Kent County Council’s £4m NHS Invoice: Zena Cooke, Ivor Duffy and the Missing Evidence

Zena Cooke (pictured below left) has moved on. So has Ivor Duffy (pictured below right). Cooke is now Lambeth Council’s Corporate Director of Resources and its statutory Section 151 Officer. Duffy was succeeded as NHS Kent and Medway’s chief finance officer in January 2026, and his public LinkedIn profile now identifies Kent Community Health NHS Foundation Trust as his employer.

 

But one piece of unfinished business from their time at the top of Kent’s public-sector finance system hasn’t moved on with them.

It concerns £4 million.

In April 2021, Kent County Council raised an invoice for £4m to an NHS Clinical Commissioning Group. The description was strikingly broad: “20/21 contribution to joint investment with adult social care for vulnerable adults”. When Grant Thornton, KCC’s external auditor, examined it, KCC couldn’t provide what the auditor called “sufficient appropriate evidence” to support raising the debtor. The council took the prudent step of not recognising the sum as revenue in its 2020/21 accounts, but Grant Thornton still identified a control failure: an invoice shouldn’t have been raised without sufficient contractual evidence behind it. When the matter later reached councillors, the official minutes described it even more starkly as a “£4m invoice to an NHS CCG without any supporting evidence”.

That’s the nub of this story.

A £4m invoice existed. Grant Thornton couldn’t establish the documentary foundation needed to justify it. Five years on, we still haven’t found a published record identifying who instructed KCC to raise it, who authorised it, what formal agreement sat behind it or who on the NHS side approved the corresponding transaction.

At the time, Cooke was KCC’s Corporate Director of Finance and Section 151 Officer — its statutory finance chief. Duffy was chief finance officer of Kent and Medway CCG and subsequently moved from the CCG into the new Kent and Medway Integrated Care Board when the NHS commissioning structure changed in July 2022. Contemporary material identifies Duffy as coming to the ICB finance role from Kent and Medway CCG.

Those positions make both relevant to the story, but they don’t establish that either personally ordered, approved or processed the £4m transaction. What their seniority does mean is that, as the finance chiefs on either side of a £4m movement of public money, it’s entirely reasonable to ask what each knew, when they knew it and what role, if any, they played in approving or overseeing it.

That’s an important distinction. The public record tells us who occupied the senior finance posts; it doesn’t reveal the individual decision-making chain behind this invoice. Turning job titles into proof of personal responsibility would go further than the documents allow.

What the documents do allow us to say is that the missing paperwork matters. And what we’ve now found makes it much harder to dismiss that absence as some routine filing cock-up.

KCC already knew how substantial joint health-and-social-care funding arrangements were supposed to be documented. Take its Integrated Community Equipment Service. That was jointly funded by KCC and NHS CCGs under a Section 75 partnership arrangement. KCC’s own decision papers recorded an annual budget of about £11.4m, specified KCC’s £5.64m contribution, said the CCGs would fund the remainder, created pooled and aligned budgets, pointed to a “Schedule 3 – Contributions” and placed governance through an ICES Partnership Board. The papers also expressly said the Section 75 agreement provided financial protections for the council.

That doesn’t mean the mystery £4m invoice was for ICES. There’s no evidence allowing us to say that, and we don’t.

It shows something more useful.

When KCC and NHS commissioners genuinely put millions into a joint service, there could be a documentary trail setting out the legal framework, each party’s contribution, how the pot worked and who governed it. The missing £4m agreement matters because arrangements of this kind weren’t some exotic bureaucratic invention that nobody in Kent finance had ever encountered.

There’s another example from almost exactly the same part of the public-sector landscape. In April 2022, KCC approved joint commissioning of a Community Mental Health and Wellbeing Service with Kent and Medway CCG and Medway Council. The NHS contribution for the initial three-year contract was put at £4.466m. KCC’s papers didn’t simply say the partners would sort the money out between themselves: they recorded that a Section 256/Memorandum of Agreement would be entered into by the parties to provide the framework for working together and to include “financial protections for KCC”.

Again, that service isn’t evidence of what the April 2021 invoice was for. It’s evidence of something else: KCC’s own records show that multi-million-pound health and social-care collaborations could come with agreements, contribution figures, legal provisions and identified authority for entering the necessary contracts.

Which brings us straight back to Grant Thornton.

In its follow-up work, the auditor recorded the original £4m problem under the heading “Insufficient evidence for raising revenue debtor”. Management’s response was that it had been an isolated incident and that the importance of having clear evidence before invoices were raised had been reiterated to staff. Grant Thornton subsequently reported that its 2021/22 procedures hadn’t identified any further examples of invoices being raised without appropriate documentation.

So the finding wasn’t that KCC routinely raised unsupported invoices.

It was that this one happened.

Councillors plainly weren’t content to leave matters there. At the Governance and Audit Committee on 16 March 2023 they raised concerns about the management response to the £4m NHS invoice and specifically asked for more information about “how the issue occurred” and for assurances about how a repeat would be prevented. The committee formally resolved that its assurance was subject to receiving that detailed response.

That should’ve moved the story towards an answer.

Instead, two months later, it hit a closed door.

On 18 May 2023, members raised the £4m transaction again. This time they were told an update couldn’t be given because the matter was “currently under investigation”. Cooke told the committee that closer collaboration had developed between Adult Social Care and the NHS system. The published minutes record the investigation. What they don’t record is its eventual finding.

That missing outcome is now as important as the missing agreement.

KCC’s public record establishes an external-audit concern, a demand from councillors for a detailed explanation and, two months later, an investigation under way. Our searches of the council’s subsequently published material haven’t located a public report telling councillors — or Kent residents — who authorised the £4m invoice, why it was raised without the evidence Grant Thornton expected, or what that investigation ultimately concluded.

Then comes a separate strand of the story, and it has to remain separate.

Cooke was still publicly carrying out her KCC role at Cabinet on 4 January 2024. KCC’s own minutes record her attending as Corporate Director of Finance. The council’s later audited accounts then record that she was absent from the role from 8 January 2024 and that an Acting Corporate Director Finance filled it from that date until 31 March. The accounts don’t state why she was absent.

Cooke formally left the post on 31 May 2024. KCC’s 2024/25 accounts disclose £65,502 salary, a £1,333 allowance, £116,529 as “Compensation for loss of Office e.g. Redundancy Payment”, £13,873 under “Other” and £5,492 in employer pension contributions. Her total remuneration excluding pension was £197,238 and including pension £202,730.

The figure that matters when discussing her departure is therefore £116,529.

£202,730 wasn’t the payoff. It was Cooke’s total disclosed remuneration for the year, including pension contributions. The accounts separately identify £116,529 as compensation for loss of office, and also record a single 2024/25 exit package in the £80,001-to-£120,000 band for exactly that amount.

That matters because it’s tempting to draw a line through the chronology and assume the pieces belong together.

First came the £4m NHS invoice, which Grant Thornton found lacked sufficient supporting and contractual evidence. In May 2023, KCC told councillors the matter was under investigation. Then, from January 2024, Cooke was absent from her post; she left the council in May and the accounts later disclosed the £116,529 compensation payment.

The sequence naturally raises the question of whether those events were connected. But chronology isn’t proof. On the evidence we’ve found, it’s legitimate to ask the question; it isn’t legitimate to claim we know the answer.

Duffy’s chronology points the other way. He remained in senior NHS finance for years afterwards. He moved from Kent and Medway CCG into the successor ICB and remained its chief finance officer until Jonathan Wilson took over in January 2026. When announcing Wilson’s appointment, NHS Kent and Medway publicly thanked Duffy for his years of work, dedication and support as CFO.

His public LinkedIn profile now names Kent Community Health NHS Foundation Trust as his employer. It doesn’t publicly display a precise job title in the material we can see, and we haven’t found a KCHFT document confirming one, so it’d be wrong to invent it.

Cooke, meanwhile, is once again occupying a statutory finance role. Lambeth Council currently names her as Corporate Director of Resources and Section 151 Officer. On 30 June 2026, a formal notice explaining the delay to Lambeth’s 2025/26 unaudited accounts was issued in her name as “Corporate Director – Finance (S151 Officer)”.

The people, in other words, have moved on.

The audit trail hasn’t.

We still haven’t found a published document identifying the officer who instructed KCC to raise the £4m invoice; the person who authorised it; the corresponding authority on the NHS side; the agreement, memorandum, Section 75 arrangement, Section 256 arrangement or other contractual instrument — if there was one — supporting the claimed “joint investment”; or the eventual finding of the investigation KCC told councillors was under way in May 2023. None of the formal joint-funding arrangements we’ve examined can safely be identified as the source of this particular £4m.

That’s important because the new evidence doesn’t solve the £4m mystery.

It makes the mystery more precise.

KCC’s own records show what the paperwork around substantial joint NHS–council funding could look like: an identified legal mechanism, stated contributions, governance arrangements, schedules and financial protections. Grant Thornton’s finding shows that when it came to this £4m invoice, KCC couldn’t provide sufficient appropriate evidence to support raising it. Councillors then asked how that had happened. Two months later, they were told it was under investigation.

Five years after the invoice was raised, that leaves a considerably narrower — and stronger — question than any allegation against an individual.

Where is the document that authorised £4 million of purported joint NHS–adult-social-care investment, and what did KCC’s investigation eventually find when councillors asked how an invoice that large had been raised without the evidence its external auditor expected to see?

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The Shepway Vox Team

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