Guidance to GP practices on GP patient registration fraud
The NHS CFS has responsibility for all policy and operational matters relating to the prevention, detection and investigation of fraud and corruption in the NHS.
It offers guidance to GP practices on how to identify and manage suspicions of patient registration fraud and how to prevent this type of activity occurring in the future.
Patient registration fraud:
There have been a number of cases where patients (both temporary and newly registered) have registered at GP practices (often at multiple practices) using their own or false details and fraudulently obtained prescription drugs without providing evidence of their identity or giving details of their most recent GP. They have obtained prescription drugs for personal use and/or to sell and this is resulting in a financial loss to the NHS.
Minimising patient registration fraud:
Taking the following steps will ensure that patient registration fraud in practice is minimised.
- Request identification
It is important to ask all new patients (whether registering permanently or temporarily) to provide identification upon registering.
A combination of the following can be accepted as identification (it is preferable that one item of photo ID is seen, along with one document like an utility bill containing the patient’s address):
- Birth certificate
- Marriage certificate
- Medical card
- Driving licence
- Local authority rent card
- Paid utility bills
- Bank/building society cards/statements
- National Insurance number card
- Pay slip
- Letter from Benefits Agency/benefit book/signing on card
- Papers from the home office
- This list is not exhaustive.
The following documents are easily obtained and should not be accepted as proof of identity if presented in isolation:
- Library card
- Video rental card
- Health club card
- Private rent book.
If the patient provides identification, a note of this should be made on their record and they should be treated as normal.
If the patient does not provide identification, the registration should still be accepted but a note should be made on the patient’s records to say that no identification has been seen and they should be asked to bring something next time they attend the surgery.
- Request proof of address Permanent patients should also be asked to provide evidence of their address.
- Contact your Local Counter Fraud Specialist
GP practices should report suspected false registrations to their Local Counter Fraud Specialist (LCFS), giving as much detail as possible. Details of these patients can then be circulated and all related incidents can be collated by the NHS CFS to identify serial offenders.
It is not unusual for some surgeries to have a too close a relationship with the local pharmacists; the senior receptionists may have such relationship bordering on unethical practices.
The senior receptionists may some times ask pharmacists to supply the usual prescription medicines and promise to give the repeat prescription soon. Due to pressure of work and forgetfulness these promised prescriptions may not been sent to the pharmacy. At the month end the pharmacist may submit a long list of repeat prescriptions that are due to him so as to claim money for medicines supplied. These would also result in surgeries prescribing less medication for those periods when the true situation is just the opposite.
The potential weaknesses in the prescription processes are ones well known to the NHS counter fraud service. In two recent cases practice receptionists have exploited these weaknesses. In each case the receptionists, both long term members of staff, had fraudulently used the computerised patient notes’ system to access records and create fraudulent repeat prescriptions, which were then unwittingly signed by the prescribing GP.
Surgery practice managers and ‘fixers’ have been secretly filmed selling access to doctors, enabling foreign nationals who have no legal right to free hospital treatment to be seen without paying.
Hospitals should check if foreign patients are entitled to free NHS hospital care but in many these patients are not entitled to as per checks.
Fraud can happen in all areas of the NHS and can be committed by staff of all levels. The various cases involving fraud and resulting in punishment are given below:
- There have been cases where one NHS practice manager sold patient registrations at a health centre to an undercover reporter for up to £800 a time.
- The reporter went on to obtain an MRI scan to which the patient was not legally entitled, which would have cost £800 privately.
- A practice manager entered her son, who was not employed by the practice, onto the practice payroll
- A GP worked privately while off sick from the NHS. He claimed payment for locum cover for his NHS practice from the primary care trust
- A patient used aliases and false addresses to fraudulently obtain prescriptions
- Two GPs claimed an improvement grant for their practice but transferred a third of the grant to their personal accounts
- A GP submitted prescriptions to a pharmacist in the name of one of his partners to gain drugs for himself.
- A bogus nurse who carried out vaccinations and cervical smears on more than 1,400 patients in Kent has admitted deception, fraud and forgery.
- Patient travel claim fraud
- Staff nurse imprisoned for timesheet fraud
- Patient sentenced for prescription fraud
- Salisbury man jailed for conning Dorset GPs
- Trust gives stark warning as worker is sentenced for theft after joint security operation
- Bank Nurse Fraud
- Two cases of obtaining drugs by deception
- Poole nurse sentenced to 150 hours community punishment
- Agency Operating Department Assistant jailed for 16 months
- Somerset GP convicted of impersonating patients in drug fraud
- Deferred Sentence used to control drug addicts behaviour
- Former employee of Dorset PCT admits sickness fraud
- Nursing & Midwifery Council removes nurse from Register
- Manager fined £5,000
Not all fraud, though, is to do with money. Some cases of fraud, such as faking qualifications, could be considered less serious, but it can have much more serious consequences when patients’ lives are put at risk.
There are many examples of this occurring in the press where people have got positions as practice nurses without having actually qualified. In these cases, references and certificates were not followed up and checked to see if they were legitimate.
The most common sign that a financial fraud has taken place will be a drop in the amounts held in the bank account from the usual monthly levels that the partners and practice manager will be familiar with.
This drop will also appear in the accounts as a reduction in bottom line profit and partners’ current account balances. This should prompt further inspection of the accounts to see if there are any other telltale signs that a fraud has taken place. These include:
- Unexplained increases in costs
- Unexplained drops in income
- Unusual explanations for missing items
- Regular payments falling out of sequence
- Unexplained delays in income.
In order to protect the practice, it is important to identify and put controls in place in the key risk areas, such as:
- Receipts of cash/cheques
- Access to the cheque book or payment process
- Access to drugs
- Sending of signed cheques
- Authorisation of claim forms and supplier payments
- Authorisation of the payroll.
However, the most effective deterrent from fraud is to create a culture where no one would think they could perpetrate a fraud without serious consequences. Implementing controls in the above risk areas is a good way to start.
However, not all GP practice frauds are the result of rogue staff. Sometimes, one or more of the partners themselves may be the fraudsters. These cases are harder to spot, as controls and identification processes may have been bypassed.
An example of this is a case when a GP partner was falsifying his patient lists, including 23 patients living in a one bedroom flat owned by the doctor and adding them to the PCT returns in order to achieve higher payments. These were picked up by PCT audits and the case was referred to the NHS Counter Fraud Service (now NHS Protect).
In these cases, the money would have been paid into the practice and then would have to be extracted by the fraudsters, so this could also be picked up by some of the internal methods that we have already looked at.
In order to put some control over these areas, it is important not to give any one partner too much control over the practice. For example, ensure that large value cheques have to be countersigned by more than one partner and those administrative tasks are shared out or rotated among partners.
If one has concerns about a possible fraud then, firstly, one should follow your standard internal reporting procedure. However, if one does not have one in place, or one suspects that the fraud may involve these individuals, then one can report in confidence to NHS Protect on 0800 028 40 60, or report on-line at www.reportnhsfraud.nhs.uk. Most of the examples about fraud were obtained from NHS sites in addition to details obtained by net working with the surgeries in earlier years.