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9 - (01) 2024 10 31 - The NFI in Scotland 2024

North Ayrshire Council · 31 October 2024
Back to Audit and Scrutiny Committee — 31 October 2024 and its agenda

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OFFICIAL INFORMATION
OFFICIAL INFORMATION 
NORTH AYRSHIRE COUNCIL 
31 October 2024 
Audit and Scrutiny Committee 
Title:    National Fraud Initiative (NFI) in Scotland 2024 
Purpose:  To provide the Committee with an overview of the NFI 2022/23
exercise outcomes. 
Recommendation:  That the Committee notes the outcomes of the exercise. 
1. Executive Summary 
1.1 Audit Scotland has published its most recent biennial National Fraud Initiative (NFI)
report. The report is provided in full at Appendix 1. 
1.2 North Ayrshire Council’s participation in the NFI exercise is coordinated by the
Corporate Fraud Team, with matches investigated by appropriate teams across the
Council. 
1.3 Investigation of the 2022/23 data matches was concluded earlier in 2024. 
2. Background 
2.1 The NFI is a major counter fraud exercise carried out across the UK every two years.
Participating bodies provide sets of data and, following matching of data provided by
various public sector bodies, anomalies in the data are provided for investigation. 
2.2  The exercise is coordinated across the UK by the Cabinet Office, and in Scotland is
delegated to Audit Scotland through the powers in the Criminal Justice and Licensing
(Scotland) Act 2010 and incorporated in Part 2A of the Public Finance and
Accountability (Scotland) Act 2000. 
2.3  The NFI exercise in Scotland is well established and remains the most comprehensive
detective and preventative scheme in which vast amounts of data across numerous
public bodies can be compared and matched using dedicated software. A data match
does not necessarily mean there is fraud or error present, but highlights that further
investigation is required in order to make a determination. Outcomes are recorded on
the system and collated for each public body in order to arrive at a total value of
recoveries across the whole of Scotland. 
2.4  110 public bodies across Scotland participated in the 2022/23 NFI exercise, and
matches are recommended for investigation across the country. Most matches are

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OFFICIAL INFORMATION
OFFICIAL INFORMATION
categorised into risk priority to enable resources to be focussed on the matches with the
most likely outcomes and recoveries. 
2.5  The value of fraud and error identified across Scotland in 2022/23 was £21.5m, resulting
in cumulative outcomes of £180m since the NFI first launched in 2006/07. 
2.6 The majority of the NFI results arise from the following key match areas:
• Payroll
• Council tax discounts
• Blue badges
• Pensions
• Housing benefit
• Housing tenancy
• Council tax reduction
• Housing waiting lists
• Creditors 
2.7 Whilst the national report does not include the outcomes of each individual body
included in the exercise, consultation with Audit Scotland confirmed that for North
Ayrshire Council NFI outcomes totalled £0.474m.  It should be noted however that this
includes a notional saving of £0.342m relating to 526 Blue Badge matches, where the
badge holder has been identified as deceased.  These badges have since been
cancelled. 
2.8 External audit also carried out an assessment of the Council’s planning and progress
with the NFI and makes recommendations for improvement where appropriate. North
Ayrshire Council was assessed as Satisfactory. 
2.9 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, and
where pilots achieve matches that demonstrate a significant level of success these are
extended nationally and included in the main NFI exercise going forward. 
3. Proposals 
3.1 It is proposed that the Committee notes the content of the Audit Scotland report on the
National Fraud Initiative in Scotland 2024. 
4. Implications/Socio-economic Duty 
Financial 
4.1 None. 
Human Resources 
4.2 None.

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OFFICIAL INFORMATION
OFFICIAL INFORMATION
Legal 
4.3 None. 
Equality/Socio-economic 
4.4 None. 
Climate Change and Carbon 
4.5 None. 
Key Priorities 
4.6 The work of the Corporate Fraud Team, including participation in the NFI, helps to
support the efficient delivery of the strategic priorities within the Council Plan 2023-
2028. 
Community Wealth Building 
4.7 None. 
5. Consultation 
5.1 No consultation has been required in the preparation of this report. 
Mark Boyd
Head of Service (Finance) 
For further information please contact John McCallum, Senior Manager (Audit, Fraud,
Safety, Risk and Insurance, on 01294 324607. 
Background Papers
None.

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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, 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
£ Million
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 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 an 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
More bodies received amber and red assessments 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
24
2022/232020/212018/192016/17
Number of cases
Overpayments
£ thousand
Cases
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
395
772
280
115
2022/23
2020/21
2018/19
2016/17
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.

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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.

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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).

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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

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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.

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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).

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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