Makes clearing the outstanding work a priority, as it was having a major impact on all aspects of the Benefits service. (Paragraph 2.54)

Y

Backlog organised and ring-fenced, new staff recruited, deadlines set for clearance and monitoring set up.

BFI Directions report (January 2002) confirmed clearance of backlog.

Ensures that there is:

• a review of reception staff targets

Y

Targets reviewed and set in stages.

In 2002 there was a full review of the structure in the Revenues and Benefits Division of which the reception staff are a part.

Enquiries and call centre staff had received training.

Enquiries and call centre staff told us that they felt supported by the Benefits section when they were dealing with customers.

• an adequate number of reception staff

Y

Review to be conducted.

• comprehensive training provision for reception staff

Y

Daily briefing sessions to be set up. Training analysis incorporated into training plan.

• formal agreement between reception and benefits staff to improve working relationships. (Paragraph 2.67)

N

Procedures being revised and issued to staff.

Ensures that:

• there are enough staff to meet caller numbers

Y

Staffing levels to be reviewed.

In 2002 a new structure was agreed for the Benefits section. Not all posts were filled by permanent employees even though London Borough of Hackney had undertaken extensive recruitment exercises.

A new call centre was introduced in 2003 with 19 lines available and a dedicated team to staff it.

No facility to enable callers to leave messages.

• full use is made of all available telephone lines

Partial

Minimum of 12 lines in use daily.

• there are better working processes and staffing levels to accommodate workload

Y

Reduced opening times within Customer Services to make additional staff available.

• a facility is introduced to enable callers to leave messages. (Paragraph 2.78)

N

Call managing system recommended.

Introduces clear management arrangements to improve working relationships between call centre and benefits staff. (Paragraph 2.78)

Partial

Liaison meetings set up with managers.

Substantial improvements had been made but could be further improved by encouraging formal liaison below manager level.

Ensures that a comprehensive programme of fraud awareness training is introduced for:

Training programme set up following meeting with Audit and Special Investigation Unit.

Training provided to benefits assessment staff and visiting staff in post in June 2002 only. Training focused on raising awareness of new intelligence-led investigations structure rather than fraud awareness.

• customer service staff (Paragraph 2.80)

N

• housing service staff (Paragraph 2.206)

N

• visiting teams (Paragraph 2.175)

N

• benefit assessment staff. (Paragraphs 2.378 and 2.447)

N

Considers the impact of increasing the First Stop Shop initiative and ensures that any openings allowing fraud to enter the system through the First Stop Shop are closed. (Paragraph 2.83)

Y

Public Access Review commenced, liaison meetings to take place and staff to be updated with applicable changes in procedures.

The First Stop Shop initiative was terminated in March 2003.

Reviews its current post-opening procedures and introduces revised procedures to provide a secure controlled post opening process. (Paragraph 2.89)

Partial

Procedures being updated, partition installed – post room now secure.

Post opening procedures had been revised and significant changes implemented. However, no documented record of the review was retained. New procedures and arrangements satisfied most, but not all, of our previous concerns.

Takes account of our comments and the Good Practice Guide when finalising the new claim form. (Paragraph 2.93)

Y

Draft form drafted.

Claim form was
re-drafted taking account of our comments, however a new BFI model claim form was subsequently released in September 2002 making this re-drafted version out of date.

Does not introduce a shortened version of the renewal claim form. (Paragraph 2.95)

Y

No plans to introduce a shortened form.

No shortened form introduced.

Does not use dummy case papers. (Paragraph 2.102)

Y

No new dummy case papers to be created.

No evidence of dummy case papers being created.

Improves its verification of evidence to meet the requirements of the Verification Framework, in particular on capital and income. (Paragraph 2.110)

Partial

Staff to be fully trained, circular A21/2000 loaded onto system.

There had been improvements in verifying evidence of income. There were still shortcomings in verifying capital.

Amends the Verification Framework control sheet to show cross-checks have been made, then scans the sheet immediately. (Paragraph 2.112)

Partial

Verification Framework control sheet set up on system, spot checks to be carried out, Monitoring sheet to be adjusted to show cross-checks.

Evidence of cross-checks undertaken were not recorded.

Provides further training to staff on Verification Framework risk categories and monitoring is undertaken by managers to ensure that the correct group is allocated. (Paragraph 2.113)

Partial

Included into overpayments training.

Monitoring incorporated into Verification Framework check sheet.

New and renewal case samples showed improvement in this regard. There were 3 cases in the joint sample of 44 where our allocation of risk category differed from that allocated by London Borough of Hackney.

Introduces written procedures for ‘payments on account’. (Paragraph 2.115)

Y

Policy document and procedure drafted.

Payments on account done only where Rent Officer determinations were outstanding. Staff awareness of other appropriate circumstance was limited.

Ensures that all new Rent Allowance claims are processed for a payment on account if a determination is not made by day 15. (Paragraph 2.117)

N

To be implemented once procedure agreed.

We were told that the Benefits IT system was unable to monitor claims on the basis of the legal requirement to pay within 14 days. Our analysis showed that it took an average of 82 days to make a payment on account.

Monitors ‘payments on account’ made to ensure they do not continue longer than necessary. (Paragraph 2.118)

N

Investigate production of a report.

A generic system report was produced to monitor all claims with an interim rent indicator. This did not indicate claims that had exceeded the 6-week duration specified by London Borough of Hackney procedure guides. It was also not cross-matched against a list of returned Rent Officer determinations.

Changes its processes to improve processing times. (Paragraph 2.132)

Partial

Outstanding claims incorporated into daily work plan, resourcing being reviewed, increasing numbers of quality checks.

Processing times had improved since 2001. Exception reports to identify procedural weaknesses were not used. A new claims procedure was introduced in December 2002.

Implements and monitors the proposal to pass completed assessments to the commissioning team electronically. (Paragraph 2.140)

Not applicable

Commissioning team no longer in existence. All assessors are LBH employees.

Not applicable.

Provides training for assessment staff to improve quality of claims processing. (Paragraph 2.144)

Partial

Training analysis completed.

Training plan being implemented based on results.

Training priorities were concentrated on new staff and training in preparation for the new IT system. There were proposals to improve the range of training available to existing staff, but no evidence that this was in place.

Moves towards daily payment runs. (Paragraph 2.147)

N

Investigating the use of Bankers Automated Clearing Services and current daily system runs to introduce daily payment runs.

We were told that the finance IT system was unable to make payment by Bankers Automated Clearing Services.

No evidence of investigation of daily payment runs. London Borough of Hackney told us it would be considering this option further after implementation of the new Benefits IT system in the summer of 2003.

Reviews all stages of the new claims process to identify and address delays. (Paragraph 2.149)

Partial

New claims process under review.

A new claims process was introduced in December 2002. There was no evidence that London Borough of Hackney was monitoring this to determine shortcomings. However, it was a move in the right direction. The evidence available from system reports did not show any improvement in claim processing times from December 2002 to March 2003.

Does not include high-value payment checks as part of the 10% check but takes a totally random sample for accuracy and quality checking. (Paragraph 2.155)

Y

Quality checking in place. Report being devised to highlight payments above £4,000. Payment release after check and approval by manager.

Checks undertaken on all payments over £1,000 separately from the 10% check.

Increases its checking of commissioning team work to at least 10%. (Paragraph 2.157)

Y

Commissioning team no longer in existence.

Commissioning team no longer in existence.

BFI Directions report shows level of checking from November to December 2001 as 16.5% – 22.7%.

10% accuracy checks being undertaken though selection of the sample to ensure it covers all types of claims and all assessors’ work needs development.

Checks the indicators on the Remote Access Terminal and puts systems in place to notify Benefits Agency if indicators are incorrect. (Paragraph 2.160)

N

Remote Access Terminal procedure in place.

HB indicators were not being checked. We conducted a spot check and confirmed this.

Ensures there is a clear training strategy and equal opportunities for training for all staff.

Y

A training plan has been drawn up and commenced. Two members of staff have been seconded as Human Resources personnel for the benefits section.

Procedures were developed as part of a project. They covered most, but not all areas, and were available to staff via their desk top computers.

Training team set up with documented training plans created.

Appraisals undertaken for the first time in 2003.

• there are regularly updated procedures to provide a reference for benefit staff

Y

A system has been developed to hold all the circulars with procedural updates. Procedures should be held by team leaders.

• staff have the necessary skills and expertise to do the job

Y

The training plan has been developed.

• appraisals planned for all staff are carried out. (Paragraph 2.171)

Y

Investigate corporate appraisal system.

Introduce regular liaison meetings and exchange visits between the audit and special investigation unit and the visiting team. (Paragraph 2.175)

Y

Monthly liaison meetings in place and training dates to be set.

The Special Investigation team and visiting team both became part of the Audit and Anti-Fraud Division following a
re-structure in 2002.

Monthly liaison meetings took place.

Ensures that direct telephone lines are available to the Rent Service. (Paragraph 2.181)

N

Not available at present but will be discussed at next liaison meeting.

Not available.

Strengthens relations with the Rent Service by:

The last service level agreement expired in April 2002. A new one had not been signed by the time of our on-site inspection in March 2003.

A standard referral form and process had been introduced in January 2003. All referrals were subject to a 100% check by a team leader.

No exchange visits had taken place.

• introducing the new service level agreement and referral form

Partial

Under discussion.

• arranging exchange visits. (Paragraph 2.182)

N

To be arranged in addition to liaison meetings which are currently held on a quarterly basis.

Promotes applications for pre-tenancy determinations. (Paragraph 2.184)

Y

New procedure in place.

Advertising campaign to be devised.

Application forms for pre-tenancy determinations were available with promotional material in the reception area of Keltan House.

Ensures that all appropriate benefit claims are referred to the Rent Officer as required by legislation. (Paragraph 2.185)

N

Daily courier in place. Though we are currently looking at improving this procedure by the use of technology.

This recommendation was still outstanding.

Referrals were not made within 3 days of an application being received. It was taking an average of 72 days to make a referral.

Put procedures in place to identify housing association claims where the accommodation is larger than required or the rent is excessively high and to refer such cases to the Rent Officer. (Paragraph 2.188)

Y

Database of local rent levels being compiled for incorporation into new procedure.

Procedures were in place.

Develops an effective filing system for Rent Officer determinations.

Y

These are currently scanned onto the individual case histories and held on FSB. Not filed centrally. To be reviewed.

Rent Officer determinations were scanned on to the Hackney Interim Document System.

Claims were checked for valid determinations before a further one was requested.

Referrals were still referred manually, with a form completed by benefit staff and sent by the team leader to the Rent Service.

Checks to see if a valid determination already exists before requesting a determination.

Y

This already happens and is part of our management checks.

Ensures that requests for copies of the determination are checked and signed by a senior officer.

Y

Procedure to be reviewed.

Introduces a software solution to the management of Rent Officer referrals to ensure that 12 month re-referrals are raised automatically. (Paragraph 2.191)

N

Report produced, further review to continue.

Ensures it is correctly referring requests for re-determination to the Rent Officer and that quality of referral documents is improved by providing training to appropriate staff. (Paragraph 2.195)

Partial

Procedure reviewed.

Training commenced June 2001.

Sample of Rent Allowance claims very small due to problems identifying claim types from the report provided by London Borough of Hackney. No evidence from this sample that requests were not being made in appropriate cases.

Training had been provided by the Rent Officer.

No evidence of management checks in place to monitor the process.

Installs scanners in the outlets receiving documents. (Paragraph 2.198)

N

Current document imaging system limited shelf life. This option to be considered when new system in place.

Hackney Interim Document System only available at Keltan House. London Borough of Hackney told us that it did not have any plans to install scanners at Neighbourhood Housing Offices when its new electronic document management system was installed in October 2003.

Improves the liaison between Housing Service and the benefit assessors to create an effective working relationship. (Paragraph 2.205)

Y

Liaison meeting set up between Housing and Benefits via senior managers. Procedures to be drafted and agreed by all stakeholders.

Benefits section and Housing Directorate staff told us of much better working relationships. Managers met regularly to discuss issues impacting on both areas.

Ensures that:

• the current service level agreements with housing associations are up-to-date and contain realistic timescales

N

Service level agreement suspended due to current backlog issues. Regular liaison meetings in place.

Service level agreement with housing associations drafted but not signed or implemented at the time of our on-site inspection in March 2003.

Payments on account were made when a Rent Officer determination was outstanding. However, there was no process to ensure that payments on account were made on day 15. There was also no effective monitoring of payments of account that were made.

• the performance requirements are met

N

Policy document and procedure drafted.

• new Rent Allowance claims are passed for payment on account on day 15 when a full assessment cannot be made. (Paragraph 2.212)

N

Puts in place a formal programme of exchange visits with Benefits Agency, to include new and experienced staff. (Paragraph 2.216)

N

To be discussed as part of the service level agreement.

No exchange visits undertaken.

Uses the Remote Access Terminals or contacts Benefits Agency or Employment Service direct to confirm benefit rather than ask the claimant for confirmation. (Paragraph 2.217)

N

Instruction issued to all staff and monitored by team leaders.

Remote Access Terminal not being fully utilised. The case study in Processing of Claims (verification policies and procedures) shows that claimants continued to be asked to confirm receipt of IS or JSA(IB).

Amends the service level agreement with the Benefits Agency to include prescribed timescales for the return of SLA3s. Turnaround times should be monitored to ensure Benefits Agency compliance so that performance certificates can be signed off. (Paragraph 2.219)

Partial

To be reviewed.

Service level agreement drafted but not signed or implemented.

This issue had been overcome by the introduction of a Fraud Partnership Agreement between London Borough of Hackney and Counter-Fraud Investigation Service.

Agrees a service level agreement with the Employment Service which should include agreed targets and a mechanism for measuring performance. (Paragraph 2.222)

Not applicable

To be reviewed.

Not applicable.

Puts in place a formal programme of exchange visits for front line staff with the Employment Service. (Paragraph 2.222)

Not applicable

To be considered by senior manager.

Not applicable, but formal programme of exchange visits with Counter-Fraud Investigation Service was in place.

Uses risk analysis to establish the stock of fraud and high-risk groups within the claim load.

N

A basic manual risk analysis has been carried out and targets risk types identified. The service needs to purchase a computerised fraud management system for any detailed risk analyses to be possible. Awaiting the recruitment of an Assistant Director.

Detailed risk analysis had not been carried out.

There was no evidence that this was being done. However a risk group was allocated to all new claims. Staff showed a clear awareness of the criteria for allocation of risk groups.

Uses the results of this analysis to implement further proactive counter-fraud measures. (Paragraph 2.232)

N

Identifies and issues outstanding determination notices.

Y

Exercise undertaken in October 2000 to issue determination notices.

Decision notices were issued promptly.

Insert included in the envelope with the decision notice to advise claimants and landlords of the need to report changes of circumstances. Claimant may not appreciate that it formed part of the letter as no reference was made to it in the body of the letter.

Ensures that determination notices inform claimants of their responsibilities to report any changes of circumstances and give examples. (Paragraph 2.238)

Partial

Determination notices to be reviewed. Monitoring of daily dispatch and quality of notices to be introduced.

Issues guidance to staff reminding them that they must tailor benefit periods to HB and CTB claims based on the individual circumstances of the claim (Paragraph 2.245)

N

Guidance notice to be issued in consultation with the training manager.

Sample of new and renewal claims and reported changes of circumstances showed that this was not done.

No guidance had been issued.

Ensures that all necessary evidence is verified for renewal claims.

Partial

Verification Framework control sheet introduced to address this issue.

Verification procedure guide in operation was good. In practice, there were areas in which improvements were required. For example, verification of capital. XXXX XXXX XX XXXX XXXX XXXX XXX XXXX XXXX XXXX X XXXX XXXX XX XXXX XXXX XXXX XX XXXX XXXX XXXX XXX XXXX XXXX XXXX X XXXX XXXX

Ensures staff are trained to recognise potential irregularities in information supplied by claimants. (Paragraph 2.253)

Y

Verification Framework training for assessment staff to commence August 2001. Customer Services and First Stop Shop staff trained.

Reviews resources available to, and responsibilities of, the commissioning team so it can meet performance standards. (Paragraph 2.266)

Not applicable

Commissioning team no longer in existence.

Out of date.

Reminds staff that making payments without a determination is unlawful.

Y

As from 1 April 2001 service in-house and assessment staff now London Borough of Hackney employees. No unlawful determinations. Previous unlawful determinations are being
re-visited.

Some agency staff employed however changed benefit regulations meant these staff could make decisions.

Effectively monitors workloads to ensure payments cannot be made without a determination. (Paragraph 2.267)

Y

Improves performance standards in processing renewal claims by reviewing the current processes to identify, analyse and address causes for delay. (Paragraph 2.271)

Partial

Team set up to deal with current work.

Review has commenced.

Some processes had been reviewed but no evidence of the analysis undertaken to inform the changes. Further changes were necessary to avoid delays in referring appropriate cases to the Rent Officer and obtaining confirmation of IS/JSA(IB).

Establishes an accurate figure for renewal claims not returned, investigates the reasons and refers cases to the Audit and Special Investigation Unit where appropriate.

N

Review claims process to be reviewed and new procedure to be implemented.

Renewal claims not returned were not routinely referred to Audit and Anti-Fraud Division.

Sampling showed that claims were not always classified as new or renewal accurately.

Establishes procedures to ensure that claims are treated in the correct manner, as either new or renewals. (Paragraph 2.275)

N

Starts the review process as required by law. (Paragraph 2.278)

Y

A project plan has been drawn up to address this issue and will be implemented shortly.

Decision Making and Appeal legislation implemented on time. Effective process in operation.

Uses the results of first stage reviews as a management tool to identify training needs. (Paragraph 2.283)

N

A checklist will be completed for all cases amended in the claimant’s favour. The result will be passed to the Training and Policy team for analysis and identification of training needs.

No evidence that appeals were used to inform training plans or process improvements.

Takes immediate preventative action to stop unnecessary applications for Judicial Reviews by:

Hackney has started to tackle the backlog and are endeavouring to ensure that cases are completed at the ‘letter before action’ stage to avoid Judicial Review.

We have had a dedicated resource in this area since November 2000. It has allowed the section to target the backlog.

Backlog of 175 requests for reconsideration and appeals dating from October 2002. Dedicated team established to deal with this and internal target of 28 days to submit an appeal had been set.

Average time to make a reconsideration decision was 57 days. Average time to process an appeal was 148 days.

• reducing the amount of outstanding work

Partial

• improving performance in dealing with internal review processes so that claimants do not have to use judicial reviews to get benefit to which they are entitled. (Paragraph 2.298)

Partial

Analyses the weaknesses identified from complaints to inform remedial training for benefit assessors.

N

Complaints procedure and processes are being reviewed. Instructions to be issued.

No analysis of complaints undertaken. New IT system being introduced from April 2003 will allow this.

Payments on account were made but not promptly and they were not monitored.

London Borough of Hackney had much improved the way it handles complaints about the service.

Ensures that the agreed timescales are met and ‘payments on account’ are made in all appropriate cases.

N

To be incorporated into monitoring by managers.

Tries to improve the complaints service by taking the same steps we recommended for review cases. (Paragraph 2.314)

Y

Complaint procedures and processes are being reviewed. Instructions are to be issued.

Initiates a management and recovery plan for overpayments (Paragraph 2.328)

Y

Report currently under discussion and implementation has begun.

Overpayment recovery strategy initiated to address serious shortcomings in overpayment work identified in BFI report.

Further report for Members in draft at time of our on-site inspection in March 2003.

Ensures that:

• notification letters, compliant with Schedule 6, are issued to claimants and landlords

Partial

Overpayment letters have been revised and are being issued. Invoice/notification letter for landlords to be issued following completion of testing on Hackney Interim Document System.

Overpayment letters revised and issued promptly to all affected persons. Concerns remained in respect of the wording used on some initial decision notices. However, all sundry debts cases were reissued with compliant notices, prior to recovery.

Comprehensive guidance issued and training delivered on recoverability issues. Systems enhanced to aid decisions on recoverability.

• its officers determine the recoverability of overpayments in accordance with the Regulations. (Paragraph 2.335)

Partial

To be investigated.

Ensures the overpayment classification is correct.

Partial

Development of the Hackney Interim Document System now stores overpayment information.

Comprehensive guidance issued and training delivered on classification requirements.

Undertakes quality checks on the accuracy of the calculation and standard of documentation provided to support the classification.

Partial

Overpayments team to monitor classification.

Quality and management checks undertaken on overpayment work, but problems identified with the standard of record keeping.

Conducts a minimum of 10% management checks on overpayment classifications. (Paragraph 2.339)

Partial

Further developments being investigated.

Problems remained with the classification of fraud and official error overpayments.

Puts in place procedures to identify all excess CTB and establish the recovery rate for this debt.

Y

Excess CTB debt is transferred directly to the Council Tax bill and recovered as Council Tax arrears.

Excess CTB transferred directly to the Council Tax account and recovered as Council Tax arrears.

Instructs that recovery from ongoing benefit be made in all appropriate Rent Rebate cases. (Paragraph 2.343)

Y

This is in place. The parameters have been set up to allow recovery from Rent Allowance cases also.

Recovery arrangements in place to recover both Rent Allowance and Rent Rebate overpayments from ongoing benefit.

Ensures that all overpayments sent to the sundry debtors section are referred within 6 weeks of the notification being sent. (Paragraph 2.345)

Y

This is in force. Sundry debtor delay is currently set at 28 days.

All appropriate overpayments were automatically transferred to the Debtsys overpayment management system after 28 days.

Ensures that recovery action is only taken once recoverability has been determined. (Paragraph 2.348)

Y

This will be done as part of the recovery strategy.

Systems enhanced to aid the decision making process. Comprehensive guidance issued and training delivered. Process in place to complete new decisions on all old debt cases where original decision documentation was incomplete.

Reviews the existing recovery target and sets a more realistic level in line with the Audit Commission’s recommendation of 75%. (Paragraph 2.352)

Partial

Targets will be set and monitored as part of the overpayment strategy.

Best Value Performance Indicator 79b target of 25% and a total sundry debt target of £2 million, had been set for 2002/03.

Undertakes a complete review of all outstanding overpayments to ensure that all recovery action has been considered.

Partial

This has been addressed within the overpayment recovery plans/strategy.

Adopted a staged approach to the take-on of various recovery methods available. Only 3 methods in use, but had also commenced action to recover through other local authorities and Jobcentre Plus. Also had plans in place to use County Court procedures and was
re-considering use of debt collectors.

No documented procedures for the prioritisation of fraud cases.

Bespoke Debtsys overpayment management system developed in-house to control recovery of HB sundry debt.

Prioritises cases for recovery, for example fraud cases.

N

To be implemented as part of the recovery plan.

Ensures completion of the exercise to introduce a database for overpayments work and that all invoices and notification letters are issued to claimants and landlords. (Paragraph 2.357)

Y

Addressed with the authorities overpayment strategy.

Uses the various overpayment reports provided by its benefits IT software to monitor and control debts. (Paragraph 2.358)

Partial

This has commenced.

System reports produced were inadequate to report accurately and comprehensively on overpayment recovery. We were told the new Benefits IT system would rectify this.

Takes steps to ensure that fraud overpayments are correctly classified, staff should be:

To be addressed through the introduction of new procedures training, and monitoring.

Although benefit staff had received appropriate guidance and training, we identified that problems existed in relation to the classification of fraud overpayments.

• issued with clear guidance on the criteria for using particular classifications

Partial

• instructed that a "designated officer" must agree all fraud classifications. (Paragraph 2.362)

Partial

Analyses all outstanding overpayments for age and recoverability.

Y

This will be done as part of the recovery strategy.

Overall debt position reviewed for completion of the overpayment recovery strategy. Ongoing review of individual debts as part of recovery work. Analysis of the characteristics and make-up of CFM system debt completed. However, significant resource implications existed due to the size and complexity of the CFM system debt.

Plans for tackling CFM system and other outstanding old debt did not include timescales for final clearance.

A separate Overpayments team had been established.

Write-off policies and procedures were in place. However, these were not being used effectively.

Assesses the potential for recovering individual debts.

Partial

This will be done as part of the recovery strategy.

Calculates the resources required to recover them, or write them off.

Partial

This will be done as part of the recovery strategy.

Defines the timescales to complete the exercise.

Partial

This will be done as part of the recovery strategy.

Evaluates and minimises the impact on the rest of the organisation of the movement of resources from one area of work to another.

Y

This will be done as part of the recovery strategy.

Ensures the write-off policy supports these objectives. (Paragraph 2.365)

Partial

Existing policy to be reviewed.

In addition to using historical data from previous investigations, it analyses success rates from various types of fraud. It should also gather historical data from wider sources such as the Benefits Agency and re-focus attention on other areas and reduce the emphasis on residency fraud. (Paragraph 2.371)

N

A basic manual risk analysis has been carried out and targets risk types identified. The service needs to purchase a computerised fraud management system for any detailed risk analyses to be possible. Awaiting the recruitment of an Assistant Director.

Detailed risk analysis had not been carried out. Historical data from other sources had not been obtained. The emphasis on residency fraud had been reduced and attention had been focused on other areas of fraud.

Extend the use of the standard fraud referral form to other Departments that have contact with the general public, particularly housing services. This should be supported by the provision of training and written guidance. (Paragraph 2.374)

N

Standard referral forms being designed to source referrals from other departments.

The referral form in use was not available to all staff who came into contact with customers.

Awareness sessions delivered to customer service, benefit processing and visiting staff in June 2002.

Audit and Special Investigation Unit:

• makes sure that feedback is always directed to the originator of the referral, particularly where a member of the Visiting team submitted the referral (Paragraph 2.380)

N

In place. Feedback reports to be provided for distribution to appropriate individuals.

Audit and Anti-Fraud Division staff were not sure that feedback was always directed to the originator of the referral.

A direct line to receive calls from the public was in place, but publicity for this had been limited to one article in Hackney today.

Analysis of trends and productive sources and types of fraud had not been carried out.

• has a direct line to receive referrals from the public, which is publicised on posters and literature sent to homes (Paragraph 2.383)

Partial

Pending decision on review of unoccupied accommodation at Keltan House. Managers will liaise with regards to distribution of publicity.

• collects data on successful and unsuccessful investigations to analyse for trends, and productive sources and types of fraud. (Paragraphs 2.389)

N

Quarterly report to be produced on identified fraud.

Reviews the current provision of investigative staff to ensure full and proper use of investigative practices and powers.

Y

Subject to current corporate and directorate reorganisation. In addition the recruitment of an Assistant Director.

In 2002 a new structure for the Audit and Anti-Fraud Division was agreed and implemented.

A review of staffing and structure took place in 2001. A new structure, known as intelligence-led investigations was set up in 2002. The Intelligence/Risk team provided enhanced administrative support, sifted referrals and gathered further information relating to allegations of fraud.

Reviews and enhances the provision of administrative support. (Paragraph 2.392)

Y

Does a training needs and skills analysis of Audit and Special Investigation Unit staff and develops a training plan to address the deficiencies identified. (Paragraph 2.398)

N

Training needs analysis done. Awaiting decision on budget allocation to Audit and Special Investigation Unit.

A formal training needs analysis had not been carried out and we saw no evidence of a training plan.

The audit and special investigation unit manager instigates random quality checks on files. (Paragraph 2.407)

Y

Random checks on files in place.

The HB Fraud Investigation Manager carried out quality checks on all open cases on a fortnightly basis.

Ensures that all investigators are trained to conduct interviews under caution, once trained they should be instructed to conduct them in appropriate cases.

Y

Training needs analysis done. Awaiting decision on budget allocation to Audit and Special Investigation Unit.

Not London Borough of Hackney policy. Included in draft corporate anti-fraud strategy pending ratification.

All HB investigations staff had received Professionalism in Security training, which covers interviews under caution. We saw evidence that all investigators were conducting interviews under caution in appropriate circumstances.

London Borough of Hackney reviewed its policy not to prosecute and had prosecuted 7 cases by the time of our inspection.

Reviews its policy not to do prosecutions. (Paragraph 2.413)

Y

Makes Remote Access Terminal checks on cases in receipt of IS or JSA(IB) before starting an investigation. (Paragraph 2.414)

Y

Subject to current corporate and directorate reorganisation. In addition the recruitment of an Assistant Director for the section.

The Audit and Anti-Fraud Division had a Remote Access Terminal and checks on cases were being carried out.

Ensures that:

• the guidance on the ‘fit and proper person’ test is revised in line with advice from DSS

N

Issue for Revenues and Benefit Policy Unit. Audit and Special Investigation Unit willing to participate in drawing up guidance.

Investigate external training course.

New procedures to be implemented.

Fit and proper person test not used.

Investigations staff had not been trained in how to obtain the necessary facts to allow the fit and proper person test to be applied.

Liaison arrangements had not been put in place to allow the passing of necessary information between the Benefits Section and the Audit and Anti-Fraud Division.

• benefit assessors and investigators are trained how to obtain the necessary facts to allow the test to be done

N

• liaison arrangements are put in place to allow the passing of necessary information between the 2 sections. (Paragraph 2.414)

N

Considers whether there are sufficient resources to allow full and proper use of investigative practices. (Paragraph 2.418)

Y

Subject to current corporate and directorate reorganisation. In addition the recruitment of an Assistant Director.

In 2002 the Audit and Anti-Fraud Division structure was reviewed. At the time of our
on-site inspection the post of Assistant Director was filled by a consultant and 2 other posts were vacant. Because of delays filling some key posts it was too soon to assess the effectiveness of the changes.

Re-profiles the 2000/01 target taking into account the current 20% deficiency. The revised target should only be apportioned to the investigators actually working on fraud investigations. (Paragraph 2.427)

Not applicable

Lapsed recommendation. No longer relevant.

No longer applicable.

Amends the form sent to the benefits section to include the categorisation of the overpayment. And only claim weekly benefit savings when the overpayment is categorised by a designated officer. (Paragraph 2.436)

Y

Form amended.

The form had been amended

Audit and Special Investigation Unit develops an overall project plan to manage new initiatives and practices in a structured way. (Paragraph 2.437)

Y

Subject to current corporate and directorate reorganisation. In addition the recruitment of an Assistant Director.

A detailed project plan had been developed, covering the recommendation from our first inspection and preparation for the implementation of the intelligence-led investigations approach.

Appoints and trains inspectors as soon as possible.

Follows up non-returned renewals. (Paragraph 2.441)

Y

N

Four authorised officers appointed and trained.

Subject to current corporate and directorate reorganisation. In addition the recruitment of an Assistant Director.

Authorised individuals had been appointed and had received appropriate Professionalism in Security training.

Non-returned renewal claim forms had not been pursued.

Along with Benefit Fraud Investigation Service, make dipstick checks of caseloads to monitor performance against the standards set out in the service level agreement. (Paragraph 2.451)

N

On the agenda for next Benefit Fraud Investigation Service liaison meeting.

No formal monitoring of performance against the service level agreement had taken place.

Introduces a programme of exchange visits with Benefit Fraud Investigation Service. (Paragraph 2.453)

Y

Exchange visits taking place.

A programme of formal exchange visits had been implemented.

Work together more with Benefit Fraud Investigation Service. (Paragraph 2.455)

Y

On the agenda for next liaison meeting.

Audit and Anti-Fraud Division staff were working closely with Counter-Fraud Investigation Service staff. They had developed a joint working protocol and had signed a Joint Fraud Partnership Agreement.

London Borough of Hackney had undertaken 7 successful joint prosecutions with the Counter-Fraud Investigation Service.

With Benefit Fraud Investigation Service ensure that the service level agreement makes reference to keeping each other informed of investigations undertaken. (Paragraph 2.456)

Y

Included in service level agreement signed 10 May 2001.

The joint working protocol ensured that Counter-Fraud Investigation Service notified London Borough of Hackney whenever it initiated an investigation with an element of HB.

Liaises with Benefit Fraud Investigation Service to establish a link to monitor the return of QB64 and QB65 forms more effectively. (Paragraph 2.458)

Y

Return of QB64s/QB65s not Audit and Special Investigation Unit responsibility. Responsibility of Benefits.

However will discuss at next liaison meeting.

A contact point in Audit and Anti-Fraud Division had been established and was monitoring the return of QB64 forms.

Introduces its anti-fraud framework. (Paragraph 2.464)

Y

Draft corporate anti-fraud strategy produced pending ratification by London Borough of Hackney.

An anti-fraud and corruption strategy document was ratified by Members in November 2002.

Introduces a formal structure to publicise successful fraud work by including a statement in its prosecution policy on the use of publicity. (Paragraph 2.458)

N

Draft corporate anti-fraud strategy produced.

The anti-fraud and corruption strategy did not include a statement on the use of publicity.

Ensures that the revised anti-fraud policy is put in place as soon as possible.

Monitors the implementation of policies set out in the framework.

Makes operational guidance to support these policies available. (Paragraph 2.478)

Y

Y

Y

Awaiting ratification of anti-fraud policy.

Awaiting ratification of anti-fraud policy.

Awaiting ratification of anti-fraud policy.

An anti-fraud and corruption strategy was ratified by Members in November 2002.

The implementation of policies set out in the strategy document were being monitored via quarterly and annual work plans.

Operational guidance had been made available in support of these policies.

Centralises responsibility for recruiting all staff, including the follow up of any pre- and post-employment checks. (Paragraph 2.486)

N

Human Resources section set up. Review of recruitment procedure to be discussed.

Original recommendation made to address differences between staff employed by London Borough of Hackney and staff employed by its contractor. The contract was terminated in April 2001. However, differences still remain between directly employed and agency staff. Revised Human Resources guidance to be issued April 2003.

Periodically reviews the extent of user access to ensure that it remains relevant.

Y

All user base checked and all accounts with no activity locked. All accounts not authorised by relevant person locked.

Procedure being written to establish written communication between Human Resources and system.

Quarterly checks of user access in place. However, timely inhibition of access rights was not satisfactory. In addition, London Borough of Hackney had no formal process of using audit trail reports to support system security. Neither did its systems allow for automatic log-off activity.

Ensures that staff access is reviewed following a change of duty.

N

Introduces a formal process requiring staff to log-off if they leave their workstation and considers operating password controlled screens.

N

Reviews whether the current arrangements to record failed log-in attempts are adequate and that the user audit trail is satisfactory. (Paragraph 2.491)

N

Considers the level of Internal Audit activity in HB and CTB and establishes a minimum resource allocation. (Paragraph 2.503)

Partial

Awaiting the recruitment of Assistant Director.

The Internal Audit contract with external contractors had been reviewed to increase the total number of Internal Audit days available. Planned increases in 2002/03 and 2003/04 but reducing in 2004/05 to levels at the time of our first inspection.

Reviews its current system for following up Internal Audit reports and recommendations. (Paragraph 2.510)

Partial

Awaiting the recruitment of Assistant Director.

A new system for following up Internal Audit reports was agreed in 2002 which involved follow-up work 6 months after an audit. We saw evidence of follow-up work being undertaken but not within 6 months.

Examines the arrangements in place for preparing and checking the annual subsidy returns to ensure the accuracy and timeous submission of claims. (Paragraph 2.525)

Partial

A team has been set up to deal with the issues still outstanding from the 1999/2000 claim and resources have been allocated to deal with the submission of the 2000/01 claims on time.

A detailed list of the tasks required to complete the claims has been drawn up.

London Borough of Hackney had established a separate team to deal with subsidy and had provided awareness sessions for all assessment staff. Although subsidy remained an issue we saw positive steps being taken to overcome the problems.

Puts in place a comprehensive set of management checks supported by a validation system to ensure they are being done. The results of these checks should be used to monitor performance against target. (Paragraph 2.528)

Partial

Reports are being produced and a procedure to be drawn up for monitoring performance by senior managers. Subsidy team produce weekly caseload statistics for senior managers.

Management checks were not being undertaken in relation to claim processing. 100% check was being undertaken in relation to counter-fraud cases.

A comprehensive set of management checks had been produced for claims processing but not used.

Ensures that the problems with the current arrangements are recognised and addressed. If it is to have a contractor it should ensure that:

• the constraints on its ability to impose liquidated damages should be removed where targets are not met
• there is clear understanding of targets and how these will be measured
• there is a regular report back of performance against targets, fully supported by system reports, validated by the commissioning team
• where performance falls below agreed standard action is taken to correct the deficiency. (Paragraph 2.551)

Not applicable

Contracted terminated. Service back in-house.

Not applicable.

Reviews the role and resourcing of the commissioning team to ensure it can monitor and manage any contract. (Paragraph 2.551)

Not applicable

Contracted terminated. Service back in-house.

Not applicable.