Remember back in 2013, the UK government uncovered a major scandal involving two private security companies, G4S and Serco, which had been contracted to provide electronic monitoring services? Investigations revealed that the companies had charged the Ministry of Justice for monitoring people who were no longer subject to electronic tagging, including individuals who had returned to prison, left the country or died. The scandal eventually resulted in the companies repaying nearly £180 million in settlements relating to electronic monitoring and other contracts.

More than a decade later, I have been examining a different area of public service outsourcing: interpreting provision in the NHS. My investigation is concerned with how public institutions govern their relationships with commercial intermediaries, including how they account for public expenditure, oversee the delivery of services and establish how much of the money they pay is actually passed down to the professionals carrying out the work.

I submitted Freedom of Information requests to a small number of NHS Trusts as a pilot study. One of my questions concerned a straightforward aspect of contract management: how do Trusts verify that the interpreting services for which they receive invoices have actually been delivered? I asked whether they maintain records of services requested, delivered and invoiced, whether these records are reconciled, and whether periodic audits are conducted to identify discrepancies. The responses reveal considerable variation in the information held and the oversight arrangements described.

Guy’s and St Thomas’ NHS Foundation Trust, for example, reported that it does not routinely maintain reconciled data distinguishing interpreting services requested, delivered and invoiced. This does not necessarily mean that invoices are not checked or that the Trust lacks alternative verification procedures. However, it raises questions about how service delivery is monitored and how the institution establishes that invoiced services correspond to those actually provided.

Kingston and Richmond Trust initially told me that the information was not held. After I pressed for a more detailed response, the Trust offered a clearer picture of its verification process. It explained that individual heads of service within departments are responsible for confirming that interpreting services have been delivered before invoices are authorised. However, it also confirmed that there is no formal written policy or guidance documenting this arrangement, no central Trust function checking invoices against delivered services, and no periodic audits or reconciliations to identify discrepancies.

Moorfields Eye Hospital NHS Foundation Trust took a different approach. When I asked about the procedures used to verify that invoiced interpreting services had actually been delivered, the Trust invoked Section 43(2) of the Freedom of Information Act, citing commercial interests as grounds for withholding the information. I find this particularly concerning. I was not asking how much the Trust pays its supplier or seeking commercially sensitive pricing arrangements. I was asking whether a publicly funded institution verifies that it has indeed received the services for which it is being invoiced. Why should information about accountability for public expenditure be treated as commercially sensitive?

The electronic tagging scandal demonstrated the importance of verifying that outsourced services have actually been delivered before paying for them. I have found no evidence of comparable misconduct in the NHS responses, nor am I suggesting any. But the question remains: how do public institutions verify that outsourced services have been delivered, and how do they know their oversight arrangements are effective?

Another finding from my FOI investigation adds a further dimension to this issue. None of the ten NHS Trusts whose responses I examined provided information about how much of the money paid to commercial intermediaries is passed down to the interpreters delivering the services. Some explicitly stated that they did not hold this information because interpreting was provided by an external supplier.

And this is why I am furious. My PhD research has documented practices within the outsourced interpreting industry that raise serious concerns about fairness, pay and working conditions. Yet the public institutions purchasing these services appear to have limited visibility of how the money they spend is distributed to the people actually doing the work.

I had previously raised concerns about these arrangements with the Department of Health and Social Care. Its response was:

Non-NHS organisations that are contracted to deliver NHS services are independent organisations. As such, they are not bound to the national terms and conditions, for example Agenda for Change, and can develop their terms and conditions as they see fit. This includes the pay scales they use and the extent to which pay awards are made. It is for them to determine what is affordable within the financial model that they operate.

I find this response troubling, not because I expect every interpreter working under an NHS contract to be employed directly by the NHS, but because it raises a fundamental question about institutional responsibility. If public institutions can outsource services without knowing how much of the public money reaches the professionals delivering them, and if employment conditions are treated as matters entirely for the commercial intermediary, who takes responsibility for ensuring that public procurement does not contribute to unfair or exploitative working arrangements?

The FOI responses I have received do not provide a complete picture of NHS interpreting governance. This was a small pilot study, and I do not intend to spend the foreseeable future sending FOI requests to every NHS Trust in the country. I would much rather see these questions become part of a wider societal conversation about how we govern outsourced public services, what information public institutions should be expected to hold, and what responsibilities should accompany the spending of public money.

I hope we can begin that conversation during Fair Translation Week, 19–25 October 2026, an initiative of the Due Diligence Club, a grassroots movement I founded with fellow linguists to advocate for a fairer translation and interpreting industry across both the public and private sectors.

Let’s call for better governance of our public services, fairer working conditions and a more equitable distribution of the value created by language professionals.

Blog image by:
Ian Taylor on Unsplash