EHFCN was founded in 2005 as a result of the first pan-European conference held in London in October 2004. Its foundations lie in the European Healthcare Fraud and Corruption Declaration agreed upon by its delegates. This was realised with the financial support from the AGIS 2004 Programme of the European Commission – Directorate General Justice and Home Affairs.
September 2004, London, under the leadership of Jim Gee, Executive Director of the Counter Fraud and Security Management Service (CFSMS ) at NHS (National Health Service), awareness has emerged amongst many participants for the sake and the urgency of a fight against the fraud and abuse, in the field of health, in order to preserve the sustainability of our healthcare systems. The prospect of a European structure to combat fraud and corruption in the field of health emerges. A constitution is drafted in Vilnius, Lithuania, as well as in London. A founding General Assembly is put in place, and at the first elections of the Executive Committee of the European network held in Bratislava the following year, a structure is created: the European network of fight against fraud and corruption, EHFCN. It is chaired by a Scotsman, Dermid Mc Causlan, and led by Jim GEE (UK).
At that moment are also present: representatives of institutions, departments and structures of professionals of health, Belgium through the INAMI, the College of pharmacists of Madrid, the Ministry of health in Lithuania, the Ministry of the Interior for Austria, a representative of a German health insurance, a representative of CNAMTS for France, as well as a few observers, including observers from Poland, Greece, Slovenia, Italy, Turkey and Portugal.
Those who agreed to the European Healthcare Fraud and Corruption Declaration consented to the following objectives:
- The development of a European common standard of RISK MEASUREMENT (baseline figures), with annual statistically valid follow up exercises to measure progress in reducing losses to fraud and corruption throughout the EU.
- The creation of a real ANTI-FRAUD and ANTI-CORRUPTION CULTURE within healthcare systems among both healthcare users and service providers and ultimately among all EU citizens. At the forefront of this objective is the development of an understanding of the importance of tackling fraud and corruption in healthcare and one’s role and responsibility in this. This objective will be furthered through the raising of awareness on this issue.
- To use all possible presentational and publicity opportunities to act as a DETERRENT to those who are minded to engage in healthcare fraud or corruption.
- The use of effective PREVENTION systems so that when fraudulent or corrupt activities are attempted, they will fail.
- The use of DETECTION systems that will promptly identify occurrences of healthcare fraud and corruption.
- The professional INVESTIGATION of all cases of detected or alleged healthcare fraud and corruption
- The imposition, where healthcare fraud or corruption is proven, of appropriate SANCTIONS – namely criminal, civil and/or disciplinary processes. Multiple sanctions should be used where possible.
- The seeking of financial REDRESS in respect of resources lost to fraud and corruption and the return of recovered resources to the area of patient care or services for which they were intended.
Under the leadership of the Director general of EHFCN, the first years are very active: creation of technical committees, structuring of operating modes, sharing of expertise and national experiences, sharing of information, exchanges of experts, and annual organization of an international meeting. New and politically sensitive, the fight against fraud is becoming an important issue for all the participants.
The structure is, initially, funded through contributions of members and more specifically through the subsidies of the European Commission. For three or four years, the network grows, takes initiatives, exchanges in particular with American, Canadian, South-African and New-Zealand counterparts. Nowadays, the network is only financed through subscription fees.
It has been quite a journey since the signing of the Articles of Association by the founding Members in 2005: some members have left, other new members have subscribed. EHFCN is very grateful to the group of loyal Members actively contributing to achieving the goals of the Network.
The path of the last 10 years has been fruitful and rewarding. In 2018 EHFCN is proud to count 20 members from 13 countries.
A retrospective evaluation was made in 2015 at the occasion of the 11th EHFCN Conference on Ensuring Financially Sustainable Healthcare in Europe where 10 years EHFCN were celebrated. The founding fathers and those who play a major role in the network were asked to share their most remarkable memories and vision for the future of EHFCN, summarised in a video ’10 years EHFCN’.
Some EHFCN realisations
I. Risk Measurement Toolbox
To achieve the aims of any counter fraud strategy, it is imperative to develop an understanding of both the nature and scale of fraud and corruption, or error, in areas of high risk. This allows the realistic setting of targets for reductions in the level of fraud or error and identifies the solutions needed to meet these targets.
Guide to undertake a risk measurement exercise (2005)
In the risk-measurement-guide the NHS method for fraud measurement is set out in eight steps. The basis of this guide is the Statistical Report of the NHS Counter Fraud Service which describes the statistical issues involved in designing and analyzing a risk measurement exercise.
This guide tries to make the measurement more usable by working out the method in steps and by using a practical example. The used example is based on the Dutch healthcare situation. In this guide the chosen example is a simple one group based work out. A more complicated example with subgroups and decisions about other types of incorrectness is worked out in a second document (A worked out example for using the ‘NHS fraud measurement exercise’ method).
The guide leads in eight steps to an estimation of occurrence of fraud and an estimation of the costs of fraud. These steps can be splitted into the following three phases:
- Phase 1: Design of a risk measurement exercise (Describe, classify and choose the group to examine; Calculate the minimal needed sample size for a certain degree of uncertainty; Select the cases that are included in the risk measurement exercise)
- Phase 2: Examination of a risk measurement exercise (Examine the selected cases)
- Phase 3: Analysis of a risk measurement exercise (Calculate the occurrence of fraud; Calculate the statistical uncertainty; Calculate the costs of fraud; Calculate the statistical uncertainty in the costs of fraud)
II. Manual of Guidance (2007)
With the financial support from the AGIS programme (AGIS 2007) of the European Commission, Directorate General for Justice, Freedom and Security.
In September 2005 a preliminary Operational Task Force meeting was held in London. Throughout the meeting it became evident there were no mechanisms in place across Europe to exchange information and best practices. It was therefore decided that action needed to be taken and that EHFCN was the perfect environment to begin this work. In 2006 members of the EHFCN applied to the European Commission for AGIS funding. The application was approved and the first Operational Sub-Committee (OPSC) meeting was held in London on 3 and 4 October 2006.
The OPSC undertook research and provided outcomes in relation to:
- Detecting and investigating healthcare fraud;
- Use of forensic investigation techniques;
- Development of high quality case management systems;
- Whistleblowing and dealing with informants;
- Proactive methods of countering healthcare fraud and corruption;
- Identifying lawful methods for sharing information;
- Creating information gateways and establishing operational contact points across Europe.
The research undertaken has led to the creation of a Manual of Guidance. It contained examples of fraud and corruption cases for each country, methods of detection and investigation, the application of types of sanctions, case management methods, and a directory of useful contacts in each European country in relation to the investigation of healthcare fraud and corruption.
III. The EHFCN Waste Typology Matrix © (2013)
In 2012 EHFCN has added ‘Waste’ to its scope aside from fraud and corruption. It was time to clarify the anti-fraud jargon and EHFCN developed the EHFCN Waste Typology Matrix ©, a unique lexicon of infringements with generic definitions and examples of different types of infringements.
This is important:
- to clarify and standardize definitions
- to improve the communication and data exchange
- to install a uniform way of reporting
- to exchange correct and accurate figures
- to make (international) benchmarking possible
- to target actions
Generic definitions of infringements, in a scale with an increasing degree of ‘intention’, are:
- Errors : unjustly obtaining a benefit of any nature by unintentionally breaking a rule or a guideline
- Abuses : unjustly obtaining a benefit of any nature by knowingly stretching a rule or guideline or by taking advantage of an absence of rule or guideline
- Fraud : illegally obtaining a benefit of any nature by intentionally breaking a rule
- Corruption :illegally obtaining a benefit of any nature byabuse of power with third party involvement
- Two major types of waste are on the one hand the violation of billing rules related to compliance and reality and on the other hand overconsumption or the provision and or prescription of unnecessary or too expensive care, contrary to guidelines, EBM and the principle of ‘bonus pater familias’
- Offenders are being called ‘outliers’ and ‘non respondent outliers’ are outliers who have not adapted their behavior after being informed and warned.
Find more information on the EHFCN Waste Typology Matrix ©, please click here.