Article

Safe recruitment in the NHS: fraud prevention

Information and guidance about the essentials and recommendations for safe recruitment practices within NHS organisations.

Publication date: 12 November 2026

Nurse in uniform working at a computer at night, with city lights visible through the window behind the desk.

Recent cases of individuals fraudulently gaining employment and undertaking work in the NHS have highlighted the importance of robust and secure recruitment processes. These processes help to protect patients and staff, as well as preventing financial and material theft.

Introduction

Employers should consider the guidance outlined in this article and review their practices and policies regularly.

Background checks

Any safe recruitment process within the NHS must be structured around the NHS Employment Check Standards. The standards help employers consider and implement pre-employment and background check requirements. They cover six elements:

identity
right to work
employment history and references
criminal records (for eligible roles)
work health assessments
professional registration and qualifications.

These checks provide assurance that individuals are of good character and have the experience, qualifications, skills and competence needed to perform the duties of the role properly and safely. Individuals must not be appointed until each applicable check has been completed and all necessary assurances have been obtained to establish their suitability for the role.

Regulations and compliance

All NHS providers are required to register with the Care Quality Commission. As part of this registration, providers are required to comply with the Health and Social Care Act 2008 (Regulated Activities) Regulations and the Care Quality Commission (Registration) Regulations (as amended).

Providers must have robust recruitment and employment practices to establish that each person is fit and suitable for the job they are being appointed to do. Employers can demonstrate compliance with these regulatory requirements by evidencing that they meet the NHS Employment Check Standards, which are mandated by the Department of Health and Social Care (DHSC).

What can be used to help make processes safer?

While complying with the standards is a key factor in safe recruitment, employers should be aware of the systems and tools that are available to support and strengthen their recruitment and employment processes.

To support organisations working through the NHS Employment Check Standards, employers might want to consider using a standard pre-employment checklist that records the evidence reviewed, the date of each check and the person who completed it.
A designated manager could be responsible for confirming that all applicable checks are complete before a start date is given. Any exception should be documented, risk assessed and approved at the appropriate level. An employment checks risk assessment template is available to download from the NHS Employers website and can be adapted as necessary for local requirements.
Inter Authority Transfer (IAT) is an automated process that reduces the administrative burden of recruiting new staff members from other NHS organisations within the Electronic Staff Record (ESR) footprint.
As part of the pre-recruitment process, information made available to the employing organisation can assist in verifying information provided as part of an application. This includes:
- employment service history from organisations using ESR
- employment reference form being sent to a previous employer for completion and returned to the requestor organisation electronically
- the standard factual reference notification highlighting whether employee relations information exists for an applicant.
With these features, IAT can help raise awareness among employers of indicators such as overlapping NHS employment, duplicate records or inconsistencies in employment history.
For more information, contact your regional Readiness and Implementation Team.
A Healthcare Professional Alert Notice (HPAN) is an official warning system used in the UK NHS to inform healthcare employers about registered practitioners who may pose a significant risk of harm to patients, staff, or the public. Managed and issued by NHS Resolution, requests must come from an executive board member or an authorised deputy.
Active HPANs are formally reviewed every three months (or sooner if new evidence appears) and can be withdrawn if interim restrictions are put in place by a regulator.
NHS trusts and approved healthcare organisations must verify new employees through the NHS Resolution Performer and Healthcare Professional Check portal or pre-employment checks.
Further information on HPANs can be found on the NHS Resolution website.

Learning from recruitment oversights in the NHS

Imposter fraud

The identity checks standard requires an in-person likeness check before an individual can begin their new role. This confirms that the person presenting for work matches the photographic identification provided during the recruitment process and is the same individual who applied for the role. It prevents an imposter presenting for a job they are not qualified or vetted for after recruitment checks have been completed. Omitting this fundamental step can compromise the patient safety and the other employees at the organisation. NHS Employers and the NHS Counter Fraud Authority have learned of multiple cases of imposter fraud, which involved employees working fraudulently and remaining undetected for significant periods because photographic identification was not properly examined for forgery or cross-checked against the individual.

External staffing providers

Employers must ensure that any agencies or other external staffing and service providers they contract use robust appointment processes that meet the same high standards applied to direct appointments. Employers should obtain this assurance through routine audits and monitoring of those providers. NHS trusts subject to agency rules must procure all agency staff, including nurses, doctors and other clinical and non-clinical staff, through framework agreements approved by NHS England. A real-life example that NHS Employers is aware of involved three individuals using one fake ID to submit timesheets through different employment agencies, thereby defrauding the NHS of thousands of pounds.

Reference checking

A recent high-profile case highlighted how failures to check and verify background information sufficiently can have severe and lasting consequences. An individual fraudulently carried out multiple concurrent NHS roles without the necessary experience or qualifications, having misrepresented their employment history and creating false references. This reinforces the necessity for employers to review all references for inconsistencies, and reconcile dates, roles and reasons for leaving against the application, employment history and any IAT information. Unexplained gaps or discrepancies should be resolved before appointment.

What actions to take if fraud is suspected or identified?

If at any point during the recruitment process information appears false, altered or inconsistent, the recruitment process should be paused and the concern documented. Staff should keep the relevant records and follow local escalation procedures, including referral to the organisation’s local counter fraud specialist (LCFS) where fraud is suspected. If appropriate HR, safeguarding, professional regulator, Disclosure and Barring Service or police routes should also be considered.

Should you need advice about a fraud concern, your NHS organisation will have details of their appointed LCFS through the staff directory and/or intranet. Suspected fraud can also be reported to the NHS Counter Fraud Authority (NHSCFA).

NHS Employers counter-fraud in recruitment hub

The counter-fraud hub contains links to all resources which can assist and support with fraud prevention in recruitment.

Further information

Resources (external)

NHS Employers communications

To keep up to date with information and developments in these areas, colleagues in NHS organisations can join our network, register on the Futures forum and subscribe to the Workforce Bulletin.

Contact

If you have any questions about safe recruitment, please email us.