disciplinary policy & procedure - West Hertfordshire Hospitals NHS ...

3.5 Liaison with the relevant NHS CFS Operational Service Team throughout the
investigation passing relevant advice onto HR for consideration.
3.6 Where necessary, and appropriate to do so, the LCFS will provide sufficient evidence to
HR in order that a disciplinary investigation can be taken forward as appropriate.
3.7 Concluding reports will be issued at the closure of any investigation undertaken by the
LCFS in accordance with the requirements outlined in the NHS Counter Fraud and
Corruption Manual.
4 Outline of Investigation Process
4.1 From the initial review undertaken by the LCFS, the following will be considered (see
Appendix A):
• No evidence of fraud found (4.2)
• No evidence of fraud found but system controls need to be strengthened (4.3)
• No evidence of fraud found but matter needs to be referred back to HR for potential
disciplinary sanction to be considered (4.4)
• Reasonably held suspicion/information/evidence of suspected fraud received
requiring criminal investigation (4.5).
4.2 No case to answer or no evidence of fraud found
The LCFS will inform the Director of Finance that no fraudulent action has been
identified. Human Resources will also be notified of this decision. A concluding report will
be written by the LCFS and issued accordingly.
4.3 No evidence of fraud found but system controls need to be strengthened
The LCFS will inform the Director of Finance and HR of this decision.
A concluding report will be issued with recommendations to strengthen controls in
identified areas of weakness. This report will be distributed in accordance with the
requirements outlined in Directions. The recommendations will be followed up by the
LCFS as part of future fraud prevention work.
4.4 No evidence of fraud found but the referral is returned to HR for potential disciplinary
sanction to be considered
The LCFS will inform the Director of Finance and HR of this decision.
If the LCFS does not find evidence of fraud but a breach of policy/procedures may have
occurred, then the LCFS will meet with a member of HR to discuss the findings and pass
on the file of evidence gathered to date as disclosure allows. HR should use this file of
evidence to establish if further consideration/action is required.
The LCFS will take no further part in any additional investigation undertaken by HR
regarding a suspected breach of procedures. However, the LCFS may be called to a
disciplinary hearing as a witness if required.
A concluding report will be issued with recommendations to strengthen controls in
identified areas of weakness. This report will be distributed in accordance with the
requirements outlined in Directions. The recommendations will be followed up by the
LCFS as part of future fraud prevention work
4.5 Case to answer criminal investigation undertaken and appropriate sanction considered
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