Findings (continued)

Putting it right

Definition

2.227 Putting it right means detecting when payments go wrong and taking prompt action to correct them, with appropriate penalties to prevent a recurrence. It is vital that fraud or error is detected as soon as possible to allow remedial action to start.

2.228 The greater emphasis on securing the gateways is intended to allow fraud investigators to concentrate activities on those who intend to steal from the social security system. There are a number of crucial areas to make this work:

• ensuring that fraud investigators are well-trained
• providing high quality referrals to investigators
• passing on experience and information to other investigations without delay
• publicising the activities of investigators
• sharing information with other agencies
• recording overpayments and making every effort to recover them
• applying a wide range of sanctions to people who steal from the benefit system.

Findings

2.229 We assessed LB Haringey’s performance in Putting it right in the key areas of:

• Countering fraud
  • counter fraud organisation, resources and management
  • investigation quality, documentation and methods
  • fraud performance and WBS
  • administrative penalties and prosecutions
  • working with BFIS and data matching
  • internal fraud team
• overpayments
  • total HB debt
  • preventing overpayments
  • identifying overpayments
  • classifying overpayments
  • notifying people concerned
  • recovering overpayment debt
  • write off.

Countering fraud

Counter fraud organisation, resources and management

Counter fraud organisation and resources

2.230 BIS is responsible for investigations, prosecutions and other sanctions, fraud awareness training, proactive detection, publicity, home visits, internal benefit fraud investigation and WBS achievement. It is part of the benefit unit and was established in 1994.

2.231 Staff told us that resources are stretched, with BIS having more work than it can deal with. This is reflected in the number of referrals closed without further action. Considering this pressure of work, the diverse range of proactive fraud project work carried out is commendable.

2.232 Two clerical staff support the BIS investigators. This provision may be inadequate, and all investigators and visiting officers (VOs) spend time on clerical work.

We recommend that the level of clerical support is reviewed with a view to releasing more investigative time.

2.233 BIS is staffed as shown in Figure 2.24.

Fig. 2.24: Staffing of BIS

Duty	Number of staff	BFI comment
Section manager	1
Internal investigation team	2	LB Haringey‘s establishment states there should be 3 staff.
External investigation team	4 Investigators and 1 team manager	Establishment states that there should be 5 investigators. Resources should be increased to provide for more investigation staff.
Visiting team	5 VOs and 1 team manager	Cadre listed by LB Haringey, should have 10 VOs.
Clerical support	2	Inadequate for the number of investigative VOs and VF staff in post or to be recruited.

Source: LB Haringey and BFI

2.234 VOs visit claimants to verify their circumstances. These visits are randomly selected from RA claimants.

2.235 The effectiveness of the visiting team has significantly reduced in identifying residency fraud. Anecdotally, we were told that during the first 3 or 4 years of operation its WBS success rate was about 40%. This has now dropped to about 5%.

2.236 Figure 2.25 shows the number of residency visits.

Fig. 2.25: Number of residency visits carried out by BIS

Year	1st visit	2nd visit	3rd visit	Total visits
1998/99	14,995	11,787	4,852	31,634
1999/00	25,939	19,644	8,255	53,838
1/4/00 to 30/09/00	7,907	6,009	2,369	16,285

Source: LB Haringey

2.237 Figure 2.26 shows the number of cases where WBS was claimed in respect of residency visits carried out by the VO team.

Fig. 2.26: Percentage success rate based on number of claimants visited and number of WBS claims made

Year	Number of claimants visited	Number of WBS claimed	Percentage success rate
1998/99	14,995	1,230	8
1999/00	25,939	1,223	5
1/4/00 to 30/09/00	7,907	527	7

Source: LB Haringey and BFI analysis.

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2.238 Fraud referrals are either allocated to investigators by the team manager on a priority basis, or selected by investigators when individual caseloads are low.

2.239 The BIS manager and team managers are experienced fraud practitioners, with strong fraud backgrounds. This experience has been effectively shared with the investigators and support staff, as we saw during the 5 weeks spent working alongside the team during the on-site phase of the inspection.

2.240 Although residency check visits make up the bulk of the work, there is some evidence of quality investigation work across a range of benefit fraud. Most fraud referrals are made by the processing teams and residency visits are selected with the objective of covering every property in the borough.

2.241 We commend LB Haringey for its very strong counter fraud approach in identifying non-residency fraud, but are concerned about the low percentage success rate between visits carried out and results achieved.

2.242 National findings of types of confirmed fraud produced in the National Housing Benefit Accuracy Review 1997/98 shows that 0.3% to 0.7% of HB caseload is subject to non-residency fraud. Extrapolating these figures suggests there should be between 92 and 214 such cases in LB Haringey’s caseload for 1999/2000.

2.243 However, there were 1,223 WBS cases identified under this category in the 1999/2000 operational year. The number of non-residency cases in LB Haringey is over 5 times that indicated by researched analysis of confirmed fraud. This may be related to the high proportion of private sector claims in the caseload and the mobility of the population.

Management controls

2.244 The files we sampled contained little evidence of managerial or supervisory checks of investigative activity, WBS claims or prosecution suitability. The following management checks and reviews should be carried out:

• all BIS staff receive a performance development review (PDR) every 6 to 8 weeks. This is a set of agreed work objectives linked to the BIS business plan. At the end of the year there is a review of individual performance that informs future training needs
• all BIS staff receive a ‘case-callover’, where management selects current fraud, internal team and VO team cases for a critical review
• all referrals to BIS are vetted by the manager of the investigation team. Similarly, all cases that relate to a claim for WBS are checked by the relevant manager
• WBS is reconciled by managers at various stages throughout the operational year, and again before sending the fourth quarter’s subsidy return.

2.245 We were shown a fraud file management checking sheet used for individual fraud cases. Although this was comprehensive, and addressed many important checking issues, we found no completed forms in the 53 closed fraud cases sampled. We commend LB Haringey for developing this control sheet, but a structured and effective approach to ensuring that work outputs in BIS are managed is needed to produce maximum efficiency.

We recommend that LB Haringey ensures that management checks are carried out and results recorded on the fraud files and the fraud case management system.

Investigation quality, documentation and methods

Investigation quality

2.246 To assess the standard of fraud investigation work, we compared LB Haringey's investigations against best practice criteria. Figure 2.27 shows the results.

Fig. 2.27: Criteria requirements used to determine the quality of fraud investigation work in LB Haringey

Investigation quality	Evidence requirements	LB Haringey
Comprehensive investigations (recommended)
	Claimant interviewed where appropriate.	Rarely in residency visit cases, whenever possible in other investigations.
	Landlord interviewed where appropriate.	Rarely.
	Questioning, under caution where appropriate, is of a high standard and noted on file.	Always in interviews under caution (IUCs), little evidence in other cases.
	In WBS cases, the requirements of the Income Related Benefits (Subsidy to Authorities) Order 1998 have been met.	Sample findings of WBS validity, show a 26% error rate.
	Employer visited.	Rarely.
	Written earnings details obtained using inspectors' powers under sections 110A and 110B SSAA 1992.	No inspectors appointed.
	Observations carried out.	Evidence of some short term observations carried out.
	Other agencies contacted to obtain evidence.	Yes.
	IUCs carried out.	In those considered potential prosecution cases only.
	Evidence of fraud obtained suitable for prosecution consideration	In those considered potential prosecution cases only
	Evidence that a false claim for benefit has been obtained, either in the claim or renewal form.	Yes.
	In residency check cases the investigation is not restricted to 1 or 2 negative visits only.	Yes.
Adequate investigation	Evidence of some of the above, and if appropriate leading to the satisfying of the WBS and/or fraudulent overpayment criteria. Investigations that have stopped short of further necessary action, such as interviews with employer, landlord or other witness. The absence of evidence from these and other sources lessens the opportunity to identify possible prosecution cases.	In many cases investigation stops when the investigator felt that WBS criteria has been satisfied. Sample findings suggest this is a feature of many fraud investigations carried out.
Less than adequate investigation	Little evidence of the above leading to superficial investigations, where conclusions have been reached which may be wrong.	Sample findings refer.

2.247 Using these criteria, we looked at the quality of investigations in a sample of 53 closed investigations. Figure 2.28 shows our findings:

Fig 2.28: Closed fraud referral investigation cases 1/4/2000 to 30/9/2000

Investigation	Number of cases	Comprehensive	Adequate	Less than adequate
Fraud cases closed including residency visits	53	6	21	26
Percentage	100	11	40	49

Source: BFI sample and analysis.

2.248 Despite the evidence of some quality investigations, around half of fraud investigations are closed after a less than adequate investigation. Two case studies illustrate this:

Case study 1 –The claimant was alleged to be sub-letting a property on which HB was being paid. BIS obtained evidence that mail was being sent to other people at this address. The claimant was not interviewed, postman not spoken to, there was no search of the system by address and there were no observations. The case was closed with no fraud found.

Case study 2 – Anonymous information that claimant and family were involved in benefit fraud. Referral received under cover of a press article where the government were exposing benefit cheats. The case was opened on 4 February 2000 and closed on 29 August 2000 with no investigative action taken.

2.249 We were, however, impressed with the comprehensive nature of some investigations. Again this is best illustrated by a case study.

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Documentation and completed investigations

2.250 The Criminal Procedure and Investigations Act 1996 code of practice came into force from April 1997. It places responsibilities on any officer involved in a criminal investigation to record and retain material and other information relating to that investigation. The Act provides a statutory framework for disclosure of unused material. Throughout an investigation officers must act fairly. This means that in every investigation, no matter how brief, all investigators must ensure that:

• notes taken at the time and other file notes are meticulously maintained
• all recorded information is strictly factual
• records are kept of all information obtained in the course of the investigation
• all reasonable lines of enquiry are pursued
• all written and computer records are retained and identified
• all tapes from IUCs are retained, identified and can be retrieved for up to 7 years.

2.251 We found that:

• BIS keeps clerical fraud investigation case notes, based on uniform documents in a standard file order
• the clerical system is supported by a case management database in MS Access
• a summary is included for closed fraud cases. This provides an excellent closure narrative, and is supported by good written activity logs.

2.252 Our sampling of completed investigation files revealed an excellent audit trail of action from the opening of a fraud case to its closure.

2.253 BIS follows the agreed procedures for exchanging information with BFIS about new investigations using an SLA1 form.

2.254 Our analysis of 53 closed investigation cases made during 1999/2000 showed:

• the actual or potential amount of the overpayment justified considering prosecution in 5 more cases
• there was no record on the fraud file, or the system, of reasons for not considering prosecution action in appropriate cases
• there was no evidence of management checks on file
• there were completed referral forms in every appropriate case
• excellent use is made of case closure summary sheets
• some written statements were taken during interview from many claimants suspected of fraudulent activity
• there was a 60% failure by the benefits section to notify BIS of actions taken in response to recommendations made by BIS after an investigation. The internal procedures have a set method for this, the BF7 process. But this was not completed in most cases
• there are some other positive elements to investigation quality such as completing WBS1 forms where appropriate and making excellent use of external information sources. These sources include Equifax Prophet, QAS, DVLC and the Land Registry.

2.255 The quality of fraud investigations is less than adequate in 49% of cases sampled, although this figure includes unsuitable referrals that would be excluded if there was a formal sift. We also accept that referral quality and the availability of resources will affect this area, however,

We recommend that LB Haringey:

• develops a training needs analysis and staff development programme covering issues such as the use of IUCs, evidence requirements for prosecution cases, and WBS claim rules
• reviews the important process of BF7 notification from the benefits section to BIS to ensure 100% compliance.

Investigation methods

2.256 We considered the investigation methods available to LB Haringey and whether it uses them effectively. These methods are:

• observations
• interview of suspects
• use of inspectors’ powers.

2.257 Observations can be time-consuming and resource intensive, but they are a necessary part of good investigation work. We found some evidence of observations. However, from our sampling and interviews with investigators, LB Haringey does not carry out sufficient observations in all cases where these are needed to prove that fraud exists. It may be that the quality of investigation is compromised in the drive to achieve WBS.

We recommend that LB Haringey identifies fraud cases where observations are required to establish fraud, and make resources available to carry out observations to an acceptable standard.

2.258 In 2 cases of the 53 sampled, there had been an IUC. However, this would have been appropriate in a significant number of other cases. The code of practice to the Police and Criminal Evidence Act 1984 requires a caution to be given in circumstances where an investigator has grounds to suspect that the interviewee has committed a criminal offence. The purpose of an IUC is to safeguard the civil liberties of the suspect and that, unless there is an IUC, it is impossible to prosecute.

2.259 The Subsidy Order requires proof of either a deliberate false statement or that the claimant or landlord had both knowledge and intent to commit a fraud. This is difficult to establish without structured interviewing of claimants, landlords, and other witnesses and will almost always require third party evidence if there is no interview. It requires evidence of criminal behaviour at the civil standard of proof. An IUC is necessary in these circumstances.

2.260 Our sample of closed investigation cases revealed some cases where this standard was not met, especially in residency visits. As a result, we found some 26% of WBS claims to be invalid. The section on Fraud performance and WBS claims has further details on our findings.

2.261 We were told that management has agreed a prosecution target of 6 a year for each investigator, plus 12 accepted administrative penalties. This will require more use of IUCs and a higher standard of evidence of fraud obtained. Potential prosecutions are logged onto the system, and are monitored by management.

2.262 We welcome this positive move towards a fraud operation based on the use of sanctions, and commend LB Haringey for its initiative.

2.263 LB Haringey has not appointed any officers as inspectors under section 110A of the Social Security Administration Act 1992. The local government associations lobbied hard for the extension of these powers to local authorities so it is disappointing that no use has so far been made of this initiative.

We recommend that LB Haringey urgently:

• ensures that some operational staff are appointed as inspectors
• identifies suitable cases and uses the powers effectively.

Fraud performance and WBS

2.264 In 1999/2000, LB Haringey was set the third largest WBS threshold in the UK. Historically, it has consistently exceeded the WBS threshold figure, mainly through residency check WBS claims. Management assured us that BIS was not directed to be self-financing through WBS claims, but given the challenging targets set, front line staff indicated that they were under regular and intense pressure to maximise WBS.

2.265 LB Haringey has sought to balance residency checks with benefit fraud investigation work. This ensures the VOs generate sufficient WBS to enable the investigation team to focus on in-depth fraud investigations. However, as the WBS derived from residency checks is diminishing it is essential that other avenues of fraud detection are explored.

2.266 Counter fraud resourcing in LB Haringey could be adversely affected because of the current projected WBS shortfall compared to previous years.

2.267 LAs have a duty to provide adequate resources to counter benefit fraud effectively and WBS subsidy was only intended to provide further incentive in this area. We are concerned that any unwritten self-financing message could reduce BIS's effectiveness.

2.268 Along with many other LAs inspected, LB Haringey has had some difficulty meeting the evidence criteria for proving fraud to enable it to claim under the Income-related (Subsidy to Authorities) Order 1998. Although LB Haringey had an unacceptable 26% error rate, this is still better than many other LAs we have inspected.

2.269 The quality of investigation is excellent in the cases identified for possible prosecution, and in many other cases where neither prosecution nor WBS were involved.

2.270 In some other cases where WBS had been claimed, fraud had not been proven. We sampled 53 completed fraud cases from April to September 2000 of which 31 were the subject of WBS claims.

2.271 Figure 2.29 shows our findings.

Fig. 2.29: WBS validity

Number of WBS cases claimed	Number of WBS cases sampled	Number of WBS cases invalid	Percentage error rate
620	31	8	26

Source: LB Haringey MIS and BFI sampling

2.272 One of the 8 cases would have been valid at the 75% rate. The cases in our sample will be subject to a reconciliation check by BIS at the end of the year. External Audit also reviews and validates the WBS claim. Both of these processes should improve the validity rate. Making sure things work contains some more details on the work of External Audit.

2.273 Figure 2.30 shows the range based on the above figures at 90% confidence.

Fig. 2.30: WBS sample and error range

		Range of invalid WBS cases
Size of population - total WBS claims made 1/04/00 - 30/09/00	620
Size of sample	31
Number of errors	8
Upper confidence level	38.4%	238
Mean	25.8%	160
Lower confidence level	13.2%	82

Source: BFI analysis

2.274 This shows that at least 82 of all WBS claimed by LB Haringey in this period may not be valid.

We recommend that LB Haringey reminds the appropriate staff of the criteria for claiming WBS.

Administrative penalties and prosecutions

Policy

2.275 Prosecutions and administrative penalties are effective sanctions against fraudsters and, with appropriate publicity, they have a strong deterrent effect. LB Haringey has a stated formal prosecution policy, and we were encouraged to see the clear management focus on the use of sanctions, including prosecutions.

Prosecution work

2.276 Although we acknowledge that LB Haringey is aiming to increase the number of benefit fraud prosecutions it achieves, we consider the current numbers of prosecutions and sanctions to be low. Locally, BFIS prosecutes or agrees administrative penalties for between 60 to 100 cases a year.

2.277 Figure 2.31 shows the number of LB Haringey prosecutions from 1 April 1997 to 31 March 2000.

Fig. 2.31: Number of prosecution cases in LB Haringey

Year	Number of prosecutions initiated	Number of successful prosecutions	Number of prosecutions pending
1997/98	5	5	0
1998/99	2	2	0
1999/00	9	9	0

Source: LA questionnaire

2.278 In LB Haringey, after the claimant has been interviewed under caution, BIS refers potential prosecution cases to the Legal Department. We sampled 12 cases of pending and completed prosecution cases. The following table shows our findings, using the same criteria of investigation quality described above.

Fig. 2.32: Review of prosecution cases in LB Haringey

Value of O/P	£91,106
Allegation/charge	6 counts of false accounting.
Outcome/judgement	27 months imprisonment. The council successfully applied for a charging order against the claimant for £91,106. The property was sold, and the HB overpayment repaid in full. 1998.
Comment	Comprehensive investigation and good use of recovery methods.
Value of O/P	£4,059
Allegation/charge	Working and claiming HB. No declaration made of employment.
Outcome/judgement	Guilty plea entered. Conditional discharge for one year.
Comment	Comprehensive investigation. We are concerned that IS was also in payment, but BA was unable to calculate the IS overpayment in time so the claimant was charged with HB fraud only.
Value of O/P	£14,694
Allegation/charge	7 counts of false accounting.
Outcome/judgement	Guilty plea entered. 6 months imprisonment.
Comment	Comprehensive investigation. WBS prosecution incentive claim made.
Value of O/P	£13,624
Allegation/charge	6 counts of false accounting. Undeclared income, fictitious dependants and contrived tenancies.
Outcome/judgement	Court appearance pending.
Comment	Comprehensive investigation.
Value of O/P	£3,052
Allegation/charge	Claimant sublet a property while in receipt of HB for the same property.
Outcome/judgement	Pending. File being referred to the legal department to consider prosecution.
Comment	Comprehensive investigation.
Value of O/P	£10,296
Allegation/charge	6 counts of false accounting. Did not declare employment while claiming HB. Employed by a neighbouring council.
Outcome/judgement	Awaiting court date.
Comment	Comprehensive investigation.
Value of O/P	£14,000
Allegation/charge	Obtaining money by deception. Did not declare employment while claiming HB. Was employed by a recruitment agency within an HA.
Outcome/judgement	Guilty. Imprisoned for 8 months. Compensation order of £796, to be paid within 30 days.
Comment	Comprehensive investigation.
Value of O/P	£30,058
Allegation/charge	7 counts of false accounting. Did not declare employment while claiming HB. Was employed by a neighbouring council. NFI data match referral received.
Outcome/judgement	Awaiting court date.
Comment	Comprehensive investigation.
Value of O/P	£9,352
Allegation/charge	3 counts of false accounting. Claimed HB and did not declare employment in a neighbouring council.
Outcome/judgement	Failed to appear in court, warrant issued for arrest.
Comment	NFI inspired referral. Comprehensive investigation.
Value of O/P	£8,473
Allegation/charge	Claimed HB, and did not declare employment in a neighbouring council.
Outcome/judgement	Pleaded guilty. 12 months’ probation, plus 120 hours Community Service. Awarded £100 costs.
Comment	Comprehensive investigation.
Value of O/P	£16,375
Allegation/charge	9 charges. 3 relating to obtaining mortgages by deception, 3 counts of fraudulently obtaining HB and 3 related to fraudulent claims for HB.
Outcome/judgement	Pleaded guilty, 15 months’ imprisonment.
Comment	Claimant set up 3 fictitious benefit claims, with HB paid directly to him as a landlord. Comprehensive investigation.
Value of O/P	£227,341
Allegation/charge	Multiple HB claims made by a team of 4 individuals, in various names, and at various Councils. Joint exercise with BASIS.
Outcome/judgement	Custodial sentences ranging from 2 years 3 months to 4 years 9 months.
Comment	Comprehensive investigation.

2.279 Although it needs to increase the number of imposed sanctions. this evidence shows that LB Haringey is committed to countering benefit fraud and to using sanctions. The prosecution sample highlights the contrast in investigation quality with the earlier non-prosecution sample.

2.280 LB Haringey also uses administrative penalties as sanctions as an alternative to prosecution as the following examples show.

Fig. 2.33: Number of administrative penalties

Offence	O/P value	Penalty value	BFI comments
Contrived tenancy	£1,274	£382	Repay overpayment over 12 months - signed official agreement on 7/2/00.
Working and claiming	£3,178	£953	£10 per month to repay overpayment – signed official agreement on 5/4/00. This agreement breaches prosecution policy guidelines. Claimant was previously prosecuted for a CTB fraud offence in a neighbouring council. Claimant should have been prosecuted.
LTAHAW	£1,700	£355	Official agreement signed on 21/7/98.
Income/capital	£3,450	£990	Official agreement signed on 7/02/00. Claimant to repay at £30 per week.

2.281 We commend LB Haringey for its commitment to increasing the use of prosecution as a sanction.

2.282 LB Haringey expects to see increases in IUCs and prosecutions in 2000/01 as a result of its move towards a sanctions-based counter fraud operation. This is particularly true now that the Regulation of Investigations Practices Act 2000 is in force.

2.283 At the end of November 2000 BIS was working towards 11 prosecutions with 4 additional cases currently with the legal department.

2.284 There is no standards of service agreement between BIS and the contracted-out legal service. BIS management told us that performance on prosecution work had always been satisfactory in the past.

We recommend that BIS and legal services agree a detailed SLA. This should allow for the planned increase in prosecution work, allowing the legal service to ensure that sufficient resources are available. Monitoring performance against agreed targets will give greater assurance on achieving the planned prosecution increases and will be useful for monitoring the legal service’s contract.

Working with BFIS and data matching

2.285 Sharing information among agencies and passing on experience and information to other investigators quickly is recognised as an important element in effective counter fraud activity. We looked at the working relationship between BIS and BFIS.

2.286 LB Haringey interfaces with both Leaside and Euston BFIS teams. There are SLAs in place with both teams.

2.287 Meetings between LB Haringey and BFIS are arranged as necessary, the last one being in April 2000.

2.288 Although BIS was reasonably content with the relationship with BFIS, it highlighted problems in responding to some requests for claimant information. In some cases this information was not provided, ostensibly due to data protection procedures. This was despite HB being in payment.

2.289 We found the following good practices that contribute to effective operational links:

• there have been joint investigations
• DCI information is provided on request
• BFIS provides DCI checks for BIS staff.

2.290 However, the teams have not agreed formal performance monitoring of the SLA, nor did they participate in the BA-funded closer working project. Future BA funded initiatives should be considered positively.

Data matching

2.291 LB Haringey takes part in annual NFI and quarterly HBMS data matching, while internal data matching includes staff payroll and student grants. The following Figures show results achieved in both NFI and HBMS investigations.

Fig. 2.34: NFI results

Year	Matches	Investigated	WBS value	WBS claims	O/p value	Sanctions
1997	2,336	1,466	£46,903	21	£52,550	0
1998	2,532	1,525	£21,008	10	£20,121	5

Source: LB Haringey

Fig. 2.35: HBMS data 1999/00

	RA	RR	CTB	Total
WBS claimed	£13,126	£10,097	£4,451	£27,674
Overpayments identified	£12,059	£5,390	£6,263	£23,712

Source: LB Haringey

2.292 Figure 2.36 shows the cumulative position of HBMS referrals to LB Haringey and statistical return details:

Fig. 2.36: Cumulative HBMS statistics to 26/11/00

Referrals issued	654
Referrals returned	538
Referrals outstanding	116
Positive results	43
Negative results	46
Cases overloaded	448
WBS achieved	£37,208
Overpayments identified	£39,800

Source: DWP statistics.

2.293 Our findings show:

• an extremely poor success rate against NFI investigations carried out
• a very high level of HBMS cases overloaded
• poor WBS and overpayment returns in both NFI and HBMS investigations
• excellent success rate of HBMS cases investigated.

2.294 We were impressed with the range of data matching carried out by BIS, and some of the results achieved, although there appears to be a problem in responding to the number of matches being found. Figure 2.37 highlights good examples of data matching projects.

Fig. 2.37: Data matching projects

Name of project	Details of project	BFI comment
Operations Edith 1, 2 and 3	In-house data matching to identify low wage fraud that could lead to multiple false claims.	Excellent initiative where benefit claim characteristics have been identified and used to counter multiple identity fraud. Extensive use has been made of the Post Office redirections data requests. This successful initiative is ongoing.
Project Anabas	Joint investigation with BFIS into employee fraud. Areas of data matching include Incapacity Benefit, Statutory Maternity Pay and new members of staff in LB Haringey.	Excellent initiative that resulted in 7 LB Haringey staff and a neighbouring council staff member identified claiming benefits fraudulently.
AVA estates project	This property company was investigated as a result of its sister company ceasing trading with debts owed to LB Haringey. The company’s property portfolio was then transferred to AVA Estates to avoid any benefit overpayment clawback. The First software system was interrogated to match claimants with the landlord.	21 benefit claimants, residing in AVA properties were visited. 10 were not resident resulting in WBS of £28,737.
Students project	A joint project with BFIS, data matching full time students and benefit recipients.	A successful exercise that produced a joint WBS total of £138,537, with £36,027 claimed by LB Haringey. Additionally, BFIS identified £78,081 in overpayments..

Source LB Haringey

2.295 Other examples of data matching projects carried out by LB Haringey include:

• duplicate dependants
• low wages declared to obtain HB
• single parents with low incomes
• male single parents
• Council Tax empty properties with live HB claims
• landlords.

2.296 A special projects manager controls these initiatives. He is responsible for drawing up and circulating written protocols, writing a final report showing the results achieved, and recommending future similar exercises.

2.297 We commend LB Haringey for the very positive approach it takes on proactive internal data matching.

We recommend that LB Haringey urgently reviews the processes for sifting, overloading and investigating NFI and HBMS referrals, and makes use of the national BA data search facility to increase data matching potential across a range of benefits.

Internal fraud team

2.298 LB Haringey has set up a small team in BIS responsible for investigating HB and CTB fraud by LB Haringey staff and the staff of other LAs. This team is known as the Fraud Investigation Section (FIS). FIS has a designated team of 2 full time staff and it maintains a separate filing system and database.

2.299 FIS has a formal written protocol with IA to ensure clear demarcation of investigations.

2.300 The main purpose of this team is to investigate allegations of internal:

• HB fraud
• CTB fraud
• IS and JSA fraud
• DWP benefit frauds.

2.301 Allegations may involve:

• current employees of LB Haringey
• new employees in LB Haringey
• employees of other LAs receiving HB or CTB from LB Haringey

2.302 Appendix E highlights some examples of comprehensive investigations carried out by FIS. FIS has achieved impressive results.

Fig. 2.38: FIS outcomes

Year	Number of cases	Staff dismissed or resigned	Prosecutions	Admin penalties pending	Cautions pending
1998/99	96	24 (2)	3 (passed to BA )	0	0
1999/00	90	22(3)	2	0	0
4/2000 to 30/9/00	55	7(5)	3	4	1

Source: LB Haringey

2.303 We commend FIS for its positive approach in identifying internal benefit fraud and the authority for its willingness to use sanctions against employees claiming benefit fraudulently. Making sure things work contains some further comment on this approach to internal fraud.

Overpayments

2.304 LAs lose subsidy if they do not take preventative action to minimise overpayments. When overpayments are created, there needs to be effective recovery action. Effective recovery also helps to deter potential fraudsters.

2.305 LB Haringey’s performance on identifying and recovering overpayments is poor. There are delays in the process, especially at the recovery stage. The level of outstanding overpayments is rising.

2.306 Implementing new software for offsetting and debtors, which would help the recovery processes, has been delayed. Management hopes that the offset module will be introduced very shortly. This will make it easier to make deductions from landlords’ payments. The First debtor system should be available from April 2001.

2.307 The amount of overpaid HB has decreased slightly, as shown in Figure 2.39, but CTB excess benefit has increased in the last year.

Fig. 2.39: Amount of overpaid benefit identified

Year	HB	CTB
1997/98	5,825,022	4,071,939
1998/99	5,300,643	3,712,055
1999/00	5,252,863	4,294,382

Source: LB Haringey

Total overpayment debt

2.308 Figure 2.40 gives LB Haringey’s recovery levels for overpayments and excess benefit. The Council Tax section, mainly through changes in liability, has responsibility CTB excess benefit. This is shown as recovered, as the debt is held on the Council Tax system. We do not know precisely how much has been recovered, but note that Council Tax collection has a high priority in LB Haringey.

Fig. 2.40: Recovery achieved

	1997/98	1998/99	1999/2000
CF from previous year	10,847,415	10,413,715	11,665,502
Classified in year	10,655,020	9,749,030	9,547,245
Started to recover in year	8,769,100	7,610,232	8,075,284
Written off at year end	2,704,684	95,539	834,331
Awaiting recovery to be CF	10,413,715	11,665,502	12,303,130

Source: LB Haringey

2.309 Figure 2.40 shows that the total outstanding debt, after falling in 1997/98, has started to rise again. In addition to these totals the First Benefit system holds £3 million of outstanding debt where no further action has been taken. We were told that this was either because further credits were due or the overpayments were created with an invalid reason. Figure 2.41 breaks down this debt.

Fig. 2.41: Outstanding debt on First Benefit system – no action taken

Financial year	Number of cases	£
1996/97	954	465,655
1997/98	1,400	613,453
1998/99	1,483	595,225
1999/2000	1,587	807,159
1/4/00 to 30/9/00	971	552,140
Total	6,395	3,033,622

Source: LB Haringey

2.310 The total debt outstanding is over £15 million. LB Haringey plans to recruit agency staff to tackle the outstanding overpayments on First benefit system and start recovery action.

2.311 LB Haringey was unable to provide figures for the Best Value performance indicators for overpayments. This is because the software update needed is not available. LB Haringey hopes it will be able to collect this information soon.

2.312 We looked at LB Haringey's overpayment procedures for:

• preventing overpayments
• identifying, classifying, notifying and recovering overpayments
• writing off debt.

Preventing overpayments

2.313 In its tender submission bid in 1998 the Benefits Unit stated that it would take steps to avoid overpaying benefit and losing subsidy by:

• ensuring claims are substantiated by appropriate evidence before payment
• checking claim forms on receipt for relevant changes
• giving urgent assessment priority to end-of-entitlement notices
• scrutinising incoming post for changes in circumstances
• ensuring post is scanned and indexed in good time
• setting short benefit periods if circumstances are due to change
• promoting customer awareness.

2.314 Getting it right and Keeping it right assessed LB Haringey’s performance in many of these areas and contain our recommendations for improvements, particularly in the areas of verification and award periods.

2.315 We took a sample of 70 overpayment cases from a bespoke system report. Some of these were either not true overpayments or were not created in the last financial year. We looked in detail, therefore, at 58 cases.

2.316 There were 8 (14%) cases in which the overpayment could have been prevented, at least in part. Figure 2.42 shows a breakdown of these.

Fig. 2.42: Breakdown of avoidable overpayments

	Number of cases
Incorrect payment cycle	1
Poor liaison with Housing department	2
Non dependant become 18	1
Inappropriate benefit period	3
Case assessed without evidence	1
Total	8

Source: BFI analysis

We recommend that LB Haringey minimises overpayments by:

• improving liaison with housing management
• tailoring benefit periods to known changes in circumstances, such as income increases
• ensuring that significant birthdays are acted upon
• assessing only cases with all the appropriate evidence.

Identifying overpayments

2.317 Changes of circumstances should be dealt with promptly to avoid overpayments. LB Haringey states that it gives priority to incoming post that may lead to an overpayment if delayed. Scanning and indexing staff are trained to identify these documents and mark them as urgent.

2.318 Teamleaders allocate work to ensure that changes that may reduce entitlement are dealt with first. The assessment officers then make the necessary adjustments when they receive the notification of change.

2.319 The target set in the Haringey Benefits Service Standards is that overpayments will be identified within 3 working days, or before the next payment run. The HB Business Plan for 2000/2003 gives the target for LA error overpayments as nil. Some assessment staff we spoke to were unaware of these targets.

2.320 We looked at the reasons for overpayments in our sample. Figure 2.43 shows our findings.

Fig. 2.43: Reasons for the overpayments in the sample

Reasons	Number of cases	%
Change in landlord	2	4%
Claimant died	2	4%
Change of address	13	22%
To correct wrongly input income	1	1%
Fraud	1	1%
Increase in income	4	6%
IS/JSA(IB) ended	18	31%
JSA suspended	3	5%
Not known	2	4%
No reply to letters	2	4%
Non dependant circumstances	3	5%
Rent incorrect	2	4%
Initial failure to refer to RO	3	5%
Started work	2	4%
Total	58	100%

Source: BFI analysis

2.321 LB Haringey could not give the reasons for the overpayment in 2 cases. The reasons for overpayments should be clearly noted for future reference and to ensure that the person affected is given the correct reason in accordance with paragraph 14, Schedule 6 of the HB Regulations.

2.322 Our sample showed that the average time from the notification of the change to the assessment of the overpayment was 16 days. There were 18 cases out of these that were due to IS/JSA(IB) ending, and the average time to stop the HB claim in these cases was 4 days.

2.323 The case that had the longest delay before assessing the overpayment involved a pension increase. The claimant told the LA in June that her pensions had increased in April, but her claim was not amended until November, the case being paid incorrectly until October.

2.324 LB Haringey plans to introduce a Closure Team, which will also deal with recovery. All changes of circumstances will go to this section immediately to action. It will also ensure that the correct reason for the overpayment and the correct subsidy code were entered on the First Benefit system.

We recommend that LB Haringey ensures that all changes in circumstances are dealt with promptly to avoid LA error overpayments.

Classifying overpayments

2.325 Accurate classification of overpayments is essential so that the LA claims the correct subsidy due, but it also important for a number of other reasons, as it:

• determines if the overpayment is recoverable
• influences the rate of recovery
• affects claims for WBS
• provides an indication of levels of fraud and error.

Fig. 2.44: HB overpayment classification 1999/00

Source: LB Haringey

2.326 Figure 2.44 shows the breakdown of HB overpayments by subsidy codes for the financial year 1999 /2000.

2.327 Overpayments are raised on the First Benefits system, which will automatically classify the overpayment depending on the data input. Assessment staff can check and amend the classification if needed. Fraud classifications should be entered manually. Procedure notes are available to assessment staff explaining the different subsidy codes.

2.328 We found in our sample of 58 cases that 21% had been classified incorrectly, at least in part. Our findings are shown in Figure 2.45.

Fig. 2.45: Incorrect classification found in sample

Number of cases	Incorrect classification	Correct classification	Decrease or increase of subsidy
10	Claimant error	LA error	Decrease
2	Claimant error	Other	No change
2	Other	Claimant error	No change
9	Fraud	Claimant error	Decrease
1	LA error	Claimant error	Increase

Source: BFI analysis

Classification of fraud overpayments

2.329 Classifying an overpayment as fraud means that the LA receives 80% subsidy for that overpayment, as well as keeping any of the overpayment recovered. Article 18(5) of the Subsidy Order needs to be met to receive this higher subsidy.

• 2.330 Guidance notes issued by LB Haringey in June 1999, explain how overpayments can be coded as fraud overpayments in certain cases. This guidance wrongly states that if the claimant does not tell LB Haringey of a change in circumstances until more than 4 weeks after the change then any overpayment may be classed as fraud. The guide notes exceptions when a case should not be classed as fraud. Only the first of these has any legal validity. The exceptions are:
• statutory
• local policy
• other exceptions
• exceptional factors.

2.331 To comply with the Subsidy Order, assessment staff should consider whether, on the balance of probabilities, the claimant knowingly made a false statement or knowingly failed to report a change in circumstances with the intention to obtain benefit.

2.332 Assessment staff complete a fraudulent overpayment checklist to explain why the case has been coded as fraud. A designated officer, either a senior caseworker or a team manager, authorises the classification.

2.333 Circular A58/98 gives LAs further guidance. It says:

You would not be satisfying the requirements of the Subsidy Order if, for example, you operated a blanket policy of assuming there was fraud in cases where there was a failure to report a change in circumstances and cheques continued to be cashed, as this evidence alone would not show deliberate intent by the individual.

2.334 There were 12 overpayment cases classified as fraud in our sample. Nine of these were classified by assessment staff without passing the cases to the investigation section. There was no evidence on these cases to prove that the person deliberately failed to notify the LA of the change to obtain benefit.

Case study: In one case, BA informed LB Haringey on 17 October 1999 that JSA had ended on 20 September. An overpayment was created on 21 October for the period 20 September to 17 October. This overpayment was classified as fraud as the claimant failed to notify the LA. There was no evidence that the claimant had knowingly failed to report this change of circumstances with the intent to obtain benefit dishonestly.

We recommend that LB Haringey reviews its policy for classifying overpayments as fraud and ensures that when a case is classified as fraud there is sufficient evidence recorded to support this decision.

Notifying people concerned

2.335 Schedule 6, paragraph 14 to the HB Regulations requires LAs to notify those affected of the overpayment. The notification must include:

• the fact that there is a recoverable overpayment
• reasons for the overpayment
• the amount of the overpayment and how the overpayment was calculated
• the benefit weeks that the overpayment relates to
• if recovering by deductions from ongoing HB entitlement, the amount of the deduction
• an explanation of the right of appeal against the determination.

2.336 LB Haringey’s determination notices are deficient because the reason for the overpayment is not always clear, as it depends on the input of the assessor. They also do not state:

• that the overpayment is recoverable
• the reason for the overpayment on landlord notification letters.

2.337 When benefit assessors create an overpayment, the benefit system usually sends notification letters automatically. LB Haringey manually stops notification letters if it is inappropriate, such as when the claimant has died. The correct practice in these circumstances to write to the person’s estate as there may be funds available to repay the debt.

2.338 If an invoice is issued to a claimant or landlord, LB Haringey sends a further manual notification letter to meet the requirements under Schedule 6. It is usually sent 8 weeks after assessing the overpayment and gives a further 6 weeks time limit for appeals.

2.339 LB Haringey is discussing how to meet the requirements of Schedule 6 with its software provider. It plans that the cancellation team will send a manual notification as soon as the overpayment is created.

We recommend that LB Haringey ensures that all affected people receive notifications in accordance with the requirements of Schedule 6. These should be issued immediately after the overpayment has been created and include the right of review.

Recovering overpayment debt

2.340 Before attempting recovery, an LA must decide:

• if the overpayment is recoverable, and if so
• if the overpayment should be recovered, and if so
• who the overpayment should be recovered from.

2.341 We found no audit trail to show how 3 decisions had been taken. Benefit assessors and the recovery section told us that they recover overpayments from the person that the payments were made to, without considering whether this is appropriate or not. In fraud cases, for example, it may be appropriate to recover from the person who committed the fraud rather than the person actually paid HB. This will act as a deterrent to potential fraudsters.

We recommend that LB Haringey keeps records of the decisions made on overpayment recovery so that recovery action is only taken when appropriate and recovery is made from the most appropriate person.

2.342 Benefit assessors, in the first instance, wait for a further claim from the claimant and recover from ongoing entitlement.

2.343 The benefit assessors decide the amount to recover from ongoing benefit using the DWP guidelines. If the benefit assessors fail to put in a figure, the First benefit system will default to clawing back the full HB entitlement. We found that this had happened in 3 cases in our sample.

2.344 In rebate cases, if the rent account is in credit, LB Haringey writes to the claimant asking for the credit to be used to reduce the overpayment.

2.345 LB Haringey has a separate recovery section. If there is no fresh claim after 8 weeks, the recovery section receives a computer generated report. It manually sets up a record on the Income Recovery Accounting System (IRAS), a separate debtors’ package.

2.346 The recovery section considers the following recovery methods:

• invoicing and agreeing to recover by instalments
• using sections 75(5)(6) of the Social Security Administration Act 1992 to recover from landlord payments
• recovering from other social security benefits
• involving the Legal department to pursue the debt, including charging orders. We were pleased to see charging orders used to pursue debt, after judgement.

2.347 Our sample had an original total overpayment value of £54,989. At the time that we took the sample this had reduced to £31,124. Figure 2.46 shows how.

Fig. 2.46: Reduction of debt in our sample

	Amount	%
Ongoing entitlement	15,072.66	63%
Invoice	4,165.43	17%
Offsetting	2,296.60	9%
Instalment	1,032.50	4%
Written off	258.44	2%
Uncashed cheques	640.00	3%
Landlords payments	400.00	2%
Total	23,865.63	100%

Source: BFI analysis

2.348 This represents a reduction of 43% of the original debt, including offsetting, uncashed cheques and debts written off. Recovery was fully completed in 24 of the 58 cases (41%), and on average it took 133 days to complete this recovery. We are disappointed that LB Haringey is achieving such a low level of recovery of its overpayments.

2.349 We found 3 cases where no action had been taken at all, and one case had been outstanding for 493 days. There were 15 cases where invoices and reminders had been issued but then no further action. There is no priority to recovering fraud overpayments. The recovery section does not look at classifications and is, therefore, unable to target fraud overpayments to deter potential fraudsters.

Invoices

2.350 When recovery officers set up manual invoices on IRAS, they check whether:

• RO referrals have been made
• there is credit on the rent account that could be used
• there are uncashed cheques that would reduce the overpayment.

2.351 The debt is then manually written off the First benefit system and on to IRAS. There is no reconciliation to ensure that the correct level of debt is transferred to the debtors’ system.

We recommend that there are regular reconciliations to ensure that debts are correctly written off and on to the appropriate systems.

2.352 IRAS generates invoices and reminders as appropriate. The system also runs a series of reports detailing cases that require further action. At present LB Haringey does not use these reports to prompt further recovery.

2.353 If the claimant subsequently makes a fresh claim, the benefit assessor has to notify the overpayment team who manually put the overpayment back on the First benefit system. Assessment staff should not input a new claim until this has been done. In our sample of cases, we found one case where the claimant was receiving HB again, but IRAS still held the overpayment and the invoice had not been cancelled.

2.354 LB Haringey provided details of invoices set up on IRAS where no further action had been taken after the reminder stage. The details are shown below.

Fig. 2.47: Invoices outstanding

Year	No	Value (£)
1990 to 1995	1,726	1,074,029.98
1995/96	751	280,023.95
1996/97	1,995	1,251,038.17
1997/98	1,775	1,126,579.00
1998/99	1,175	876,920.20
1999/00	1,318	1,005,534.65
Total	8,740	5,614,122.95

Source: LB Haringey

2.355 LB Haringey is planning a pilot to use debt collection agencies to reduce some of the outstanding debt. The debt that will be transferred to the debt collectors will initially be £4.3 million and a timescale has been put on the pilot for 3 months. If successful, LB Haringey will consider transferring more of their debt to debt collectors.

Recovery from landlords’ payments

2.356 LB Haringey will recover from other claimants’ HB for landlords under section 75(5) of the SSAA, but this has to be done manually at present, as the software has not been implemented. Therefore, this option is time consuming and not as effective as it could be.

2.357 LB Haringey does not use this recovery method for HAs. Figure 2.48 shows that there are 5 HAs among the 10 landlords in the borough with the highest outstanding overpayment deb.

Fig. 2.48: Top 10 landlords

Name	Value
XXXX XXXX XXXX XXXX XX	189,170.10
XXXX XXXX XXXX XXXX X	175,084.85
XXXX XXXX XXXX X	149,208.92
XXXX XXXX XXXX X	142,666.27
XXXX XXXX XXXX	102,980.56
XXXX XXXX XXXX X	97,017.02
XXXX XXXX XXXX XX	90,720.00
XXXX XXXX XXXX XXXX XXXX XXXX X	85,963.69
XXXX XXXX XXXX XXXX X	84,711.36
XXXX XXXX XXXX XXXX XXXX	79,057.11
Total	1,196,579.88

Source: LB Haringey

We recommend that LB Haringey uses Sections 75(5)(6) Social Security Administration Act to recover overpayments from other tenants’ payments.

2.358 LB Haringey tries to arrange for the debt to be repaid by instalments with landlords before recovering from other tenants' benefit.

Case study: The managing agent with the largest debt owing in the borough, XXXX XXXX XXXX XXXX XXXX , initially agreed to repay the debt by instalments but defaulted.

The recovery section started using HB payments from other tenants’ HB to reduce the debt but the company went into liquidation. A former employee, the daughter of the managing director, set up a new managing agency that took over all of the properties XXXX XXXX XXXX XXXX XXXX X
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX

Instalments

2.359 Recovery officers deal with telephone calls and repayment offers. In general, the recovery section tries to get immediate full recovery for HA overpayments. With other overpayments, it attempts to recover within 6 months if recovering from landlords, or within 12 months from tenants. If a claimant or landlord states that they cannot repay in this period they are asked for a financial statement.

2.360 The debtors’ system generates a report listing all instalment agreement cases that have defaulted. This report is actioned irregularly by the recovery section when reminders are sent. No further action is taken at present if there is no response to the reminder.

Other recovery methods

2.361 LB Haringey uses its legal section to pursue debts. As well as using other methods, it seeks recovery under section 75(7) of the Social Security Administration Act 1992. This accelerated procedure registers the debt at the county court. The recovery section told us it did not find the legal section very effective as officers changed regularly. At the time of our inspection, the recovery section had been told not to refer any new cases to legal. Legal section gave no reason for this. The recovery section is not referring cases regularly anyway, as the last bulk referrals were sent to the legal section over a year ago.

2.362 With the help of its legal section, LB Haringey has used charging orders on properties as an effective recovery method.

In a particular case an overpayment was created of £29,325 due to a fraudulent claim for benefit. The claimant was the owner of the property but made a claim as a tenant to receive HB. The claimant was told that a charging order was to be held against the property to recover the debt. To avoid this, the claimant repaid the overpayment in full by taking out a loan and cashing in insurance policies.

2.363 This is good practice, using this method of recovery where there is a property owed by a claimant or a landlord. However, it can take time before recovery is actually received.

2.364 The recovery section uses deductions from other social security benefits, if possible and it uses DWP to trace debtors, It also checks housing and council tax records. LB Haringey does not recover from other LAs.

Management checks

2.365 There were no management checks on any of the cases in our sample. There is no formal monitoring of the recovery section’s work.

2.366 The recovery section has only one target, which is to create 10 invoices a day. The overpayment section does not produce regular reports to show its performance.

We recommend that LB Haringey improves its recovery of outstanding debts by:

• setting targets for the recovery section
• monitoring the section to ensure that the required level of recovery is achieved
• keeping management information on the effectiveness of different forms of recovery
• targeting resources to those areas found to be most effective.
• training its recovery section to use section 75(7) of the Social Security Administration Act 1992, rather than using its legal section
• recovering through other LAs.

Write off

2.367 LB Haringey’s policy is to recover all overpayments and there is no automatic write-off. There are procedures for debts under £1,000 to be written-off by the Director of Finance and for debts over £1,000 to be written-off by the Director of Finance and the Chair of the Housing Committee. All cases are judged on their individual merits.

2.368 We took a sample of 10 cases recommended for write off. Figure 2.49 gives the reasons why.

Fig. 2.49: Reasons for write off

Reasons	Number
Statute barred	3
No trace	3
Landlords in official receivership	1
Uneconomical to pursue	1
Debtor deceased	1
Unable to establish liability	1
Total	10

Source: BFI analysis

2.369 Two cases in the sample were written off before all appropriate action had been taken. One case should have had a claim made against the estate as the claimant had died. In the other case, £155.14 was written off because there was no trace of the debtor. But he was still a tenant of a council property, and no checks were done with housing management. A new claim was submitted by this claimant and paid before the write-off was recommended.

2.370 Debts were written off IRAS before the appropriate authorisation was given. There was no monitoring to ensure that authorisation was received from the appropriate officer.

We recommend that LB Haringey ensures that all appropriate action is taken and the correct authorisation is received before an overpayment is written off.

Use the box below to list recommendations.

Putting it right – recommendations

We recommend that:
the level of clerical support is reviewed with a view to releasing more investigative time. (Paragraph 2.232)
LB Haringey reviews the viability of the team as it currently operates. XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X (Paragraph 2.237)
LB Haringey ensures that management checks are carried out and results recorded on the fraud files and the fraud case management system. (Paragraph 2.245)
LB Haringey: develops a training needs analysis and staff development programme covering issues such as the use of IUCs, evidence requirements for prosecution cases, and WBS claim rules reviews the important process of BF7 notification from the benefits section to BIS to ensure 100% compliance. (Paragraph 2.255)
LB Haringey identifies fraud cases where observations are required to establish fraud, and make resources available to carry out observations to an acceptable standard. (Paragraph 2.257)
LB Haringey urgently: ensures that some operational staff are appointed as inspectors identifies suitable cases and uses the powers effectively. (Paragraph 2.263)
LB Haringey reminds the appropriate staff of the criteria for claiming WBS. (Paragraph 2.274)
BIS and legal services agree a detailed SLA. This should allow for the planned increase in prosecution work, allowing the legal service to ensure that sufficient resources are available. Monitoring performance against agreed targets will give greater assurance on achieving the planned prosecution increases and will be useful for monitoring the legal service’s contract. (Paragraph 2.284)
LB Haringey urgently reviews the processes for sifting, overloading and investigating NFI and HBMS referrals, and makes use of the national BA data search facility to increase data matching potential across a range of benefits. (Paragraph 2.297)
LB Haringey minimises overpayments by: improving liaison with housing management tailoring benefit periods to known changes in circumstances, such as income increases ensuring that significant birthdays are acted upon assessing only cases with all the appropriate evidence. (Paragraph 2.316)
LB Haringey ensures that all changes in circumstances are dealt with promptly to avoid LA error overpayments. (Paragraph 2.324)
LB Haringey reviews its policy for classifying overpayments as fraud and ensures that when a case is classified as fraud there is sufficient evidence recorded to support this decision. (Paragraph 2.334)
LB Haringey ensures that all affected people receive notifications in accordance with the requirements of Schedule 6. These should be issued immediately after the overpayment has been created and include the right of review. (Paragraph 2.339)
LB Haringey keeps records of the decisions made on overpayment recovery so that recovery action is only taken when appropriate and recovery is made from the most appropriate person. (Paragraph 2.341)
there are regular reconciliations to ensure that debts are correctly written off and on to the appropriate systems. (Paragraph 2.351)
LB Haringey uses Sections 75(5)(6) Social Security Administration Act to recover overpayments from other tenants’ payments. (Paragraph 2.357)
LB Haringey improves its recovery of outstanding debts by: setting targets for the recovery section monitoring the section to ensure that the required level of recovery is achieved keeping management information on the effectiveness of different forms of recovery targeting resources to those areas found to be most effective. training its recovery section to use section 75(7) of the Social Security Administration Act 1992, rather than using its legal section recovering through other LAs. (Paragraph 2.366)
ensures that all appropriate action is taken and the correct authorisation is received before an overpayment is written off. (Paragraph 2.370)

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