relief being identified in 208 SBBS awards. Councils
will now try to recover SBBS which was incorrectly awarded. Recovery
is already in progress for 119 cases with a value of almost £745,000 in
incorrectly awarded relief.
Given the success of the 2021/22 pilot, consideration is now being given
as to how this data match can be repeated on a regular basis as part of
the main NFI exercise. The pilot report is available on our website.
National entitlement
cards for travel
The National Entitlement Card (NEC) is Scotland’s National
Smartcard. Supported by the Scottish Government to deliver national and
local services, the NEC makes it convenient for people to access various
public services and facilities with only one card. The NEC can be used for
services such as a travel pass, a library card, a leisure membership card
and a Young Scot card as well as providing access to other local services.
In 2021/22, a pilot was undertaken with Fife Council, to match travel
passes for elderly and disabled customers with deceased customer
records. Fife Council provided a total of 112,044 NEC records for matching
against deceased person records. This resulted in 1,737 matches being
identified for review by Fife Council (a return rate of 1.6 per cent).
Following Fife Council’s review, all 1,737 cards (100 per cent) were
cancelled on the NEC system as it was established that the customers
had died. This means no further cards can be requested for these
customers, and the card will be blocked should someone attempt to use
it. No matches were identified where the customer was still alive.
Thirteen matches showed cause for concern as the NECs appeared to
have been used after the death of the cardholder. Two of these cards
were used for journeys to the value of almost £2,300 for one, and £240
for the other. The value of the journeys for the other 11 cards varied from
£3.10 to £69.00.
Given the success of this pilot, consideration will be given as to how this
data match can be expanded to other councils in Scotland and included
in the main NFI exercise in the future. The pilot report is available on 
our website.
The pilot identified £412,974
in incorrect awards
The National Fraud Initiative in Scotland 2022 | 22 |

Page 27

Social security benefits
A pilot is under way with Social Security Scotland 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. Claimant data was matched to data already in the
NFI system from across the UK. Data was submitted in March 2022,
with matches released to Social Security Scotland in May 2022. Social
Security Scotland is currently reviewing the matches.
Police Scotland’s use
of AppCheck
Police Scotland’s Serious and Organised Crime Interventions
Team deals with vetting applications, eg for landlord registration and pre-
contract procurement check requests from public bodies such as councils
and the NHS. These checks aim to prevent and detect fraud within public
procurement and other public services such as landlord registration and
taxi licencing. Police Scotland is undertaking a pilot to identify if data in
the NFI data base can be used to help its vetting processes to prevent
and detect fraud. Data has yet to be shared.
A match was highlighted,
demonstrating the benefit AppCheck
can bring in preventing fraud
Applications for student
awards 
A pilot was undertaken with Student Awards Agency
Scotland (SAAS) to help confirm residency and address details for
students applying for awards for tuition fees, grants and bursaries. SAAS
funds students from Scotland and as such it is interested in verifying the
address of student applicants and flagging where students are potentially
fraudulently misrepresenting their address to benefit from the more
attractive financial support offered to Scottish students.
Student applications were matched against data held in the NFI system.
An initial batch of 50 applications was processed which SAAS found
very helpful in verifying and querying address details. One known fraud
was put through the NFI pre-application screening service (AppCheck)
to test the system. A match was highlighted, demonstrating the benefit
AppCheck can bring in preventing fraud.
SAAS is now looking to expand the pilot to allow the upload of a large
batch of applications to the NFI system quickly, securely and easily.
Case study
A new NFI pilot matching National Entitlement cards in 
Fife Council against deceased person records identified
one card that had been fraudulently used for bus travel valued at almost
£2,300 after the cardholder had died. Investigations are continuing into
the individual(s) who used this card.
The National Fraud Initiative in Scotland 2022 | 23 |

Page 28

Future developments
The 2022/23 NFI exercise is due to start in late summer 2022. Datasets have been reviewed and updated as necessary.
Audit Scotland continues to work with the Cabinet Office
in developing new ways to prevent and detect fraud. This
includes piloting new data matching opportunities.
The Scottish Parliament approved The Digital Government (Scottish
Bodies) Regulations 2022 in March 2022. These Regulations name
Audit Scotland under Regulation 3 - ‘Scottish bodies for the disclosure
of information in relation to fraud against the public sector’. This allows
Audit Scotland to access HM Revenue & Customs income and savings
data for Scottish residents for future NFI exercises. This will help identify
outcomes where customers have received benefits and services above
what they are entitled to.
Audit Scotland continues to work with the Scottish Government in
promoting and enhancing participation in the NFI across Scotland.
The Scottish Parliament’s Public Audit Committee (PAC) is considering
the expansion of legislative powers around the NFI. This may include
expanding the NFI to bodies in receipt of significant amounts of public
funding that do not fall under the audit remit of the Auditor General for
Scotland or the Accounts Commission.
The Cabinet Office recently consulted on extending its legal powers
around the purposes for which data matching can be used. It is looking
to potentially extend its legal powers in the following areas:
• to assist in the prevention and detection of crime other than fraud
• to assist in the apprehension and prosecution of offenders
• to assist in prevention and detection of errors and inaccuracies. The
NFI data could be used to help public-sector bodies to ensure citizens
get access to their full benefit entitlements. For example, a number
of passported benefits across the welfare system entitle recipients
to help with housing costs, free school meals, etc. A match could
identify citizens entitled to additional help they are not claiming
• to assist in the recovery of debt owing to public bodies. Public bodies
may need to trace individuals with outstanding overdue debt and with
no arrangement to pay in place. In some instances, these individuals
may be difficult to trace. The NFI data could be used to help identify
where a debtor was living or working, for example.
The Cabinet Office is considering the responses and will publish a formal
consultation response in due course.
Section 97 of the Criminal Justice and Licensing Act 2010 already
permits Audit Scotland to use data matching for the first two purposes.
We will monitor developments.
The National Fraud Initiative in Scotland 2022 | 24 |

Page 29

Appendix 1. Background to the NFI
The NFI is a counter-fraud exercise across the UK public sector which aims to prevent and detect fraud. The Cabinet Office
oversees it, and Audit Scotland leads the exercise in Scotland, working with a range of Scottish public bodies and external auditors.
The NFI uses data sharing and matching to help
confirm that services are provided to the correct people.
The NFI takes place every second year. 132 public-
sector bodies in Scotland participated in the 2020/21
exercise including councils, NHS bodies, colleges and
larger central government bodies such as the Scottish
Government, Revenue Scotland and Transport Scotland.
A full list of participants is available here.
The NFI enables public bodies to use computer 
data matching techniques to detect fraud and error.
We carry out the NFI under powers in The Criminal
Justice and Licensing (Scotland) Act 2010. It is
important for all parties involved that this exercise is
properly controlled, and 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.
Although the main purpose of the NFI is to ensure
funds and services are provided to the correct
people, the review of NFI matches may also identify
that a customer is entitled to additional services or
payments, eg housing benefit matches may identify
customers entitled to council tax discount or reduction.  
Data matching exercise every
two years in partnership with
the Cabinet Office
Participating bodies submit
data to a secure website
NFI outcomes are reported by
participating bodies, auditors
and Audit Scotland 
The NFI system matches data
within and between bodies to
identify anomalies 
Auditors monitor participating
bodies' processes and progress
Potential anomalies called
‘matches’ are reported to
participating bodies to review,
investigate and record outcomes  
The National Fraud Initiative in Scotland 2022 | 25 |

Page 30

Appendix 2. Costs and benefits
of participating in the NFI
The Scottish Parliament provides funding to Audit Scotland to cover public-sector participants’ NFI fees for the biennial data
matching exercise.
Participating bodies incur costs following up
matches and investigating. Participating bodies
also incur costs for pilot work and additional
services such as the AppCheck pre-application
screening and the ReCheck4 flexible data
matching service.
Many bodies do not keep separate records
for NFI costs as it is just one of many counter-
fraud activities they are doing. Those that
do have records were able to estimate that
their costs ranged from £500 to £71,000.
This compares favourably with the average
outcome for each public body in Scotland of
£113,000 for the 2020/21 NFI exercise.
Overall, the £14.9 million of outcomes from the
2020/21 NFI outweigh the costs.
£8,416 £204,500
Average reported cost of NFI
(total of 25 bodies)
Audit Scotland costs
4. ReCheck is a flexible data matching
service that complements the NFI biennial
national exercise. It allows NFI participants
re-perform the existing NFI data matching
at a time that suits them.
No. of bodies reported Cost range
Councils 0 £0
Other local 
government
bodies
2 £1,397 – £5,000
NHS bodies 7 £1,277 – £71,000
Central 
government
bodies
11 £590 – £20,000
Colleges 5 £500 – £6,000
The National Fraud Initiative in Scotland 2022 | 26 |

Page 31

Appendix 3. Estimation bases
The figures used in this report for fraud, overpayments and errors include outcomes already delivered (actual amounts
participants have recorded) and estimates. Estimates are included where it is reasonable to assume that incidents of fraud,
overpayments and errors would have continued undetected without NFI data matching.
Details of estimate calculations used in the report are shown below.
Data match Basis of calculation of estimated outcomes 
Council tax single 
person discount  Annual value of the discount cancelled multiplied by two years. 
Housing £93,000 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.
Housing benefit  Weekly benefit reduction multiplied by 21 weeks. 
Pensions  Annual pension multiplied by the number of years until the pensioner would have reached the age of 85. 
Payroll   £5,000 for each employee dismissed or resigns as a result of NFI matching, or £10,000 for each resignation or dismissal for
employees who have no right to work in the UK. 
Council tax 
reduction scheme Weekly change in council tax discount multiplied by 21 weeks.
Housing waiting lists £3,240 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.
Blue badges  Number of badge holders confirmed as having died multiplied by £575 to reflect lost parking and congestion charge revenue.
The National Fraud Initiative in Scotland 2022 | 27 |

Page 32

The National Fraud
Initiative in Scotland
2022
Audit Scotland’s published material is
available for download on the website in a
number of formats. For information on our
accessibility principles, please visit:
www.audit-scotland.gov.uk/accessibility
For the latest news follow us on social media
or subscribe to our email alerts.
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500 Email: info@audit-scotland.gov.uk
www.audit-scotland.gov.uk
ISBN 978 1 913287 91 7

Page 33

National Fraud Initiative
2020/2021 
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
participant 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. 
Renfrewshire Council Facebook                Renfrewshire Council twitter
Council data from across a range of services including Payroll, Revenues
and Benefits and Housing was exported as a snapshot in time at the
beginning of October 2020 and uploaded to the secure NFI web portal.
Data Matching
The NFI aims to improve the detection and prevention of fraud in the
public sector by matching data from one authority / organisation against
both its own data and the data from other bodies for example, payroll
data from a local authority against state benefit data from the DWP.
Data exported in early October is quality checked prior to submission and
a further continuity check is carried out by the Cabinet Office data
matching contractor.  It is then cross referenced against data held and
most matches are released by early Spring 2021.
Match Category Match Release
DWP deceased data January 2021
Payroll, State Benefit, Housing
Benefit, Housing Applications,
Housing Tenants, Council Tax
Reduction, Taxi Drivers License,
Blue Badge, Creditors
February 2021
Procurement, Business Grants* April 2021
Small Business Bonus Scheme July 2021
*Business Grants matches across all Scottish Local Authorities were suspected to be under-reported
in the April release.  A further data matching exercise is being run and has yet to be released.

Page 35

2. OUTCOMES
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 2020/21 
The Cabinet Office have included 2 new areas for investigation and
removed 4 datasets from the 2018/19 exercise
Additions: Covid related Business Grants and Non domestic rates Small
Business Bonus Scheme
Deletions: Market Trader license holders, Personal Alcohol License
(licensed premises) holders, Personal Care and Private Residential Care
Homes.
These updates have seen a significant reduction in the number of reports
and matches released for investigation.
2020/2021 Change 2018/2019 
88 Reports  115 Reports
4901 unique matches  6250 unique matches 
The results included in this report are lifted from those reported and
verified by Audit Scotland.  All results are correct as at 31 March 2022.
Any cases open at the time of the Audit Scotland report were followed up
by the Counter Fraud Team and worked to their conclusion however any
savings from these cases are not reported in the Audit Scotland, The
National Fraud Initiative in Scotland 2022 report which was published by
Audit Scotland in August 2022.
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.

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3. PROCESS
All required datasets were exported in September 2020 and submitted to
the National Fraud Initiative web portal.
The National Fraud Initiative data matching cases are released on the web
portal January 2021.
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 
All
Matches
high
risk
% of all
matches that
are high risk
Housing Benefit claimants 85 42 49.41%
Payroll 105 16 15.24%
Housing Tenants 316 200 63.29%
Blue Badge Parking Permit 522 383 73.37%
Housing Waiting List 191 166 86.91%
Council Tax Reduction Scheme 1326 37 2.79%
Creditors 2160 264 12.22%
Procurement 66 0 0.00%
Business Rates 127 127 100.00%
Business Grants 3 0 0.00%
Multiple Occurrence report   
cumulative total 4901 1235 25.20%
Analysis of Renfrewshire council NFI matches 2020/21 
Matches allocated ‘high risk’ status are prioritised for investigation. 
Previous NFI exercises indicated potential savings from ‘low risk’ Council
Tax Reduction Scheme matches.  These matches were also given priority
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. 
2018 2020 Change
HB 237 85      64%
Payroll 133 105      21%
Tenants 247 316      28%
Blue Badge 176 522      197%
Waiting List 283 191      33%
CTRS 1161 1326      14%
Creditors 3004 2160      28%
Analysis of Renfrewshire council NFI matches 2020/21 and 2018/19
Blue Badge and Housing Tenant matches saw the most significant
increase in total number of matches from the previous exercise in
2018/19.  This may have been caused by the increased mortality rates in
the elderly and clinically vulnerable due to the COVID 19 pandemic as a
large proportion of these matches were to deceased person data.
The Counter fraud team work closely with Housing Services to provide
verification for new housing waiting list applications which may have had
a positive impact on the number of matches identified in the NFI exercise
in 2020/21.

Page 37

4. RESULTS
2020/21 Fraud and error identified
Fraud Area No. of
cases 
Actual
Overpayment
Estimated
Savings
All 842 £410,735 £1,640,731
CTRS1 78 £132,222 £16,769
HB2 1 £4,402 £2,634
Housing
Tenancy
9 N/A3 £837,000
Waiting
List
92 N/A £298,080
Payroll 1 £6,386 N/A4
Blue Badge 207 N/A £119,025
Creditors 2 £75,644 N/A
NDR5 2 £13,232 £18,933
CT
Discount6
450 £178,849 £348,290
NFI Outcomes 2021: interactive report, Audit Scotland 
https://www.audit-scotland.gov.uk/uploads/docs/um/outputs/nr_220818_nfi/index.html 
Overall outcomes are down from the previous exercise, this is the case
across the whole of Scotland, however the actual overpayment identified
in Council Tax Reduction Scheme has risen.  The counter fraud team
approached this exercise differently.  Our strategy for this exercise was to
investigate all CTRS matches and not only the high risk recommended
matches. 
Council Tax Reduction data matched with public body private pensions
generated a large proportion of the CTRS outcomes.  
In many cases claimants were unaware that annual pension upratings
were not automatically added to their claim, or that the pension paying
body did not routinely share the upratings with local authority revenue
and benefit services.  Claimants impacted were supported by Revenues
and Benefits Service and counter fraud officers to ensure that their claim
was brought up to date to prevent any future overpayments.
The 2020/21 exercise introduced the non-domestic rates matches after a
previous Audit Scotland pilot demonstrated successful outcomes.  NDR
outcomes relate solely to the reassessment of Small Business Bonus
Scheme (SBBS) discounts.  
The financial savings in excess of £410,000 are set to be recovered
following the Council’s usually debt recovery processes.
Our participation in the 2020/21 NFI exercise is estimated to have
prevented further financial loss to Renfrewshire Council in excess of £1.6
million. 
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

5. FUTURE EXERCISES
Progress is being made on the preparations for the 2022/23 NFI exercise. The data will be extracted from Council systems from September 2022 and
uploaded to the secure web portal in October 2022. There is a communications plan in place to ensure Elected Members, employees and members of the
public are aware of the initiative and ensure our compliance with the privacy notice expectations. Our arrangements have been self-assessed against Audit
Scotland’s self-assessment checklist as detailed below:
Part A: Leadership, commitment and communications Yes/no/partly Is action
required?
1. Are we aware of emerging fraud risks and 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 the 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?
Yes - there is a Counter Fraud Policy in place and it is incorporated into the
Counter Fraud Business Plan. 
No
4. Have we considered using the point of application data
matching service offered by the NFI team, to enhance
assurances over internal controls and improve our approach
to risk management?
Yes - we continue to review the use of Appchecker and other optional
services.  Previous experience of appchecker has influenced our approach to
regular data matching.
No
5. Are the 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 (including the
most recent SBBS pilot report) are shared with Senior Management.  The
overall NFI outcomes and results are reported at the end of the biennial
exercise.
No

Page 39

5. FUTURE EXERCISES
6. 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
7. 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
8. 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
9.  Do we publish, as a deterrent, internally and externally
the achievements of our fraud investigators (eg, successful
prosecutions)?
Yes - Report to members of the Audit, Risk and Scrutiny Board. Other
publicity is considered on a case-by-case basis.
No
Part B: For the NFI key contacts and users    
Planning and preparation    
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. 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 included in audit plan and regular engagement with service
through counter fraud team monitoring.  Revenues and Benefit services
have included NFI match investigation in their work plan for 2023.
No

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5. FUTURE EXERCISES
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.
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. Is our NFI Key Contact (KC) the appropriate officer for that
role and do they oversee the exercise properly?
Yes - Chief Auditor oversees the task and a further 2 counter fraud
investigators identified to progress investigations and liaise with operational
services.
No
5. Do KCs have the time to devote to the exercise and
sufficient authority to seek action across the organisation?
Yes - included in work plan and liaison with operational service contacts for
actionable cases agreed at the planning and preparation stage of the NFI
exercise
No
6. Where NFI outcomes have been low in the past, do we
recognise that this may not be the case the next time, that
the 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
7. Do we confirm promptly (using the on-line facility on the
secure website) that we have met the fair processing notice
requirements?
Yes - deadline met  No
8. 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
9. Have we considered using the point of application data
matching service offered by the NFI team, to enhance
assurances over internal controls and improve our approach
to risk management?
Yes - Appchecker has been used in the past and has influenced the approach
to regular data matching.
No
Effective Follow Up of Matches    
10. Do all departments involved in the NFI 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 and Resources
No
11. Do we give priority to following up recommended
matches, high-quality 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

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5. FUTURE EXERCISES
12. Are we investigating the circumstances of matches
adequately before reaching a no issue outcome, in
particular?
Yes No
13. (In health bodies)  are we drawing appropriately on the
help and expertise available from NHS Scotland Counter-
fraud Services?
N/A No
14. 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.  Recovery of funds in some areas
was impacted by the COVID 19 pandemic however this is now returning to
normal.
No
15. Do we avoid deploying excessive resources on match
reports where early work (eg, on recommended matches)
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
16. 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 No
17. Do we follow up matches which indicate a customer may
be eligible for a benefit or service which they currently do
not receive?
Yes - Counter fraud team work jointly with operational services to
investigate matches.  All changes of circumstances identified are considered
in the reassessment of the claim and where additional benefit entitlement is
identified this is communicated to the claimant. 
18. Overall, are we deploying appropriate resources on
managing the NFI exercise?
Yes - any resourcing issues are discussed with the Service and Director of
Finance and Resources as appropriate. Counter Fraud resources are
committed within the workplan to the NFI exercise. 
No
Recording and reporting

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5. FUTURE EXERCISES
19. Are we recording outcomes properly in the secure
website and keeping it up to date?
Yes - monitored by Internal Audit No
20. Do staff use the online training modules in the secure
website and do they consult the NFI team if they are unsure
about how to record outcomes?
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
21. If, out of preference, we record some or all outcomes
outside the secure website have we made arrangements to
inform the NFI team about these outcomes?
Yes - this is included in the Report notes. No