Recommendations
| We recommend that London Borough of Hackney: |
Paragraph |
- develops a strategic vision
for the Benefits service, approved by Members, covering the 7
functional areas of Standards and that the service is:
- speedy and accurate
- secure, reducing the risk of error
- deters fraud by recovering overpayments
- minimises barriers to work.
|
2.10 |
- links its policy objectives
for the Benefits service to the strategic vision we recommend it
develops for the service
|
2.19 |
- ensures the objectives bridge
the gap between the strategic vision and the current position
|
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- sets specific targets,
including key milestones, to meet all Standards over time
|
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- develops objectives in
relation to the links between efficient benefits administration
and social inclusion and anti-poverty in its next Finance
Directorate service plan.
|
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- ensures work plans include
key milestone dates for each objective
|
2.29 |
- recognises and communicates,
to all its stakeholders, the impact of operational plans on its
stakeholders
|
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- produces a documented
business continuity plan for its Revenues and Benefits and Audit
and Anti-Fraud Divisions and that this plan is:
- tested
- reviewed annually
- communicated to staff.
|
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- sets targets for all Best
Value Performance Indicators not only for 2003/04 but also up to
3 years ahead
|
2.38 |
- develops targets that are specific,
measurable, achievable, realistic and time-based, in service
and work plans for counter-fraud activity
|
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- communicates to customers,
its local performance indicators on standards of service.
|
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- ensures that audited subsidy
returns and management information are submitted to the
Department on time
|
2.48 |
- develops the Hackney interim
document system reporting capability as a priority.
|
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- recruits sufficient staff to
provide the level of service required to achieve all Standards
without heavy reliance on temporary staff.
|
2.63 |
- completes the process of documenting its procedural guidance notes by:
- updating the database
- making them available to all staff
- ensuring they are maintained effectively.
|
2.70 |
- develops clear criteria for
management checks in the processing of claims and overpayments
recovery that identify:
- the types, numbers and proportions of cases it checks
- the selection of samples
|
2.76 |
- introduces a central summary
of the results of checks to aid the identification of training
needs and procedural weaknesses. This summary should be reported
to senior officers and Members at regular intervals
|
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- ensures the results of the
checks are used to inform individual staff training and
development plans.
|
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- develops its management information so that is can use it to:
- predict trends
- identify patterns and risks
- establish areas of low take-up
- identify and remedy procedural weaknesses
|
2.80 |
- urgently implements the use
of existing system reports that enable analysis of performance
in key areas of benefits administration
|
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- fully assesses its management
information needs in relation to the Benefits service, prior to
implementing the new Benefits IT system.
|
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- introduces a training
evaluation system and ensures that the results of this influence
future training plans
|
2.100 |
- ensures that interim feedback to staff on their performance is undertaken across all teams.
|
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- the new Benefits and finance IT systems:
- provide sufficient data for the accurate and timely completion of
subsidy and the Department’s management information returns
- provide comprehensive management information
- allow payment via the Bankers Automated Clearing Services
- allow full reconciliation of payments
|
2.112 |
- ensures that the new Benefits
IT system includes automatic interfaces to all other relevant IT
systems within the authority
|
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- fully documented testing
procedures are used to test all software releases and systems
updates, including those for all interfacing systems
|
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- an IT disaster recovery plan
is produced for the its fraud data-tracking database
|
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- its IT disaster recovery
plans are tested at least annually and the outcome is used to
refine the existing plan.
|
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- includes assessing
performance against Standards in its Internal Audit work
programme
|
2.123 |
- deploys the level of Internal
Audit resource based on risk including due consideration of the
amount of money paid in respect of HB and CTB, compared to the
council’s gross revenue expenditure.
|
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- puts procedures in place to
ensure the monitoring of progress against External Audit
recommendations and that these procedures are reviewed at least
annually to ensure that they are effective.
|
2.128 |
- calculates the cost per claim
at quarterly intervals.
|
2.133 |
- formalises its relationships
with other council teams involved in benefit administration.
This should involve defining the responsibilities, communication
channels and cover the frequency of reviews of the effectiveness
of the agreement.
|
2.140 |
- establishes service level
agreements with:
- Rent Service
- Jobcentre Plus
- The Pension
Service
- Registered
Social Landlords
|
2.147 |
- monitors these agreements at
least quarterly to assess performance, and holds regular
meetings to discuss performance.
|
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Recommendations
| We recommend that London Borough of Hackney: |
Paragraph |
- revises its claim form in
line with the latest BFI model form.
|
3.9 |
- adopts and achieves a
telephone answering target of 80% of all calls to be answered
within 15 seconds.
|
3.25 |
- adopts and achieves a target
for seeing 80% of customers within 15 minutes of calling into
enquiry offices without an appointment
|
3.44 |
- advertises in the public
areas of its offices the availability of private interview
facilities
|
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- extends the checks on
leaflets to include ensuring that they are up-to-date
|
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- provides Neighbourhood
Housing Office staff with training on the use of the Benefits IT
system and gives them access to allow them to provide full and
accurate advice to customers
|
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|
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- introduces, as a discrete
item, targets taking into account Standards, for response times
to general correspondence and monitors performance.
|
3.45 |
- reviews and improves the
effectiveness of training of Neighbourhood Housing Office staff
and ensures that they are kept up-to-date on changes in
regulations, local policies and procedures.
|
3.53 |
- amends its decision letters
to include the need for claimants and landlords to advise any
changes of circumstances to the council
|
3.59 |
- amends its decision letters
to landlords and claimants, when the landlord is receiving
direct payments, to include the kind of changes of circumstances
to be notified.
|
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- identifies the needs of its
ethnic minority groups and acts upon the findings of the review
|
3.71 |
- provides large print leaflets
and forms, information on computer disc and British sign
language interpreters
|
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- undertakes a survey to
determine the suitability and accessibility of Keltan House and
the 6 Neighbourhood Housing Offices for people with disabilities
|
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- uses the Language Line
translation service as back up for its own staff.
|
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- undertakes a review to
establish the needs of claimants in work
|
3.75 |
- uses the information received
from Jobcentre Plus to fast-track claims of those who start
work.
|
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- liaises with Jobcentre Plus
and other external groups to encourage benefit take-up from
under-claiming groups
|
3.84 |
- offers advice to working age
claimants on their possible entitlement to benefit should they
start work.
|
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- ensures that analysis of
complaints is undertaken
|
3.96 |
- ensures that general queries
indexed to the assessors’ work queues are dealt with promptly
to avoid them escalating into complaints
|
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- uses only one type of
complaints form and guidance notes to avoid confusion
|
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- accepts complaints verbally
from customers with no requirement for them to confirm in
writing.
|
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- clears the backlog of appeals
and requests for reconsideration as a priority
|
3.104 |
- achieves its target of 28
days to deal with an appeal or a reconsideration and monitors
its performance
|
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- ensures that the guidance in
the Appeals Service’s Communication Bulletin 6 is
implemented.
|
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Recommendations
| We recommend that London Borough of Hackney: |
Paragraph |
- introduces and monitors
procedures to ensure it meets the
14-day and 36-day processing targets
|
4.26 |
- develops an exception report
that specifically monitors claims not reaching the 14-day and
36-day targets. For each new claim not reaching the specific
target, the report should show the time taken for each stage of
the process
|
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- includes provision of
document scanning facilities in its Neighbourhood Housing
Offices on introduction of its new document management system.
|
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- introduces and monitors
procedures that ensure that all appropriate payment on account
cases are quickly identified
|
4.35 |
- reviews its existing payment
on account monitoring process and develops improved management
reports to better inform its analysis and control of payments on
account.
|
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- introduces and monitors
procedures to ensure it meets the 9-day changes of circumstances
target in Performance Standards
|
4.51 |
- introduces measures to ensure
accurate input of performance data on changes of circumstances
and urgently re-assesses reports from its Benefits IT system to
ensure their validity.
|
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- introduces and monitors
procedures to ensure that it meets the Standard of renewing 83%
of claims before the expiry of the benefit period
|
4.75 |
- establishes and monitors
adherence to clear guidelines enabling benefit officers to
identify claims where assistance may be required by the claimant
when a renewal is due
|
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- updates procedure guides and
training notes to reflect the need to consider the extension of
current benefit periods in appropriate circumstances. Quality
and management checks should be introduced to monitor this
practice
|
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- produces a system report that
identifies cases where a renewal form is not returned. The
report should form the basis for follow-up action to identify
potential fraud and error.
|
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- ensures that management
checks are carried out to identify weaknesses in the
verification process
|
4.84 |
- ensures that claimants are
not asked to provide evidence more than once
|
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- establishes appropriate
quality checks to monitor the labelling of scanned documents to
ensure an audit trail of evidence collected.
|
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- introduces and monitors procedures that ensure cross-checks are carried out and recorded.
|
4.86 |
- ensures the identity of the
claimant and partner, where appropriate, is verified in all
cases.
|
4.93 |
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|
4.101 |
- sets collective and
individual targets for the HB Visiting team that have links to
performance required in its verification guidance.
|
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- ensures that entitlement to
IS and JSA(IB) is verified when processing renewal claims and
where possible this is undertaken through a Remote Access
Terminal check.
|
4.105 |
- ensures staff check for
capital when scrutinising claims forms and supporting evidence.
|
4.109 |
- ensures that non-dependants’ income is verified in all appropriate cases.
|
4.111 |
- ensures that management
checks are performed before a decision notice is sent
|
4.122 |
- provides guidelines on
selecting samples to ensure that its management checks are
consistent and representative of the range of assessments
performed by Benefit teams
|
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- includes in its management
checks the requirement to cover:
- the
application of the fit and proper person test for landlords
- the decision
on the benefit period has taken into account all known or
anticipated changes of circumstances.
|
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- introduces and monitors
procedures to ensure that benefit periods are tailored to take
account of claimants’ circumstances.
|
4.130 |
- ensures that the risk of
fraud and error attached to every claim is assessed
|
4.135 |
- ensures management checks
include the requirement to confirm that the risk attached to
each claim has been assessed
|
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- undertakes a detailed risk
analysis using local knowledge and including analysis of changes
of circumstances notifications and non-returned renewal claims
to reduce fraud and error.
|
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- signs and implements a service level agreement with the Rent Service
|
4.148 |
- introduces a mechanism for
monitoring performance against the targets in the service level
agreement. It must also take reasonable steps to obtain
performance information from the Rent Service at regular
intervals
|
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- introduces management checks
on appropriate claims to identify cases where a delay in
processing a Rent Officer referral may have occurred
|
4.148 |
- ensures that all appropriate
cases are identified promptly so that a referral to the Rent
Officer is processed in accordance with Regulations
|
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- takes urgent steps to improve
its exception reporting to identify in particular, cases paid on
account where:
- the claim is
paid for longer than the 6-week period London Borough of Hackney
recommends as maximum duration of a payment on account
- past benefit periods have not been decided due to an outstanding Rent Officer
determination.
|
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Recommendations
| We recommend that London Borough of Hackney: |
Paragraph |
- produces help sheets and
leaflets on the operation of HB for existing and prospective
landlords
|
5.13 |
- amends its claim form to
include:
- consent
wording clearly specifying what information may be given to the
landlord on the progress of the claim
- an opt-in
section, which allows the claimant to choose whether payment is
to be made direct to the landlord, and which requires an
additional signature, separate to that at the end of the claim
form
|
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- writes annually to all its
landlords giving up-to-date information on the responsibilities
of landlords and encouraging them to co-operate to prevent
overpayments
|
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- engages in regular
communication with its smaller landlords to encourage closer
working relations
|
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- formalises relationships with
the Registered Social Landlords and Neighbourhood Housing
Offices by introducing and monitoring the proposed service level
agreements
|
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- formalises the current custom
and practice of the Housing Directorate contacting the Landlord
Liaison team to check on the progress of outstanding claim prior
to enforcement action being taken. This should be included in
the service level agreement.
|
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- provides staff with written
procedures that detail the requirements for identifying fit and
proper landlords and introduces a control mechanism to ensure
the test is carried out as required by the Regulations.
|
5.18 |
Recommendations
| We recommend that London Borough of Hackney: |
Paragraph |
- revises its post opening
procedures to meet the good practices set out at Appendix D.
|
6.6 |
- assesses its guidance on
recruitment and declarations of interest to ensure that they
include procedures for:
- the vetting of
both directly employed and agency staff to be equal to, or
greater than those recommended by the Audit Commission
- obtaining
annual declarations of interest from all staff.
|
6.12 |
- formally reviews its
recruitment and vetting procedures annually
|
6.15 |
- ensures that Internal Audit
uses Standards to assess the performance of the Benefits
service.
|
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- produces and implements an IT
security strategy and information security policy. These
documents should be approved by Members and senior officers, and
include:
- clear
allocation of security responsibilities and reporting
arrangements
- education and
training in respect of IT security
- production of
comprehensive procedural guidance and supporting documentation
- the operation
of key controls and independent validation
|
6.20 |
- updates its system of
information security and access controls to comply with
acknowledged standards of best practice.
|
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- assesses the impact of its
document management system on the efficiency, effectiveness and
security of its benefits administration
|
6.27 |
- ensures that its document
management system meets the requirements of document management
best practice
|
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- routinely monitors scanning
and indexing timescales.
|
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- continues its programme of
work to minimise subsidy and reconciliation discrepancies, and
ensures that its replacement IT systems allow comprehensive
reconciliation of all payments made
|
6.41 |
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|
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- ensures Internal Audit
provides comprehensive assurance on the security of the system
of making and reconciling payments.
|
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Recommendations
| We recommend that London Borough of Hackney: |
Paragraph |
- communicates its anti-fraud and corruption strategy to all Benefit and housing staff and
provides awareness of the policy to all other staff
|
7.18 |
- amends its 2003/04 service plan to include targets for the value of Weekly Incorrect
Benefit and the number of sanctions in that year.
|
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- ensures the originator of the referral is notified of the outcome of any investigation that
may result from their referral
|
7.25 |
- extends the use of its standard referral form to all departments within the council
that have contact with the public.
|
|
- introduces a programme of fraud awareness training for staff across the authority and that
this programme includes:
- induction training
- annual refresher training.
|
7.31 |
- increases publicity for its hotline
|
7.37 |
- collects and analyses records of referrals received through the hotline to assess its
effectiveness.
|
|
- analyses the source of fraud
referrals to identify risk areas, trends and target resources.
|
7.40 |
- ensures that any necessary
investigation begins within 14 days of the data match
|
7.51 |
- records actions taken on
Housing Benefit Matching Service files to ensure a clear and
complete audit trail
|
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- analyses issues identified by
data matching for trends to inform improvements to benefit
processing procedures and policies
|
|
- applies correct
classification of overpayments resulting from Housing Benefit
Matching Service cases.
|
|
- conducts internal data matching to include:
- XXXX XXXX XXXX XX
- XXXX XXXX
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- XXXX XXXX XXXX
|
7.53 |
- reviews the results of Do Not Redirect referrals to:
- identify trends and patterns in fraudulent activity
- inform risk analysis.
|
7.58 |
- regularly reviews its appointment of authorised individuals for relevance and need.
|
7.64 |
- commences activity on all cases referred to the HB Fraud Investigation team within 5
working days of the referral being accepted for investigation.
|
7.70 |
- maintains proper records on
files in accordance with the Police and Criminal Evidence Act
1984, the Criminal Procedure and Investigations Act 1996, the
Regulation of Investigatory Powers Act 2000 and the Data
Protection Act 1998.
|
7.74 |
- maintains training logs and
professional development records to measure the effectiveness of
training
|
7.100 |
- conducts a training needs
analysis
|
|
- develops a training plan.
|
|
- introduces procedures to
monitor its own performance and the performance of the
Counter-Fraud Investigation Service against the Fraud
Partnership Agreement.
|
7.107 |
- administers formal cautions
when its policy criteria are met.
|
7.112 |
- offers an administrative penalty in all cases that meet its policy criteria
|
7.118 |
- implements a mechanism to
review recovery of fraudulent overpayments and administrative
penalties to ensure that rigorous and effective recovery action
is taken.
|
|
- publicises suitable cases to
send out a deterrent message to fraudsters.
|
7.122 |
Recommendations
| We recommend that London Borough of Hackney: |
Paragraph |
- revises appropriate work and
service plans to make clear the link between overpayment
policies and corporate strategic aims and objectives
|
8.16 |
- updates its overpayment policy documentation to reflect current operational practice and requirements
|
|
- provides training on overpayments to all staff involved in benefits administration.
|
|
- processes changes of
circumstances within the Standard of 7 calendar days
|
8.24 |
- sets targets for the
processing of changes of circumstances cases resulting in an
overpayment and monitors performance
|
|
- undertakes analysis of
changes of circumstances cases resulting in an overpayment that
takes longer than 7 calendar days to process, to establish
reasons for the delays and takes action accordingly.
|
|
- identifies overpayment
calculations that take longer than 14 calendar days to process,
to establish reasons for the delays and takes action accordingly
|
8.29 |
- ensures that staff are aware
of the correct procedures for identifying:
- proper effective dates of change
- uncashed and
returned cheques.
|
|
- improves the classification
of overpayments through its checking regimes and training
arrangements
|
8.40 |
- ensures that staff are aware
of the correct procedures for the classification of official
error and fraud overpayments
|
|
- reviews its quality and management checking process to ensure:
- overpayment decisions and subsequent recovery activity is subject to a minimum 10% check
- checks include all aspects of work undertaken
- checking activity is fully documented on both individual and summary records.
|
|
- records sufficient
information to explain the reasons for decisions and the
exercise of discretion, as to whether or not an overpayment is
recoverable and from whom.
|
8.47 |
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|
8.56 |
- sets a budget with staged
targets to achieve upper quartile performance against Best Value
Performance Indicator 79b
|
8.78 |
- employs all possible methods
of recovery
|
|
- completes final plans,
including completion dates, for:
- tackling all
outstanding CFM system debt
- the clearance
of outstanding invoice reminder and final notice work
|
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|
|
- ensures that reports to
Members are accurate in relation to the level of outstanding
debt and total recovery position
|
|
- ensures that its replacement
Benefits IT system can report accurately and comprehensively on
all aspects of overpayment recovery, including Best Value
Performance Indicator 79b.
|
|
- updates its overpayment
recovery strategy to reflect existing and planned policies for
improvement in the level and age of debt
|
8.88 |
- monitors the level and age of
all outstanding debt and reports the results to Members
|
|
- sets specific targets for a
reduction in the level and amount of dormant debt
|
|
- makes use of its write-off
procedures to ensure the timely and effective write-off of both
current and old debt, where it is appropriate to do so.
|
|