TIAA commissioned a review from the Chartered Institute of Public Finance and Accountancy (CIPFA) of our Counter Fraud arrangements.
The review tested TIAA’s approach to:
- the effectiveness of our capabilities to deliver effective counter fraud services,
- our internal processes and operations,
- whether TIAA operates in line with Government Standards, legislation and best practice.
By comparing the equivalent of the investigation process to that of other investigation service providers, CIPFA identified themes of good practice at TIAA. These include:
- Working within approved government functional standards.
- Working to best practice set out within a detailed investigation manual, supported with relevant, informative and clear guidance documents.
- Focusing resources on areas of greatest risk.
- A regime of continuous monitoring of work, guidance material and staff training.
- Improved early identification, and the subsequent management, of issues arising.
- Continuous improvement driven by lessons learned reviews.
- Appropriate and timely revision to policies & procedures; and
- Proportionate engagement with partner agencies
The outcomes against each area reviewed are attached below, along with a brief summary of the commentary against each area:
Governance and Management Framework – Substantial Assurance
‘The review found that TIAA undertook internal review activity on a regular basis. CIPFA found the proactive monitoring and review of internal activity to be evidence of good practice and sets expected standards for others to follow.’
Action Plans – Substantial Assurance
‘This review found that TIAA investigation activity is carefully planned and documented from the outset. The Investigation Plan used by TIAA staff is clear and concise, capturing all relevant information prior to the commencement of an investigation. This includes detailed information on the subject of the investigation, an evaluation of the intelligence source, the offences and points to prove and the scope of the investigation and points to prove, amongst other things.
CIPFA found that the implementation of the Investigation Plan led to a clear understanding of required activity and aided in the management of a timely and thorough investigation.’
Decision Making – Substantial Assurance
‘Pre investigation decisions are clearly supported through guidance that sets out the process for opening investigations, defines the roles (of those involved) and provides Investigators with acceptance criteria to assist in the identification of cases that should be progressed.
TIAA follows clear timescales for decision making and records decisions both on investigation plans, but within accessible case management systems. The Investigation Manual clearly sets out expectations placed upon its staff for making and recording decisions and the expected supporting documentation.’
Roles and Responsibilities – Substantial Assurance
‘The review found there was a clear reporting line and distinct responsibilities regarding the management and delivery of investigation work. Management responsibilities were clearly defined as providing quality technical advice, investigation strategy and case direction advice on a variety of investigations. Investigation responsibilities were clearly set out within the Investigation Manual and included but was not limited to setting out the initial terms of reference, collecting evidence, interviewing witnesses, drawing conclusions and writing a final report making recommendations.’
Risk Assessment – Substantial Assurance
‘CIPFA is confident that TIAA could deliver a successful Fraud Risk Assessment for its clients and provide them with robust fraud risk measurement, define controls and mitigating activity, provide guidance and advice on the same and produce a thorough fraud risk management activity plan.’
Loss Measurement – Substantial Assurance
‘Loss measurement is also used by TIAA to continually monitor value for money and ensure investigation work is cost effective to both the client and the organisation.’
Training and Awareness – Substantial Assurance
‘CIPFA found that all TIAA resources were qualified to a minimum Accredited Counter Fraud Specialist level (expected industry standard) and had significant experience in the management and delivery of fraud investigations across a plethora of public services.’
Application of Relevant Legislation – Substantial Assurance
‘A review of the Investigation Manual and TIAA’s guidance documents and standard templates found that TIAA considered and applied all aspects of legislative requirements in their delivery of work. This is evidenced in both the reference to and explanation of specific legislation (as it pertains to investigations) within guidance documents and TIAA’s own internal review of its activity and adherence to such legislation.
The review found TIAA kept abreast of legislative changes and continually reviewed the impact such changes would have on its service delivery.’
CIPFA provided substantial assurance over all aspects of our Counter Fraud Service. Concluding:
The review found that TIAA undertook internal review activity on a regular basis. CIPFA found the proactive monitoring and review of internal activity to be evidence of good practice and sets expected standards for others to follow.’
Should you wish to discuss any aspect of our service, details of this review or would like to receive a copy of the full report, please do not hesitate to contact us.