Counter-fraud
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Fig. 7.1: Results of BFI’s assessment for Counter-fraud |
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Source: BFI analysis
For an explanation about how to read this radar chart see Executive summary
7.1 This section deals with London Borough of Barking and Dagenham’s efforts to deter, prevent and detect fraud and to deal with it when it is detected.
7.2 In its self-assessment London Borough of Barking and Dagenham told us that it was at Standard in one element of the Counter-fraud Standard, Authorised individuals. We did not agree with this assessment and found London Borough of Barking and Dagenham was not at Standard in any of the elements.
7.3 Until
October 2002 one investigator and a Counter-fraud manager undertook counter-fraud
activity at London Borough of Barking and Dagenham. From October 2002 additional
support was provided by an officer seconded from the Visiting team. In 2003
the Counter-fraud Officer left the authority following a period of absence.
In July 2003, 2 experienced
Counter-fraud officers were recruited and the secondee was temporarily appointed
as a Counter-fraud officer. In November 2003 a further experienced Counter-fraud
Officer was appointed and the temporary appointment was made permanent. Although
posts had been added to the Counter-fraud team delays and difficulties in
recruitment impacted on the level of
counter-fraud activity undertaken. London Borough of Barking and Dagenham
told us that although posts had been added to the Counter-fraud team, delays
and difficulties in recruitment had led to there being insufficient resources
available to deal with the workload.
7.4 We assessed the performance of London Borough of Barking and Dagenham against the Counter-fraud functional area in a variety of ways. We examined key documents, such as its published plans and policies. We interviewed managers and staff and examined referrals and sampled 100% of the fraud investigations opened since April 2003.
Policies and procedures
7.5 Local authorities should have specific counter-fraud policies, built on the policy objectives for the Benefits service as a whole. These policies should be supported by comprehensive procedures for the Counter-fraud team to ensure effectiveness, and consistency in:
· investigations
· recovery action
· prosecutions and other alternatives.
7.6 London Borough of Barking and Dagenham was not at Standard in this element because it did not:
· include in its prosecution policy, criteria for securing alternatives to prosecutions
· have an annual business plan for counter-fraud activity that included resource allocation, work profile or a Weekly Incorrect Benefit target
· document all counter-fraud operational procedures
· have counter-fraud operational procedures that reflected latest legislative changes
· monitor investigation results against the counter-fraud policy and account for any inconsistencies.
7.7 London Borough of Barking and Dagenham implemented an anti-fraud policy and strategy in June 2003. In August 2003, it communicated the policy and strategy to staff in the Rents and Benefit Business Unit and Housing and Health Department and placed a copy on the council’s intranet.
7.8 London Borough of Barking and Dagenham publicised its anti-fraud policy and strategy externally, through a publicity campaign in August 2003. This involved:
· placing advertisements on 4 bus shelters at key locations within the borough
· displaying posters in various locations within the borough, including all public libraries and the Civic Centre
· placing leaflets on display at London Borough of Barking and Dagenham's public reception counters
· live interviews with the Executive Member portfolio holder for Housing and Council Tax Benefits on 2 local radio stations
· press releases in the local press
· sending a copy of the press release by e-mail to local registered social landlords.
7.9 Through sampling, we found examples of letters and telephone calls received from members of the public, specifically quoting the publicity campaign.
7.10 London Borough of Barking and Dagenham also implemented a prosecution policy in June 2003. It included reference to the 3 main forms of deterrent actions of:
· an official local authority caution
· an administrative penalty equal to 30% of the overpaid benefit involved
· prosecution.
7.11 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX
7.12 A counter-fraud business plan had been developed for 2003/04. The plan stated that each of the Counter-fraud officers would:
· undertake 50 investigations
· achieve £20,000 additional subsidy for the authority through the Security Against Fraud and Error scheme
· conduct 5 prosecutions
· achieve 15 sanctions.
7.13 The
business plan was based on the assumption that there would be
4 Counter-fraud officers in post throughout 2003/04. However, London Borough
of Barking and Dagenham did not fill all posts within the
Counter-fraud team until November 2003.
7.14 The business plan did not:
· profile planned activities and expected outcomes according to the level and experience of the resources available
· include dates for any of the planned activities
· include targets for the value of Weekly Incorrect Benefit to be achieved.
7.15 In addition, it had not been reviewed with revised targets set in the light of the lack of Counter-fraud officers between April and July 2003.
7.16 London Borough of Barking and Dagenham had produced a range of documented counter-fraud operational procedures. However, there were no procedures covering:
· post returned under the 'Do Not Redirect' scheme
· the fraud hotline
· interviews under caution.
7.17 Also the counter-fraud operational procedures did not reflect the latest legislative changes. For example, there were no procedures covering the:
· Criminal Procedure and Investigations Act 1996
· Data Protection Act 1998
· Human Rights Act 1998.
7.18 London Borough of Barking and Dagenham told us that it did not monitor investigation results against its anti-fraud policy and strategy, so it did not know if:
· the anti-fraud policy and strategy was successful in reducing fraud
· the anti-fraud policy and strategy needed revising to take account of findings from fraud investigations
· cases
were being investigated consistently and fairly in line with its
anti-fraud policy and strategy
· appropriate sanctions were being missed where they should have been applied.
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· includes criteria for securing cautions and administrative penalties, in its prosecution policy · revises its counter-fraud business plan to: - profile planned activities and expected outcomes according to the level and experience of the resources available - include dates for all planned activities - include targets for the value of Weekly Incorrect Benefit to be achieved · produces fraud operational procedures that reflect the latest legislative changes and cover: - post returned under the 'Do Not Redirect' scheme - the fraud hotline - interviews under caution · monitors investigation results against its anti-fraud policy and strategy and accounts for any inconsistencies. |
Fraud referrals
7.19 Good quality fraud referrals are important as they:
· are essential to detecting and deterring fraud
· establish an authority’s reputation for rigour in claims processing
· indicate the type of fraud which may be prevalent in an area
· can identify weaknesses in benefit administration systems and the remedial action necessary
· influence the allocation of fraud investigation resources
· assure management that verification processes operate to identify fraud and error effectively.
7.20 London Borough of Barking and Dagenham was not at Standard in this element because it did not:
· have a referral form that captured all the required information
· provide appropriate written guidance on making a referral to all council employees, particularly those who deal with the public
· provide fraud awareness sessions to all employees at induction and support this with annual refresher training
· provide comprehensive feedback to the referrer, where appropriate
· provide quarterly feedback to Benefits service and Housing staff on the activities and success of fraud investigations
· publicise its counter-fraud activity and hotline quarterly
· have procedures to monitor quarterly the outcome of referrals received by source
· have procedures to sift all referrals, in line with the council’s risk and quality criteria, within 5 working days of receipt.
7.21 London Borough of Barking and Dagenham used 3 different forms for referrals made by:
· the Customer Services team, where a suspicion of fraud was generated by a telephone call from the public
· other staff in the Rents and Benefits Business Unit
· other council staff.
7.22 However, none of these forms captured all the required information. There were no prompt questions to:
· establish how the informant came to be aware of the alleged fraud
· establish the duration of the alleged fraud
· encourage callers to ring again with further information
· record the informant’s name and telephone number.
7.23 Separate procedural instructions had been produced providing guidance on making referrals for staff in the Rents and Benefits Business Unit and other council staff.
7.24 While an incomplete referral form does not mean a successful investigation cannot be carried out, London Borough of Barking and Dagenham’s instructions say that:
It is important to remember, without adequate detailed information, we cannot undertake an investigation.
7.25 London Borough of Barking and Dagenham had not provided any fraud awareness training or annual refresher training to the Assessment team in the 12 months before we went on site. However, while we were on site, London Borough of Barking and Dagenham told us it planned to deliver fraud awareness training to all Assessment team staff early in 2004.
7.26 Both fraud referral procedural instructions stated feedback would be provided to the referrer:
…a form F2 will be issued to the referring officer, acknowledging receipt of the referral. This will indicate the next course of action with the referral, if an investigation is to proceed and the officer to which it has been allocated.
7.27 The instructions for Rents and Benefits Business Unit staff and other council staff also stated progress reports would be provided.
7.28 However, through interviews and sampling we found London Borough of Barking and Dagenham did not:
· issue the referral acknowledgement form F2 to staff
· provide regular feedback on the progress and outcome of fraud referrals made by council staff
· provide quarterly feedback to Rents and Benefits Business Unit staff on the activities and success of fraud investigations.
7.29 London Borough of Barking and Dagenham did not produce a quarterly newsletter or press release publicising its counter-fraud activity or the success of the hotline. However, while we were on site London Borough of Barking and Dagenham told us it planned to:
· introduce a quarterly newsletter for staff, in December 2003
· produce a counter-fraud article for a newsletter to be issued to all properties in the borough.
7.30 London Borough of Barking and Dagenham did not have procedures to monitor the outcome of referrals received by source. It did not know:
· how many referrals it received
· the type of referrals it received
· how many referrals it received by source
· the types of referral it received by source
· which cases produced the best results by source and type
· how many referrals resulted in Weekly Incorrect Benefit being claimed
· the number of referrals where no fraud was found
· the amount and number of overpayments established through fraud investigation
· how many referrals were deemed not suitable for fraud action and the reasons why.
7.31 London Borough of Barking and Dagenham was unable to tell us the number, source, or type of fraud referrals it had received in 2001/02, 2002/03 and 2003/04. We analysed all fraud referrals received by London Borough of Barking and Dagenham since April 2002 to determine their source and type of alleged fraud. Figures 7.2 and 7.3 show the results of our analysis.
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Fig. 7.2: Source of referrals 2002/03 and 2003/04 |
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Source |
2002/03 |
2003/04 – 31 October 2003 |
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Rents and Benefits Business Unit staff |
143 |
224 |
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Fraud staff, including proactive fraud drives |
Nil |
1 |
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Other local authority staff |
6 |
20 |
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National Fraud Initiative data matching |
1,367 |
Nil |
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Housing Benefit Matching Service data matching* |
Nil |
282 |
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Registered social landlords and other landlords |
Nil |
Nil |
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The Department, Counter-Fraud Investigation Service, Jobcentre Plus |
2 |
10 |
|
Hotline |
18 |
81 |
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Public |
11 |
31 |
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Other external sources including the police |
3 |
14 |
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Post returned by Royal Mail |
4 |
3 |
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Total |
1,554 |
666 |
Source: BFI analysis
*The reason for the difference in performance in relation to Housing Benefit Matching Service between 2002/03 to 2003/04 is explained under the section on Data matching.
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Fig. 7.3: Referrals by type 2002/03 and 2003/04 |
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Fraud type |
2002/03 |
2003/04 – 31 October 2003 |
|
Living together as husband and wife |
91 |
134 |
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Income |
1,343 |
426 |
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Capital |
1 |
8 |
|
Identity |
Nil |
6 |
|
Tenancy |
6 |
14 |
|
Residency |
106 |
61 |
|
Non-dependant |
11 |
26 |
|
Total |
1,558 |
675 |
Source: BFI analysis
7.32 In both years, there were referrals containing more than one alleged type of fraud, so the total number of referrals was different to the total number of types of referrals.
7.33 Figure 7.2 shows there were significant increases in the number of referrals received from Rents and Benefits Business Unit staff, the fraud hotline and the public in 2003/04 compared with 2002/03. We consider that this demonstrates:
· awareness of the anti-fraud policy and strategy by Rents and Benefits Business Unit staff
· the effectiveness of the external counter-fraud publicity campaign.
7.34 Figure 7.3 shows the majority of referrals related to income, living together as husband and wife and residency.
7.35 London Borough of Barking and Dagenham told us it implemented its computerised fraud case management system in December 2003. London Borough of Barking and Dagenham should use the results of analysis of fraud referrals to inform:
· future patterns and trends
· the success of the hotline and external publicity
· resource requirements
· annual business plans.
7.36 London Borough of Barking and Dagenham had a risk assessment system to score incoming referrals. However, it told us it had abandoned the system in July 2003 due to a lack of staff resources.
7.37 The following 7 criteria should have been used in accordance with its risk assessment system:
· referral source
· quality of evidence
· nature of alleged fraud
· length of time for which benefit had been paid
· whether a previous file existed
· Verification Framework risk group
· the likelihood of proving fraud.
7.38 Each of the 7 criteria scored between 1 and 5 points, so the maximum score was 35 and the minimum 5 points. XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX
7.39 According to London Borough of Barking and Dagenham’s risk analysis procedural instructions, cases should be risk assessed within 5 days of receipt, with cases scoring over 25 treated as high priority cases.
7.40 Referrals were not risk assessed within the 5-day target. Our analysis of referrals received during 2002/03 and 2003/04, showed:
· only 34 of the 1,554 referrals received in 2002/03 had been risk assessed
· only 33 of the 666 referrals received in 2003/04 had been risk assessed
· no referrals had been risk assessed since July 2003.
7.41 We sampled all 10 referrals that had been risk assessed in July 2003 to measure the accuracy of the scoring. We found errors in all 10 cases including one case that had been scored as medium priority that should have been high priority. The Counter-fraud manager told us that due to the lack of resources, an untrained, inexperienced officer had undertaken the assessment of these referrals. Given this level of delegation, we would expect a senior officer to have checked some of these cases. However, none had been checked. We consider the use of untrained, inexperienced staff to risk assess fraud referrals to be very poor practice.
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· amends its fraud referral form to: - establish how the informant came to be aware of the alleged fraud - establish the duration of the alleged fraud - encourage callers to ring again with further information - record the informant’s name and telephone number · provides fraud awareness sessions to all employees at induction and supports this with annual refresher training · provides comprehensive feedback to the referrer, where appropriate, through: - the issue of acknowledgement forms - regular feedback on the progress and outcome of fraud referrals made by other London Borough of Barking and Dagenham staff - regular updates at Rents and Benefits Business Unit staff briefings · provides quarterly feedback to Rents and Benefits Business Unit staff on the activities and success of fraud investigations · publicises its counter-fraud activity and hotline through quarterly newsletters and external publicity · introduces a fraud case management system to monitor and record: - the number, source and type of referrals it receives - which cases provide the best results by source and type - how many referrals result in Weekly Incorrect Benefit being generated - the number of referrals where no fraud is found - the amount and number of overpayments established through fraud investigation - how many referrals are deemed not suitable for fraud action and the reasons why · XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X · sifts all referrals within 5 working days of receiving the referral · ensures that referrals are risk assessed and that regular management checks are performed on the accuracy of the scoring used. |
Data matching
7.42 The Housing Benefit Matching Service is run by the Department. It provides an authority with the opportunity to identify discrepancies between its HB and CTB records and records for other benefits such as:
· IS and JSA(IB)
· Incapacity Benefit
· Disability Living Allowance
· Working Tax Credit.
7.43 The Audit Commission runs the National Fraud Initiative that matches the data held by different local authorities. It provides English and Welsh local authorities with an opportunity to identify discrepancies between HB and CTB records and other details such as:
· student awards
· staff loans
· private pensions
· payrolls.
7.44 London Borough of Barking and Dagenham was not at Standard in this element because it did not:
· sift referrals in line with its policy and procedures
· investigate all referrals where appropriate
· start the investigation within 14 days from the receipt of the referral
· report the outcome of National Fraud Initiative data matching annually to Members, senior officers and the Audit Commission
· analyse the outcome of data matching exercises to identify if weaknesses in benefits administration led to the error
· amend its working practices when weaknesses had been highlighted
· internally match its benefit records against other council held data, such as educational awards, parking permits and traders’ licences
· refer appropriate cases to Jobcentre Plus’ Counter-Fraud Investigation Service for investigation.
7.45 London Borough of Barking and Dagenham told us it did not sift data matching referrals in line with its policy and procedures. All cases originating from the National Fraud Initiative and the Housing Benefit Matching Service were treated as high priority, without using the risk assessment criteria.
7.46 London Borough of Barking and Dagenham was suspended from the Housing Benefit Matching Service in February 2001. This was because it investigated only 15% of referrals in 1998, and failed to investigate any referrals in 1999 and 2000. London Borough of Barking and Dagenham was reinstated in July 2003, and received 282 data matches in August 2003.
7.47 London Borough of Barking and Dagenham did not keep a central record of the outcome of these data matching referrals, so it did not know how productive they were. We collated the results from each of the Counter-fraud officers to measure the progress made on these referrals. Figure 7.4 shows the results of our analysis.
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Fig. 7.4: Referrals and results from August 2003 Housing Benefit Matching Service exercise |
|
|
Amount |
|
|
Referrals received |
282 |
|
Referrals cleared and returned |
71 |
|
Referrals outstanding |
211 |
|
Sanctions applied |
Nil |
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Claims reassessed |
8 |
|
Total fraud overpayments recorded |
Nil |
Source: BFI analysis
7.48 Figure 7.4 shows that only 8 referrals had resulted in a change to the rate of benefit in payment. London Borough of Barking and Dagenham told us that in the majority of cases, HB and CTB had already been adjusted prior to receipt of the data match.
7.49 London Borough of Barking and Dagenham participated in the 2002 National Fraud Initiative and received 1,367 referrals in March 2003. London Borough of Barking and Dagenham maintained a central record of National Fraud Initiative referrals received. Figure 7.5 shows the results obtained by November 2003.
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Fig. 7.5: Results from National Fraud Initiative referrals received in March 2003 |
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Amount |
|
|
Referrals received |
1,367 |
|
Referrals cleared and returned |
12 |
|
Referrals outstanding |
1,355 |
|
Sanctions applied |
Nil |
|
Positive results* |
8 |
|
Total Weekly Incorrect Benefit recorded |
Not known |
|
Total overpayments reported |
£10,816 |
Source: BFI analysis
*Note: Positive results means overpayments identified and raised.
7.50 Figure 7.5 shows only 12 National Fraud Initiative referrals had been cleared, of which 8 had resulted in an overpayment identified and raised.
7.51 Of the 1,367 National Fraud Initiative data matching referrals received in March 2003, London Borough of Barking and Dagenham had commenced investigations in only 80 cases by August 2003. None of these cases commenced within 14 days of receipt of the referral. We sampled all 12 closed National Fraud Initiative cases investigated and found the average time taken from receipt of the referral to the start of the investigation was 92 days, with a delay of over 100 days in 5 cases.
7.52 London Borough of Barking and Dagenham did not report the outcome of National Fraud Initiative data matching to Members, senior officers or the Audit Commission. Members, senior officers and the Audit Commission did not therefore know how productive the exercise had been.
7.53 London Borough of Barking and Dagenham did not assess data matching to identify if weaknesses in benefits administration led to the error. In one case in our sample of 12 closed National Fraud Initiative cases, the customer had declared receipt of a private pension, but this had not been included in the benefit assessment. This had caused a local authority error overpayment of £2,200. In 2 other cases, the claim form was missing, so it was not possible to establish whether the customer had failed to declare an occupational pension. No action was taken by Counter-fraud staff to bring these errors to the attention of Benefits service staff.
7.54 London Borough of Barking and Dagenham did not internally match its benefit records against other council held data, such as educational awards, parking permits and traders’ licences. London Borough of Barking and Dagenham told us this was due to the lack of counter-fraud resources available to deal with any cases arising. In November 2002 London Borough of Barking and Dagenham purchased an IT system for the purpose of carrying out internal data matching, but this system had not been used.
7.55 London Borough of Barking and Dagenham told us it did not refer overload cases to the Counter-Fraud Investigation Service for investigation. These are fraud referrals which London Borough of Barking and Dagenham is unable to investigate due to lack of resource. This was despite the fact that:
· the reason given for the failure to investigate data matching was the lack of counter-fraud resources
· it had signed a local agreement with the Counter-Fraud Investigation Service, which included provision for referring appropriate cases to it, when unable to investigate them.
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· sifts all referrals in line with its policy and procedures and investigates where appropriate · starts the investigation within 14 days from the receipt of the referral and records the outcome of these investigations · reports the outcome of National Fraud Initiative data matching annually to Members, senior officers and the Audit Commission |
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We recommend that London Borough of Barking and Dagenham: |
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· assesses data matching to identify if weaknesses in benefits administration led to the error · amends its working practices when weaknesses have been highlighted · internally matches its benefit records against other council data, such as educational awards, parking permits and traders’ licences · refers appropriate cases to the Counter-Fraud Investigation Service for investigation. |
'Do Not Redirect'
7.56 Section 182A of the Social Security Administration Act 1992 allows local authorities to require providers of postal services not to redirect HB or CTB post. This can help identify possible fraudulent HB and CTB claims.
7.57 London Borough of Barking and Dagenham was not at Standard in this element because it did not:
· have procedural instructions for operating the 'Do Not Redirect' scheme
· use 'Do Not Redirect' envelopes for all benefit post
· record all items returned under the 'Do Not Redirect' scheme
· have a named contact point for liaison with Royal Mail or other relevant service providers
· liaise with Royal Mail to identify the address to which post would have been delivered
· ensure that the Counter-fraud team received post returned under the 'Do Not Redirect' scheme on the day it was received
· carry out a sift and investigate all cases where it appeared benefit had been paid while a redirection had been in force.
7.58 London
Borough of Barking and Dagenham did not have written procedural instructions
for dealing with post returned under the 'Do Not Redirect' scheme. XXXX XXXX
XXXX XXXX XXXX XXXX XXXX XXXX X
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX
XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX X
· XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX
· XXXX XXXX XXXX XXXX XXXX XXXX XXXX
7.59 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX 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 XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX X
7.60 London Borough of Barking and Dagenham did not record all items returned under the 'Do Not Redirect' scheme. From our analysis of all fraud referrals received since April 2002, we found only one envelope had been returned in 2002/03 and one in 2003/04, under the scheme. However, the first envelope had not been sifted and investigated. We consider the low level of referrals to the Counter-fraud team may indicate that the scheme was not being operated correctly, and that London Borough of Barking and Dagenham should investigate the reason for the low numbers.
7.61 We included the one case that had been investigated following a returned item under the 'Do Not Redirect' scheme in our fraud sample. We found the investigation established there was a genuine reason for the redirection.
7.62 Royal Mail had returned a further 3 items of post in 2002/03 and 2 items in 2003/04, where the addressee had gone away. However, XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXX
7.63 London Borough of Barking and Dagenham had a named contact point for liaison with Royal Mail. However, at the time we were on site, the named contact was absent long-term with no date for a return to work. London Borough of Barking and Dagenham had failed to appoint a deputy in his absence. No record existed of the name of the contact point at Royal Mail. This meant London Borough of Barking and Dagenham was unable to liaise with Royal Mail to identify the address to which post would otherwise have been delivered.
7.64 The Counter-fraud team did not always receive post on the day it was returned to London Borough of Barking and Dagenham. We examined all 7 items of returned post received by the Counter-fraud team since April 2002 and found only the latest item had been referred to the Counter-fraud team on the day of receipt. While we were on site, London Borough of Barking and Dagenham amended its internal post arrangements to ensure post was referred to the Counter-fraud team on the day of receipt.
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· produces written procedural instructions for the 'Do Not Redirect' scheme, and ensures that all appropriate staff are aware of the action to take where post is returned · uses 'Do Not Redirect' envelopes for all benefit post, including claim forms · records all items returned under the 'Do Not Redirect' scheme · investigates the reason for the low level of post returned under the 'Do Not Redirect' scheme |
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We recommend that London Borough of Barking and Dagenham: |
|
· passes all cases to the Counter-fraud team for investigation where there is a live HB or CTB claim in payment and where post has been returned by Royal Mail as gone away · sifts and investigates all cases where it appears benefit has been paid while a redirection has been in force · appoints an additional named contact point for liaison with Royal Mail · records the identity of the named contact point at Royal Mail · ensures that post returned under the 'Do Not Redirect' scheme is referred to the Counter-fraud team on the day it is received. |
Authorised individuals
7.65 Section 110A of the Social Security Administration Act 1992 provides for local authorities to authorise individuals to exercise the powers under sections 109B and 109C of the Act.
7.66 Authorised individuals have powers to:
· enter certain premises
· require a person to provide information, including the delivery of documents
· question persons on premises that have been entered under the powers.
7.67 The Act requires these powers to be exercised reasonably and at reasonable times. The powers help the proper investigation of suspected fraud and error and can be used if verification evidence is difficult to obtain.
7.68 In its self-assessment London Borough of Barking and Dagenham told us that it was at Standard in this element, however, it was not at Standard because it did not:
· maintain central records to show when, where and why authorised individuals had used their powers
· monitor the role of the authorised individuals to ensure compliance with legislation and assess their impact on counter-fraud and verification work.
7.69 London
Borough of Barking and Dagenham had appointed 3
Counter-fraud officers as authorised individuals. All 3 authorised individuals:
· had completed the relevant Professionalism in Security training module
· held a relevant certificate of appointment authorised by the Chief Executive
· had been registered with the Department’s Programme Protection Division in accordance with the Department’s circular F11/2001.
7.70 However, London Borough of Barking and Dagenham did not maintain a comprehensive record of when, where and why authorised individuals had used their powers. London Borough of Barking and Dagenham told us a central record was belatedly implemented in October 2003, containing details of instances where authorised powers had been used since September 2003.
7.71 London Borough of Barking and Dagenham made good use of authorised individuals’ powers. We examined the central record and found these powers had been used on 17 occasions since September 2003. Through sampling, we established that requests for information using these powers were used appropriately and according to the legislation.
7.72 London Borough of Barking and Dagenham did not monitor the role of authorised individuals to ensure compliance with legislation. London Borough of Barking and Dagenham told us no management checks had been performed on requests made using these powers nor were they assessed for their effectiveness in obtaining information.
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Recommendations |
|
We recommend that London Borough of Barking and Dagenham: |
|
· maintains a full central record to show when, where, and why authorised individuals have used their powers · monitors the role of the authorised individuals to: - ensure compliance with legislation - assess their impact on counter-fraud and verification work. |
Quality fraud investigations
7.73 It is important that investigations are focused to make best use of the resources available, and that each case is thoroughly investigated.
7.74 London Borough of Barking and Dagenham was not at Standard in this element because it did not:
· commence activity on all cases referred within 5 working days of the referral being accepted for investigation
· gather sufficient evidence to support conclusions and if necessary, invoke prosecution or other alternatives.
7.75 London Borough of Barking and Dagenham did not commence activity on cases promptly. Our examination of all referrals received since April 2002 showed that 570 had been received from sources other than data matching. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX This figure included nearly all the referrals received during 2002/03 and 2003/04 from:
· Benefits service staff
· other local authority staff
· Counter-Fraud Investigation Service
· the hotline
· the public
· other external sources, including the police.
7.76 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX
· XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXX
· XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX
· XXXX XXXX XXXX XXXX XXXX XXXX XXX
7.77 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX 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
7.78 We sampled XXXX X completed investigations, to establish the amount of time taken to commence investigation activity from the date of the referral being accepted for investigation. This showed that the average time taken was 74 days, with a range of between one and 198 days, including 4 cases where the delay was over 100 days.
7.79 London Borough of Barking and Dagenham was unable to provide us with full information relating to investigations in 2002/03 and 2003/04. It was unable to tell us how many referrals:
· it had investigated
· led to fraud being established
· led to Weekly Incorrect Benefit being recorded.
7.80 This was because no fraud case management system or clerical control records were kept.
7.81 London Borough of Barking and Dagenham did not always gather sufficient evidence to support the conclusions in its investigations. We found weaknesses on all 15 cases sampled, including:
· 4 cases where an interview should have been conducted with the customer
· 3 cases where a visit should have been made to the property to confirm residency
· 3 cases where there was no record of the source of the evidence obtained
· 4 cases where key evidence was missing from the file
· 4 cases where the conclusions were contradicted by the evidence obtained
· 7 cases where there was no record of amount, period and classification of the overpayment
· 2 cases where key customer details were missing
· 7 cases where obvious avenues of enquiry were not explored
· 3 cases where the quality of the evidence was unacceptable
· 3 cases with unexplained delays during the course of the investigation
· 2 cases where Benefits service staff had intervened while the investigation had been in progress, compromising all further fraud action
· 3 cases where an interview under caution had been conducted, but where there was no summary or transcript of the interview on file.
7.82 Fraud files did not always contain full background information. For example, 10 cases did not contain:
· the customer’s age, address, type of claim or details of HB and CTB paid
· a copy of the claim form.
7.83
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XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· commences activity on all cases referred within 5 working days of the referral being accepted for investigation · gathers sufficient evidence to support conclusions and if it is necessary to invoke prosecution or other alternatives, the evidence obtained must be admissible and to the criminal standard. |
Management of investigations
7.84 Proper management of investigations:
· focuses resources on the reduction of fraud
· identifies and rectifies administrative and investigative weaknesses
· assures Members and senior officers of the integrity and quality of investigations.
7.85 In its self-assessment London Borough of Barking and Dagenham told us that it was at Standard in 20 of the 21 components in this element. Our assessment was very different.
7.86 London Borough of Barking and Dagenham was not at Standard in this element because it did not:
· conduct management checks on investigations to ensure compliance with:
– the Police and Criminal Evidence Act 1984
– the Criminal Procedure and Investigations Act 1996
– the Regulation of Investigatory Powers Act 2000
– Social Security legislation
– the Human Rights Act 1998
– the relevant provisions of the Theft Act 1968.
· monitor the outcome of investigations, measure success against the business plan and achieve 100% of its Security Against Fraud and Error target
· use a computerised management information system to track all fraud referrals and monitor progress on them by individual investigators
· allocate referrals to a specific investigator, to avoid them being overlooked
· review and monitor investigators’ caseload allocations monthly
· have key review stages where documented decisions are taken on whether to proceed or close an investigation
· ensure that managers gave advice on the direction of the investigation, such as other avenues to explore and minimising further delay
· maintain records of all management checks
· submit data on time to the Department.
7.87 London Borough of Barking and Dagenham did not conduct any routine management checks on fraud investigations. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX
· 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 XXXX XXXX XXXX XXXX XXX
· XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X
· XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX
7.88 We found no evidence of any management checks in 14 of the 15 closed cases in our sample. The only case that contained evidence of a management check was where the Counter-fraud manager had checked a case to consider a sanction.
7.89 London Borough of Barking and Dagenham Members and senior officers had no assurance that:
· cases complied with all relevant legislation
· weaknesses in benefits administration and investigation were identified
· cases were investigated fully and to a high standard.
7.90 London Borough of Barking and Dagenham did not monitor the outcome of investigations and measure success against the business plan, nor did it achieve 100% of its Security Against Fraud and Error target. The 2003/04 counter-fraud business plan set a target of achieving £80,000 additional subsidy from 20 prosecutions and 60 other forms of sanction. XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX
7.91 London Borough of Barking and Dagenham did not use a computerised management information system to track all fraud referrals and monitor progress, nor did it maintain clerical records. This meant it did not know:
· how many referrals had been received
· which cases had been investigated
· which cases had been allocated to a particular officer
· how many cases were outstanding
· individual Counter-fraud officer’s caseloads
· the length of time cases had been under investigation
· how many cases resulted in positive outcomes.
7.92 Although London Borough of Barking and Dagenham purchased a computerised fraud case management system in October 2002, it was not used until after the on-site phase of our inspection in November 2003.
7.93 London Borough of Barking and Dagenham did not allocate referrals to specific investigators to avoid referrals being overlooked. Referrals were not allocated geographically or by surname. We were told that data matching received from the Housing Benefit Matching Service had been divided randomly between 3 of the Counter-fraud officers. We consider this will:
· increase the risk of a referral being missed
· make it harder to monitor and check caseloads
· lead to confusion by Rents and Benefits Business Unit staff, in the event of an enquiry during the course of an investigation.
7.94 London Borough of Barking and Dagenham did not review or monitor individual Counter-fraud officer’s caseload allocations, nor did it keep records of the number of cases held by Counter-fraud investigators. We established that 2 of the Counter-fraud officers maintained their own records of cases allocated, in the absence of any other form of record keeping. At the time of the on-site phase of our inspection, one officer had 83 live investigations and the other officer had 58. London Borough of Barking and Dagenham had not considered the appropriate caseload for its investigators.
7.95 London Borough of Barking and Dagenham did not review cases at key stages to make decisions on whether to proceed or close an investigation.
7.96 London Borough of Barking and Dagenham told us that the Counter-fraud officers decided:
· the course and conduct of the investigation
· which avenues to explore
· whether and when to close an investigation.
7.97 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX
7.98 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXX
7.99 London Borough of Barking and Dagenham had not submitted all data to the Department when required. Fraud statistical returns had not been provided to the Department for the quarters ended 30 September 2002 and 30 September 2003 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX London Borough of Barking and Dagenham also told us that when making statistical returns to the Department, it relied on a manual count of fraud cases, which may have contained inaccuracies.
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· conducts management checks on investigations to ensure compliance with: - the Police and Criminal Evidence Act 1984 - the Criminal Procedure and Investigations Act 1996 - the Regulation of Investigatory Powers Act 2000 - Social Security legislation - the Human Rights Act 1998 - the relevant provisions of the Theft Act 1968 · monitors the outcome of investigations, measures success against the business plan and achieves 100% of its Security Against Fraud and Error target · uses a computerised management information system to track all fraud referrals and monitors progress on them by individual investigators · allocates each referral to a specific investigator, to avoid referrals being overlooked · reviews and monitors investigators’ caseload allocations monthly · has key review stages where documented decisions are taken on whether to proceed or close an investigation · ensures that managers give advice on the direction of the investigation, such as other avenues to explore and minimising further delay · maintains a record of all management checks · submits data on time to the Department. |
Training for fraud investigators
7.100 Counter-fraud officers should be fully trained in:
· social security legislation and all relevant regulations
· relevant legislation, such as the:
- Police and Criminal Evidence Act 1984
- Criminal Procedure and Investigations Act 1996
- Regulation of Investigatory Powers Act 2000
- Human Rights Act 1998
- Theft Act 1968
· professional standards such as Professionalism in Security
· good practice such as that contained in Performance Standards and in the Department’s Fraud Investigators’ Manual or its Fraud Procedures and Instructions.
7.101 London Borough of Barking and Dagenham was not at Standard in this element because:
· it did not have a policy to provide ongoing, informal and formal training
· not all investigators were either studying for, or had obtained, a recognised professional counter-fraud qualification
· it did not maintain training logs and professional development records to measure the effectiveness of all training provided
· investigators did not have Specific, Measurable, Achieveable, Relevant and Time-based key work objectives
· XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX
7.102 London Borough of Barking and Dagenham did not have a policy to provide ongoing, informal and formal training, nor did it maintain training logs and professional development records to measure the effectiveness of all training provided. London Borough of Barking and Dagenham told us:
· there was no counter-fraud training programme
· Counter-fraud officers did not have individual training plans
· no training needs analysis had been carried out
· the Counter-fraud manager had not received HB and CTB awareness training
· the 3 Counter-fraud officers recruited in 2003 had received only 30 minutes training on the benefits IT system.
7.103 The 3 Counter-fraud officers recruited in 2003 had been fully trained in Professionalism in Security. However, the remaining officer was untrained. London Borough of Barking and Dagenham told us this officer would not be able to start Professionalism in Security training until April 2004, as all funding from the Department for this training had already been allocated for 2003/04.
7.104 The Counter-fraud manager had not been set any key work objectives. The Counter-fraud officers did not have Specific, Measurable, Achieveable, Relevant and Time-based key work objectives.
7.105 London Borough of Barking and Dagenham had a staff development programme that included proposals to conduct:
· an annual appraisal
· 6-monthly reviews.
7.106 However, Counter-fraud staff did not receive XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX For example, staff told us:
· 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 XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX
· none of the 3 Counter-fraud officers recruited in 2003 were aware of the corporate appraisal scheme.
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· ensures that investigators receive ongoing, informal and formal training · ensures that investigators are either studying for, or have obtained, a recognised professional counter-fraud qualification · maintains training logs and professional development records for investigators to measure the effectiveness of all training provided · provides Specific, Measurable, Achievable, Relevant and Time-based key work objectives for investigators · ensures investigators receive interim and annual feedback on their performance from their line manager. |
Liaison with Counter-Fraud Investigation Service and the National Investigation Service
7.107 The ability of local authorities to administer HB and CTB claims securely, effectively and efficiently depends on good working relationships with the Counter-Fraud Investigation Service. This is because both organisations are often involved with investigating persons in receipt of benefits administered by both local authorities and the Department.
7.108 London Borough of Barking and Dagenham was not at Standard in this element because it:
· had not signed a Fraud Partnership Agreement with the Counter-Fraud Investigation Service at Joint Operational Board level
· did not monitor performance against the Fraud Partnership Agreement service standards
· did not take appropriate action defined in the Fraud Partnership Agreement if standards were not met.
7.109 London Borough of Barking and Dagenham signed a local agreement with the Counter-Fraud Investigation Service in May 2003. The signatories were the Counter-fraud manager and the Counter-Fraud Investigation Service, Fraud Sector Manager. However, this agreement was based on the 2001/02 fraud service level agreement. This document was replaced by the Fraud Partnership Agreement in 2002/03. To be at Standard, the agreement needs to be signed at Joint Operational Board level.
7.110 London Borough of Barking and Dagenham signed a certificate of performance on the minimum standards agreed with the Counter-Fraud Investigation Service for 2002/03, in May 2003. However, the certificate did not include a summary of performance, showing whether, and to what extent, the minimum standards were met.
7.111 London Borough of Barking and Dagenham told us it did not carry out any monitoring of the service standards contained in the local agreement with the Counter-Fraud Investigation Service. This meant it did not know whether service standards were being met, or the extent of any deficiency.
7.112 London Borough of Barking and Dagenham did not take appropriate action if the minimum standards were not met. For example, through our examination of fraud referrals received since April 2002 but not acted upon, we found 5 received from the Counter-Fraud Investigation Service on 28 October 2003. These referrals had been sent to London Borough of Barking and Dagenham for consideration of investigation under the local agreement, as they had failed to achieve the score required for the Counter-Fraud Investigation Service to raise an investigation. However, none contained details of the allegation or the customer’s address. Without this vital information, London Borough of Barking and Dagenham would have been unable to score the referrals under its risk analysis system.
7.113 The minimum standard contained in the 2003/04 Fraud Partnership Agreement requires that the Counter-Fraud Investigation Service refers cases it was unable to investigate, to local authorities within 10 working days of receiving the referral. None of the 5 referrals had been passed to London Borough of Barking and Dagenham within 10 working days. Despite this, no action had been taken to bring this to the attention of the Counter-Fraud Investigation Service.
7.114 London Borough of Barking and Dagenham told us it did not refer cases to the Counter-Fraud Investigation Service where it was unable to investigate. In view of the very high number of referrals where London Borough of Barking and Dagenham had taken no investigation action, this meant potentially promising cases had been missed.
7.115 Through interviews with Counter-fraud staff at London Borough of Barking and Dagenham and the Counter-Fraud Investigation Service, we found other minimum standards were not being met. For example:
· liaison meetings between London Borough of Barking and Dagenham, the Counter-Fraud Investigation Service and Jobcentre Plus Operational Intelligence Unit managers were not held every quarter
· there were no formal minutes from liaison meetings held in May and October 2003
· the Counter-Fraud Investigation Service had not appointed a nominated liaison officer of supervisory grade
· the Counter-Fraud Investigation Service had not provided an up-to-date telephone list of contact points in all relevant Jobcentre Plus units.
7.116 London Borough of Barking and Dagenham had not taken any action to address these failures to meet minimum standards.
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· signs and monitors performance against a Fraud Partnership Agreement with the Counter-Fraud Investigation Service at Joint Operational Board level · monitors performance against the Fraud Partnership Agreement service standards · takes appropriate action defined in the Fraud Partnership Agreement if standards are not met. |
Formal cautions
7.117 In England and Wales a local authority may offer a formal caution as an alternative to prosecution, as long as certain criteria are met and the case is one the local authority would wish to see in court, if the caution were refused.
7.118 To be able to offer a caution the authority must have the same standard of criminal evidence required for a prosecution. A caution should only be offered if the local authority can then go on to prosecute, should the caution be refused.
7.119 London Borough of Barking and Dagenham was not at Standard in this element because it did not:
· consider the application of a formal caution in all cases that comply with its policy on sanctions
· set a target for cautions
· XXXX XXXX XXXX XX
7.120 London Borough of Barking and Dagenham’s prosecution policy did not contain any criteria for offering a formal caution. We have recommended that London Borough of Barking and Dagenham include criteria for securing cautions in its prosecution policy. Until this is implemented, London Borough of Barking and Dagenham will be unable to achieve Standard.
7.121 Although London Borough of Barking and Dagenham’s counter-fraud business plan for 2003/04 contained a target of 60 sanctions other than prosecutions. It did not set a specific target for the number of cautions it expected to achieve.
7.122 London Borough of Barking and XXXX XXXX XXXX XXXX XXXX X XXXX XX to date. London Borough of Barking and Dagenham had not conducted any interviews under caution prior to August 2003, therefore no cases had previously reached potential sanction stage. XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· considers the application of a formal caution in all cases that comply with its policy on sanctions · sets a target for formal cautions · achieves its target. |
Administrative penalties
7.123 Section 115A of the Social Security Administration Act 1992 provides local authorities with an opportunity to offer a customer an administrative penalty as an alternative to a prosecution. The penalty is 30% of the value of the overpayment. The full amount of penalties recovered by an authority may be retained as additional revenue.
7.124 London Borough of Barking and Dagenham was not at Standard in this element because it did not:
· consider the application of an administrative penalty in all cases that complied with its policy on sanctions
· set a target for administrative penalties
· XXXX XXXX XXXX XXXX XXXX XXXX
7.125 London Borough of Barking and Dagenham’s prosecution policy did not contain any criteria for offering an administrative penalty. We have recommended that London Borough of Barking and Dagenham includes criteria for securing administrative penalties in its prosecution policy. Until this is implemented, London Borough of Barking and Dagenham will be unable to achieve Standard.
7.126 Although London Borough of Barking and Dagenham’s counter-fraud business plan for 2003/04 contained a target of 60 sanctions other than prosecutions, it did not set a specific target for the number of administrative penalties it expected to achieve.
7.127 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· considers the application of an administrative penalty in all cases that comply with its policy on sanctions · sets a target for administrative penalties · achieves its target. |
Prosecutions
7.128 The ultimate sanction is to prosecute fraudsters. London Borough of Barking and Dagenham was not at Standard in this element because it did not:
· consider prosecution action in all cases that comply with its policy on sanctions
· XXXX XXXX XXXX XXXX XXXX XXXX XXX
7.129 The counter-fraud business plan for 2003/04 set a target of 20 prosecutions. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX
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Recommendations |
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We recommend that London Borough of Barking and Dagenham: |
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· considers prosecution action in all cases that comply with its policy on sanctions · achieves its prosecution target. |