Fraud Control in Emergency Management: Covid-19 guidance

Fraud Control in Emergency Management: Covid-19 guidance


CategoryNews, Articles Author Marion Smith QC, Rose Grogan, Philippe Kuhn Date

This is further to our article on local authority commercial contracts and procurement in a Covid-19 world on 25 March 2020 discussing two Procurement Policy Notes (PPN 01/20 and PPN 02/20) introduced in light of the current crisis (see the links below). The Cabinet Office has issued further guidance yesterday on fraud prevention measures by central and local government, NHS bodies, education institutions and other public bodies.

The guidance entitled ‘Fraud Control in Emergency Management’ recognises a heightened threat from fraud during emergency situations. It identifies two particular sources of imminent danger:

(1) first party application fraud in light of the roll-out of new support schemes (i.e. the risk that an applicant may misrepresent their circumstances to qualify); and

(2) third party impersonation fraud in accessing government grants and loans (i.e. the risk that a third party may impersonate a business).

The principal guidance to public bodies is to integrate fraud control personnel into the policy and process design to build awareness of fraud. Low-friction controls into payments should be introduced, where possible, and post-event assurance checks are vital. Public bodies are also urged to be mindful of the shift from emergency payments into longer term services, and to revisit the control framework.

Key links:

‘Fraud Control in Emergency Management’ (Cabinet Office guidance) (26.03.2020)

‘Local Authority Commercial Contracts and Procurement in a Covid-19 World’ (39 Essex Chambers article) (25.03.2020)

‘Procurement Policy Note 02/20’ (Cabinet Office) (20.03.2020)

‘Procurement Policy Note 01/20’ (Cabinet Office) (18.03.2020)


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