Item 7 Appendix 1 - National Fraud Initiative 2022-23 Exercise

Page 1

Self Appraisal Checklist Appendix 1
Part A
for those charged with Governance Yes/No/Partly Is action Required? Who and By When
Leadership Commitment and Communication
1      Are we aware of emerging fraud risks and taken
appropriate preventative and detective action?
Yes
Yes - regular updates are received through
NAFN and CIFAS which are circulated to
relevant services within the Council.
The Internal Audit Annual Audit Plan for
2024/25 includes an allocation of resource to
undertake relevant fraud activity including
investigation of national fraud initiative
exercise and other investigations.
N/A
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
The responsibility for overseeing the NFI lies
with Internal Audit.  Internal Audit will review
all aspects of NFI for the coming 2024/2025
exercise.  A report will be presented to the
Audit Committee outlining how the Council is
engaging with the 2024/2025 exercise.
Shared Service Manager -
Audit & Fraud
May 2025
3.    Is the NFI an integral part of our corporate policies
and strategies for preventing and detecting fraud and
error ? Yes
The NFI is included within our Anti-Fraud
and Corruption Policy. N/A
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? Partly
This is not something that is actively used by
services as there are other systems and
processes in place as part of the Council's
system of internal control.  We maintain a
watching brief on this via the relevant audit
and fraud networking groups.
Shared Service Manager -
Audit & Fraud
May 2025
5.  Are the NFI progress and outcomes reported regularly
to senior management and elected/board members (eg,
the
audit committee or equivalent)?
Yes
A high level summary is provided to Audit
Committee on NFI progress and the annual
report provides more detail on areas
investigated and outcomes.
N/A
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?
N/A
All required data sets are submitted.
N/A
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
The responsibility for overseeing the NFI lies
with Audit & Fraud.  Internal Audit will review
all aspects of NFI for the coming 2024/2025
exercise.  A report will be presented to the
Audit Committee outlining how the Council is
engaging with the 2024/2025 exercise.
Outcomes of the NFI exercise are used to
inform potential audit areas for future annual
audit plans.
Shared Service Manager -
Audit & Fraud
May 2025
8.    Do we review how frauds and errors arose and use
this information to improve our internal controls?
Yes
Outcomes of the NFI exercise are used to
inform potential audit areas for future annual
audit plans.
N/A
9.   Do we publish, as a deterrent, internally and
externally the achievements of our fraud investigators
(eg, successful prosecutions)?
Yes
Published on website and during fraud
awareness training internally. N/A
Part B
For the NFI Key contacts and users
Planning and Preparation
1.Are aware of emerging fraud risks and taken
appropriate preventative and detective action?
Yes
Yes - regular updates are received through
NAFN and CIFAS which are circulated by
the Corporate Fraud team to relevant
services within the Council.  Members of the
team attend the Scottish Local Authority
Investigators Group.
Shared Service Manager -
Audit & Fraud
Ongoing
2.   Are we investing sufficient resources in the NFI
exercise? Partly
As part of the 2024/25 exercise the Audit &
Fraud team will carry out a review of dataset
owners across the Council to ensure
sufficient resources are in place.
Shared Service Manager -
Audit & Fraud
May 2025
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
Quality checks on data are carried out
regularly. N/A
4.   Is our NFI Key Contact (KC) the appropriate officer
for that role and do they oversee the exercise properly?
Yes
The responsibility for overseeing the NFI lies
with Audit & Fraud who will review all
aspects of NFI for the coming 2024/2025
exercise. 
A report will be presented to the Audit
Committee outlining how the Council is
engaging with the 2024/2025 exercise.
Shared Service Manager -
Audit & Fraud
May 2024
5.   Do KCs have the time to devote to the exercise and
sufficient authority to seek action across the
organisation? Yes
Sufficient allocation of resource for the NFI
work is included within the Internal Audit
Annual Audit Plans.  Progress reports are
submitted to Audit Committee on a regular
basis.
Shared Service Manager -
Audit & Fraud
Ongoing
6.   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
This is recognised in terms of the matches
received.  Resources for the Audit & Fraud
team's workplan are reviewed in light of the
matches received and the level of outcomes
for earlier exercises.
Shared Service Manager -
Audit & Fraud
Ongoing
7.   Do we confirm promptly (using the online facility on
the secure website) that we have met the fair processing
notice requirements?
Yes
This exercise has been confirmed using the
online facility in September 2024. N/A
8.    Do we plan to provide all NFI data on time using the
secure data file upload facility properly? Yes
Audit & Fraud co-ordinates the NFI exercise
and a timetable is in place to meet
timescales for data upload for the 2024-2025
N/A
9.   Have we considered using the 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
This is not something that is currently used
within the Council as it attracts additional
costs and the functionality requires to be
reviewed for any enhancements offered. 
This will be considered as part of the
2024/25 NFI exercise.
Shared Service Manager -
Audit & Fraud
May 2025
Effective Follow up Matches
10   Do all departments involved in NFI start the follow-
up of matches promptly after they become available?
Yes
Progress is monitored and followed up by
the Audit & Fraud team. Shared Service Manager -
Audit & Fraud
Ongoing
11. 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
A full review of protocols for all services has
been carried out by Audit & Fraud to ensure
compliance.  High risk matches have been
fully discussed with all services and they are
aware to prioritise these.  This will be
monitored by the Audit & Fraud Team.
Shared Service Manager -
Audit & Fraud
Ongoing
12.  Are we investigating the circumstances of matches
adequately before reaching a ‘no issue’ outcome, in
particular?
Yes
User training has been provided by Audit &
Fraud team to ensure all services are
investigating adequately. 
N/A
13.   (In health bodies) are we drawing appropriately on
the help and expertise available from NHS Scotland
Counter-Fraud Services?
N/A
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
Appropriate reports to PF, disciplinary action
are taken, debt recovery procedures are in
place. N/A
15. Do we avoid deploying excessive resources on
match reports where early work (eg, on high-risk
matches) has not found any fraud or error? Yes
Reviews of results undertaken and
resources based on the outcomes achieved
will be deployed to other recommended or
high risk matches.  The Audit & Fraud team
will review all services to ensure compliance.
Shared Service Manager -
Audit & Fraud
Ongoing
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
The Audit & Fraud team have provided
training on the investigation process which
includes the  consideration of investigating
all matches.
N/A
17.    Overall, are we deploying appropriate resources on
managing the NFI exercise? Yes
The Audit & Fraud team review resources to
ensure appropriate resources are being
deployed.
N/A
Recording and Reporting
18.    Are we recording outcomes properly in the secure
website and keeping it up to date? Yes The Audit & Fraud team have carried out a
full review of this area to ensure compliance. N/A
19. Do staff use the online training modules and
guidance on the secure website, and do they consult the
NFI team if they are unsure about how to record
outcomes (to be encouraged)?
Yes
Officers have found the online training
helpful and Audit & Fraud have provided
additional training on the required process
for 2024/25 exercise. 
N/A
20. 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?
N/A
All outcomes are reported in secure website.
N/A