Bromley CCG – Another Basic Public Sector Procurement Fraud

This has only at time of writing been picked up by The Bromley Times. A “senior commissioner”, working for the Bromley Clinical Commissioning Group, was jailed last week for two years and three months for defrauding his employer out of £145,000. He had already been convicted of fraud by abuse of position.

According to the Bromley Times report, he was “employed at the CCG from June 2012 via an agency”.  So does someone want to look at the IR35 disguised employment issues around that too?

He has apparently already paid back £93,681 to his former employer, so he obviously didn’t spend his ill-gotten gains on wine, women and fast cars. This is as much as we know about the crime:

During his time there, he was responsible for approving and managing mental health ‘cost per case’ care packages for patients with learning difficulties. An investigation revealed the CCG had received invoices for services that were never delivered”.

Those invoices led to £144,986.70 being paid into Morrow’s bank account. It doesn’t look like the cleverest fraud, to be honest, but yet again we end up asking - how it was allowed to happen? What were the procedures at the CCG? There are basic concepts here around “separation of duties” that every organisation should follow.

You just can’t have the same person holding a budget, approved to order goods and services, and allowed to sign off the invoice, all without another person’s approval or involvement. We don’t know how long this particular fraud went on – maybe it was picked up reasonably quickly. But basic checks on approvals and indeed on checking that whatever was bought was actually provided, would stop this sort of fraud. Yet time and time again we see these cases where it just seems too easy for someone to sign off fake invoices and approve money to go to their own accounts.

Now it is possible that Morrow was faking another approver’s signature too - that is an issue and someone who is that devious can execute a fraud even if you have decent processes in place.  Or it may just be that the processes were lax. If it was the latter, then I would fire the Finance Head of the organisation as well. If they allow such lousy processes to exist, whether or not it ends up in fraud really, then they should not be in that role.

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First Voice

  1. RJ:

    From the NHS Protect website:

    “The investigation began after Bromley CCG identified a potential fraud through its monthly financial reporting controls and notified the LCFS of a concern about Morrow on 6th May 2014, in respect of invoices for its Mental Health and Learning Disability Services. The Finance department had spotted a suspicious invoice from Choice and Independence Care Solutions Ltd and conducted further investigations, establishing that the company was registered to Morrow’s home address and a former address. The invoice was waiting for payment, and yet related to a patient whom Morrow had previously advised them was already discharged (and therefore not incurring these costs).

    The investigation uncovered links between Morrow and a second company, Blue Gale Ltd, that was also invoicing the CCG for delivery of care packages. Morrow had a sign off limit of £10,000 and all of the invoices from these two companies were just under that amount, so Morrow could authorise them himself.”

    Looks like a bit of a foolish but simple fraud but why did a contractor have a sign-off limit at all and why was he allowed to set up suppliers himself without any checks on their validity? Still lots of questions for the management.

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