An inspectorate of the Department for Work and Pensions.

Report

Charter Mark - Awarded for excellence

Appendix A: Summary of recommendations

Strategic Management

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
 
  • sets specific targets, including key milestones, to meet all Standards over time

 

  • develops objectives in relation to the links between efficient benefits administration and social inclusion and anti-poverty in its next Finance Directorate service plan.

 

  • 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

 

  • 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.

 

  • 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

 

  • communicates to customers, its local performance indicators on standards of service.

 

  • 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.

 

  • 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

 

  • ensures the results of the checks are used to inform individual staff training and development plans.

 

  • 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

 

  • fully assesses its management information needs in relation to the Benefits service, prior to implementing the new Benefits IT system.

 

  • 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.

 

  • 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

 

  • fully documented testing procedures are used to test all software releases and systems updates, including those for all interfacing systems

 

  • an IT disaster recovery plan is produced for the its fraud data-tracking database

 

  • its IT disaster recovery plans are tested at least annually and the outcome is used to refine the existing plan.

 

  • 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.

 

  • 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.

 

Customer Services

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

 

  • extends the checks on leaflets to include ensuring that they are up-to-date

 

  • 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

 

  • XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XX

 

  • 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.

 

  • 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

 

  • undertakes a survey to determine the suitability and accessibility of Keltan House and the 6 Neighbourhood Housing Offices for people with disabilities

 

  • uses the Language Line translation service as back up for its own staff.

 

  • 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.

 

  • 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.

 

  • 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

 

  • uses only one type of complaints form and guidance notes to avoid confusion

 

  • accepts complaints verbally from customers with no requirement for them to confirm in writing.

 

  • 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

 

  • ensures that the guidance in the Appeals Service’s Communication Bulletin 6 is implemented.

 

Processing of Claims

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
 
  • includes provision of document scanning facilities in its Neighbourhood Housing Offices on introduction of its new document management system.
 
  • 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.

 

  • 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.

 

  • 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

 

  • 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

 

  • 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.

 

  • 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

 

  • establishes appropriate quality checks to monitor the labelling of scanned documents to ensure an audit trail of evidence collected.

 

  • 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

  • XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX

4.101

  • sets collective and individual targets for the HB Visiting team that have links to performance required in its verification guidance.

 

  • 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

 

  • 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.

 

  • 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

 

  • 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.

 

  • 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

 

  • 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

 

  • 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.

 

Working with Landlords

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
 
  • 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
 
  • engages in regular communication with its smaller landlords to encourage closer working relations

 

  • formalises relationships with the Registered Social Landlords and Neighbourhood Housing Offices by introducing and monitoring the proposed service level agreements

 

  • 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.

 

  • 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

Internal Security

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.

 

  • 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.

 

  • 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

 

  • routinely monitors scanning and indexing timescales.

 

  • 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

  • XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XX

 

  • ensures Internal Audit provides comprehensive assurance on the security of the system of making and reconciling payments.

 

Counter-fraud

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.
 
  • 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

 

  • 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
    • XXXX XXXX XXXX
    • 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

Overpayments

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

  • XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX

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

 

  • XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX

 

  • 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.

 

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