Processing of Claims

Fig. 4.1: Results of BFI’s assessment for Processing of Claims

Source: BFI analysis

For an explanation about how to read this radar chart see Strategic Management

4.1 HB and CTB are vital payments made to help people on low incomes. As these groups of people are at risk their claims should be dealt with quickly and accurately.

4.2 To help us comment on Knowsley Council's effectiveness in this area we:

· held workshops and interviews with:

– key members of the management team

– Remote Access Terminal operators

– home-workers

– Quality Assurance and Control Team Leaders

– verification staff from Knowsley Housing Trust and The Village Housing Association

– Assessments Team Leaders

– Assessment Benefit Officers

– the Training Officer

– The Pension Service

– Jobcentre Plus

– The Rent Service

· analysed data files from both the Benefits and document image processing systems which included:

– a sample of 30 new claims which had been determined between
1 April 2003 and 30 June 2003

– a sample of 10 renewal claims which had been determined between
1 April 2003 and 30 June 2003

– a sample of 30 cases containing changes of circumstances which had been determined between 1 April 2003 and 30 June 2003

· examined key documentation and management information provided by Knowsley Council in support of its Performance Standards
self-assessment.

Knowsley Council confirmed that our findings were fair and representative of its claims population as a whole, although, the ratio of standard claims to IS/JSA(IB) claims (40% – 60%) was slightly higher than expected.

4.3 Figure 4.1 above shows that Knowsley Council is not at Standard in any area of Processing of Claims.

New claims – speed of processing

4.4 Regulation 76(3) of the Housing Benefit (General) Regulations 1987 states that every claim must be decided within 14 days of the relevant information having been received or as soon as is reasonably practicable thereafter. There is a similar provision in respect of CTB at regulation 66(3) of the Council Tax Benefit (General) Regulations 1992.

4.5 In addition to the statutory requirements the Best Value regime also requires local authorities to measure and report the average time for processing new claims and sets a target of 36 days.

4.6 To allow us to assess Knowsley Council’s performance, we took a sample of 30 new claims, which had been determined between 1 April 2003 and 30 June 2003. One claim in our sample had been in receipt of an extended payment and a new claim was made before the extended payment had ceased. This claim was subsequently treated as a reapplication and is therefore not included in our analysis of new claims.

4.7 Knowsley Council did not meet Standard but had strengths in the following areas of New claims – speed of processing.

4.8 System reports that identified the number of days taken to process individual claims were produced weekly. All cases failing to meet Standards were analysed by the Quality Assurance and Control team. The reports did not show the reasons for the delay. However, the reasons were identified by clerically checking individual claims.

4.9 Following our examination of reports produced in 2003/04, we identified a good practice to prevent delays in claims referred to the Rent Officer. Assessment officers filed all claims referred to the Rent Officer in their IT system pending trays. This action ensured that the document image and workflow system automatically allocated the returned Rent Officer decision to the same individual Assessment officer’s tray for processing, thereby reducing potential processing delays.

4.10 To achieve Standard Knowsley Council needs to:

· decide 90% of new claims within 14 calendar days of receiving all information

· improve the average time to complete processing of new claims to 36 days or less.

4.11 Processing times had shown a marked improvement in the period
April to October 2003 from that achieved in 2002/03. However, performance was still significantly below targets set in Standards.

4.12 Figure 4.2 highlights the scale of the improvement in processing new claims. Performance statistics produced by the council for October 2003 reported that 63% of new claims had been processed within 14 days of receipt of all information being received, giving a cumulative year to date figure of 61%.

Fig. 4.2: Percentage of new claims processed within 14 days
Claim type	2001/02	2002/03	April – October 2003/04
Rent allowance	24	33	61

Source: Knowsley Council

4.13 Our sample of 29 new claims showed 66% were determined within 14 days as shown in Figure 4.3. We were concerned to find 5 cases that had taken over 28 days to determine the claim following receipt of all the necessary information, this included one case taking 132 days. This highlighted the need for closer scrutiny of outstanding work.

Fig. 4.3: Analysis of new claims sample – time taken to decide claim
Time taken to decide	Number	%
Within 14 days	19	66
15 – 28 days	5	17
Over 28 days	5	17
Total	29	100

Source: BFI analysis

4.14 Performance Standards requires new claims to be processed within
36 days and council’s performing in the Best Value top quartile achieve this target. Knowsley council’s statistics for the period July – September 2003 shows in Figure 4.4 that this target was achieved.

Fig. 4.4: Average number of days to process new claims – April – October 2003
Month	April	May	June	July	Aug	Sept	Oct
Days	57.21	62.96	52.00	34.22	35.25	31.27	36.25

Source: Knowsley Council

4.15 However, Knowsley Council’s average number of days to process new claims for the period April – October 2003 was 44.17 days. This met the council’s own target of 45 days for 2003/04. Our sample of new claims, taken between April 2003 – June 2003 showed that the average number of days taken to process new claims was 46.8 days.

4.16 Knowsley Council told us that it had implemented a number of major changes since March 2000 which had caused a backlog of outstanding work and impacted processing times. These included:

· implementation of the VF

· introduction of document image and workflow system

· operational changes including the introduction of the Contact Centre and one stop shops

· new Benefits IT system

· Large Scale Voluntary Transfer of the housing stock

· VF pilot with registered social landlords.

4.17 Knowsley Council had attempted to directly control this through the use of overtime and agency personnel. At the time of our on-site activity Knowsley Council had significantly reduced the backlog of outstanding new claims and had begun to prioritise other areas of outstanding work. We look at this in greater detail later in this report under outstanding work.

4.18 Understanding peaks and troughs in workloads and identifying the reasons for hold ups at particular stages of the process provides management with the basis to plan and improve processing times. Our analysis of new claims at Figure 4.5 highlights where delays had occurred in the process and provides some answers to why the council’s ability to reach Standard had been undermined.

Fig. 4.5: New claims processing – days taken for each stage in the process
Work step	Average days	Range days
Date of receipt (at designated office) to date of receipt by assessment section	8	0 – 81
Date of receipt by an assessment section to all information or evidence available	15.9	0 – 101
Date of all information or evidence available to date of decision	17.1	0 – 132
Date of assessment or decision to date of first payment	5.8	1 – 24
Total days from claim received to first payment	46.8	8 – 149

Source: BFI analysis

4.19 Knowsley Council told us that registered social landlords responsible for accepting claims and verification of documents could hold on to paperwork for up to 2 weeks. We were also told by one of the registered social landlords we interviewed that it was common practice for a registered social landlord to receive documentation on a Monday and deliver it to Kirkby one stop shop on Friday afternoon. This may explain why our sample showed an average of 8 days between the date of receipt at a designated office to the date of receipt by an assessment section.

4.20 We found 9 cases in the sample that had taken significantly longer to action and had consequently had a major impact on average processing times. Regular monitoring would have identified these cases and enabled action to be taken at the point they were impacting on processing times. By excluding these cases the calculation of the average total days taken from the claim being received to the first payment was reduced to 28.6 days.

4.21 Another example of where a proactive approach would have reduced processing times was the education of landlords and customers to promptly submit claim forms and all supporting evidence. We also discuss this under Customer Services – timely, helpful response to public enquiries. Our sample contained 4 cases where it took between 42 and 101 days from receipt of a claim on the assessment section to the point at which sufficient evidence was received so that the claim could be determined. By excluding just these cases the calculation of average total days taken from the claim being received to the first payment was reduced to 38.8 days.

Outstanding work

4.22 Knowsley Council told us that new and renewal claims had taken priority over other outstanding work. We asked for a breakdown of outstanding work as at 12 November 2003 under a series of generic headings. The breakdown is shown in Figure 4.6.

Fig. 4.6: Knowsley Council outstanding work as at 12 November 2003
Category	Number of items over 5 weeks old	Total items outstanding	Date of receipt of oldest item
New claims	13	292	8/10/03
Renewal claims	279	916	18/7/03
Change of circumstances (general)	1,556	1,904	4/3/02
Change of circumstances (urgent)	710	925	24/4/03
Cases pending	46	506	8/5/01
Others	16,164	20,581	6/2/01
Total	18,768	25,124	–

Source: Knowsley Council

4.23 Knowsley Council told us that the high number of items in the "others" category included individual items of post as well as outstanding claims, and that the 20,581 cases included the following:

· CTB new and renewal claims

· documents related to HB new and renewal claims

· correspondence between Revenues and Benefits

· appeals outstanding

· Council Tax banding changes

· verification evidence.

4.24 We were told that a high percentage of this work outstanding was believed to be work that had already been processed.

4.25 We were also concerned about the volume of work outstanding in the other categories and the age of some items:

· 710 urgent changes of circumstances outstanding over 5 weeks old, with the oldest dated 24 April 2003

· 46 pending cases over 5 weeks old, with the oldest dated 8 May 2001

· one renewal claim almost 4 months old

· 1556 general changes of circumstances outstanding, with the oldest dated 4 March 2002.

4.26 We were also informed that approximately 500 NHB8 cessation of benefit forms received from the Department between November 2002 and January 2003 had not been processed or immediately entered on the document image processing system. The NHB8 forms had been retained as individual pieces of post and gradually entered on the document image processing system at a later date and over an unspecified period of time. Staff told us that it was not known if all the NHB8 forms had been processed or superseded by events or if some were still in the backlog of post awaiting action. Forms NHB8 should always be treated as a priority and action taken to ensure they are processed immediately on receipt.

4.27 We discuss the impact on counter-fraud staff in Counter-fraud – data matching. There is also the potential for increased official error overpayments and we discuss the implications of this in Overpayments – identification of overpayments.

4.28 It is not sufficient to collect details of outstanding work, it is vital that it is analysed and developed into quality management information to provide assurance and to facilitate decision making. XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX X At the very least we would have expected appropriate action to be taken to ensure the older items in all categories had been effectively resolved. The timescales for delays in dealing with the oldest items outstanding are not reasonable or acceptable levels of service.

4.29 In any backlog situation careful scrutiny of all post items must be regularly undertaken to ensure potential hardship is being avoided and that overpayments are not accruing.

Recommendations

We recommend that Knowsley Council:

· monitors the time taken between the various stages of claims processing to identify where delays are occurring · introduces procedures to ensure that all claims and documentation received by registered social landlords are delivered to its offices for processing on the same day · introduces a publicity programme to remind customers and landlords to send in all claims and supporting evidence promptly · takes immediate action to establish the precise nature of all outstanding work to prevent incorrect payments and potential hardship · instigates a recovery plan to address the outstanding work situation.

Payments on account

4.30 Regulation 91(1) of the Housing Benefit (General) Regulations 1987 requires local authorities to make a ‘payment on account’, if:

· they are unable to decide a rent allowance claim within 14 days of receipt of the claim, and

· that inability has not arisen out of the customer’s failure to provide the necessary information, when the local authority has requested whether on the claim form or otherwise.

4.31 Payments on account should only be made when necessary, and for as brief a period as possible, as they are not intended as a substitute for making a full decision and correct payment on a claim.

4.32 Knowsley Council did not meet Standard but had strengths in the following areas of Payments on account.

4.33 Rent allowance claims were monitored to identify if a payment on account was required and payments were made where appropriate in accordance with Regulations.

4.34 A system report was produced weekly for the 6 months prior to our
on-site activity, to identify cases where a payment on account was being made. This report identified all cases in payment for over 28 days and was monitored by the Quality Assurance and Control team to ensure follow-up action was taken. The weekly report did not identify the reason for a payment on account being made. Each entry was checked on the Benefits IT system by the Quality Assurance and Control team and appropriate cases referred to the Benefits assessment section with a recommendation of action to take, for example, to send a new Rent Officer decision request.

4.35 We were told that the Benefits assessment teams did not always take the appropriate or recommended action. This resulted in cases continuing to receive a payment on account and also recurring on the system report.

4.36 We were told that the vast majority of cases involved referrals to The Rent Service and that the authority had extended the payment period to 42 days due to arrears accruing in The Rent Service following the installation of a new IT system. We discuss this in greater detail under requirement to refer to Rent Officer.

4.37 We confirmed with The Rent Service that all arrears of work had been cleared and Knowsley Council told us that the 28-day period would be reinstated.

4.38 Our sample of new claims contained 5 cases where a payment on account was appropriate and had been made.

4.39 To achieve Standard Knowsley Council needs to:

· ensure that management are aware of the age and reasons for payments on account and monitor these on a monthly basis

· develop a process to ensure that assessment sections take prompt action on all cases referred weekly by the Quality Assurance and Control team.

4.40 The production of a monthly age analysis report for management showing claims that have been in payment for more than 4 weeks and identifying the reasons why, will provide benefit managers with assurance that control is being maintained over this area of work. It is important that final decisions on entitlement are being made and that payments on account are not being allowed to continue indefinitely, causing potential hardship and under or overpayments.

Recommendations

We recommend that Knowsley Council:

· develops and introduces a monthly management report that identifies all cases where a payment on account has been in place for more than 4 weeks and the reasons why · introduces procedures to ensure that assessment sections take appropriate and prompt action on all payment on account cases referred by the Quality Assurance and Control team.

Reported changes of circumstances

4.41 Between July 1997 and 17 October 2001, Sections 111A and 112(1A) to (1F) of the Social Security Administration Act 1992 (as amended) created specific legal offences relating to social security benefits making it an offence to dishonestly or without reasonable excuse to fail to notify a change of circumstances prescribed in regulations under the Act.

4.42 From 18 October 2001 Sections 111A(1A) to (1G) and section 112(1A) to (1F) created offences of dishonesty or knowingly failing to notify changes of circumstances effecting entitlement to benefit or other payment or advantage under the social security legislation which are not changes that are excluded by regulation from the changes that are required to be notified. These offences can be extended to landlords.

4.43 The Best Value regime requires local authorities to measure and report the average time for processing notifications of changes of circumstances.

4.44 Knowsley Council did not meet Standard but had strengths in the following areas of Reported changes of circumstances.

4.45 All communications with customers and landlords included explicit reference to the need to report changes of circumstances and a standard form of words was used. Evidence of this was found on our examination of the claim form and notices of determination.

4.46 Our sampling of 30 cases with changes of circumstances revealed that the correct effective date for change was being used and the council requested the same level of evidence to support the change as it did for a new or renewal claim.

4.47 To achieve Standard Knowsley Council needs to:

· make explicit the consequences of not reporting changes of circumstances on notices of determination

· process changes of circumstances on average within 9 calendar days of receipt of a written report or written evidence in support of a change.

4.48 Our sample of claims with reported changes of circumstances confirmed the assessment section’s policy of prioritising new and renewal claims before those with changes in circumstances. Figure 4.7 provides an overview of the time taken to process the changes of circumstances cases within our sample. The average time taken to process a change of circumstances in our sample was 58.2 days. 93% of cases in the sample took over 9 calendar days to be processed and 9 cases took over 10 weeks from the date received to the date processed.

4.49 Knowsley Council’s failure to take prompt action was leading in some cases to official error overpayments of benefit that could have been avoided. The loss to public funds and increased administration costs to the council is covered in Overpayments – identification of overpayments and Overpayments – classification of overpayments.

Fig 4.7: Time taken for Knowsley Council to take action on changes of circumstances cases
	Number	%
0 – 7 days	2	7
8 – 15 days	6	20
16 – 23 days	4	13
24 – 35 days	3	10
Over 35 days	15	50
Total	30	100

Source: BFI analysis

4.50 Knowsley Council prioritised its changes of circumstances into urgent cases and general cases, we were told that those cases deemed to be urgent included cancellations and other claims where the change could result in a decrease or increase in benefit. However, our sample of 30 cases included 9 claims (30%) where benefit had been overpaid.

4.51 In the 9 claims where an overpayment was incurred the cumulative number of days between the date the authority received the reported change of circumstances and the date it was processed was 625 days.

4.52 These results highlight weaknesses in Knowsley Council’s process for sifting and prioritising changes of circumstances cases.

4.53 The source of notification of the change was found to be the customer in 27 (90%) cases. Other sources included the Benefits assessment section, the Department and The Rent Service. However, we also found that opportunities were being missed to align benefit periods to known future changes of circumstances. We look at this in greater detail under tailoring of benefit periods later in this report.

Recommendations

We recommend that Knowsley Council:

· processes on average, changes of circumstances within 9 calendar days of receipt of a reported change or written evidence in support of a change notified by telephone · ensures its Notices of Determination for both customers and landlords make explicit the consequences of not reporting changes of circumstances · develops and implements a policy to ensure all changes of circumstances that have a potential material effect on the benefit award are prioritised and actioned accordingly.

Renewal claims

4.54 Regulation 72(14) of the Housing Benefit (General) Regulations 1987 and regulation 62(15) of the Council Tax Benefit (General) Regulations 1992 require local authorities to invite a customer to make a claim for a further award of benefit when a benefit period:

· exceeding 16 weeks is due to end within the next 8 weeks and no claim has been received

· is brought to an early end because entitlement or receipt of IS or JSA(IB) has stopped.

4.55 The Best Value regime requires local authorities to measure and report the percentage of renewal claims processed on time.

4.56 However, the HB and CTB (State Pension Credit) Regulations 2003 abolished benefit periods for pensioners from October 2003 and it is the Department’s stated intention to abolish benefit periods for working age customers from April 2004.

4.57 We noted that Knowsley Council had taken appropriate action in line with the abolition of benefit periods for pensioners from October 2003.

4.58 Knowsley Council did not meet Standard but had strengths in the following areas of Renewal claims.

4.59 Returned renewal claim forms were logged on the document image processing system and indexed appropriately. Administration staff undertook checking on all returned forms and took action to ensure reminder letters were suppressed.

4.60 The Benefits system issued a reminder to all customers failing to return renewal claim forms within 2 weeks of the expiry of the benefit period, advising that any delay might result in loss of benefit.

4.61 We were told that cases requiring a welfare visit were identified through a number of sources including, Benefits Assessment staff, Knowsley Housing Trust personnel and the Accessible Services staff at one stop shops. Customers who were elderly, infirm or required assistance with form completion for some other reason were identified and the system endorsed appropriately. These cases were treated as requiring a welfare visit and, instead of issuing a renewal claim form, a home visit was arranged.

4.62 We found no examples of benefit periods being extended inappropriately within our sample of claims and therefore conclude that benefit periods were not being extended for more than the maximum set out in accordance with the provisions of HB Regulation 66(4) and CTB Regulation 57(4).

4.63 Although benefit periods are to be abolished from April 2004, to achieve Standard in the meantime Knowsley Council needs to:

· invite further claims by sending out a claim form within 8 weeks of the expiry of the current benefit period

· decide at least 83% of claims before the expiry of the current benefit period

· operate a system of exception reports that contain the length of time since the receipt of the claim and the reasons for the delay, to monitor performance against claims not decided by the end of the current benefit period.

4.64 Our sample of 10 renewal claims contained only 4 cases (40%) that had been determined before the expiry of the benefit period. This figure is below the council’s out-turn figure for the period April 2003 – June 2003 (53%) and significantly below the figure required to reach Standard (83%).

4.65 We noted that the wording on notification of determination letters stated that an application form to renew the benefit claim would be issued about 6 weeks before benefit was due to end. We found that assessment staff and team leaders had different views. Some staff thought that renewal claim forms were issued 10 weeks before expiry of the benefit period and others 8 weeks before.

4.66 Our sample of 10 renewal claims showed that 5 claim forms were issued less than 6 weeks before the expiry of the benefit period.

4.67 We discussed the wording on notification of determination letters with Knowsley Council and we were told that the wording would be changed immediately to show that an application form to renew the benefit claim would be issued about 8 weeks before benefit was due to end.

4.68 Knowsley Council did not operate a system of exception reports to monitor the length of time since receipt of the claim and the reasons for the delay. We were told that where renewal claims were not returned a letter was sent to the customer advising the claim had expired and that it had not been renewed. No further follow up action was taken and the Benefit Investigation Unit was not involved.

4.69 It is important to follow up renewal claims that are not returned as this provides some assurance that benefit had been paid correctly, may identify previous fraudulent activity, and also serves as a deterrent to fraudsters.

4.70 Figure 4.8 shows the days taken for each stage of the process in our renewal claims sample.

Fig. 4.8: Renewal claims processing – days taken for each stage of the process
Work step	Average days	Range days
Date of receipt at designated office to date received by assessment section	9.5	3 – 44
Date received by assessment section to date all information or evidence available	3.4	0 – 24
Date of all information or evidence available to date of decision	26.7	7 – 58
Date of assessment or decision to date of first payment	9.4	1 – 26

Source: BFI analysis

4.71 The average total days for processing renewal claims in our sample was 49 days. This figure would not be a cause for concern if renewal claim forms had been issued 8 weeks before the expiry of the benefit period.

4.72 It is important that all claims are processed and determined before they expire if the council is to prevent possible hardship to customers or the threat of eviction. However, as 50% of the renewal claim forms in our sample were sent out less than 6 weeks before the expiry of the benefit period, the risk of benefit expiring before a renewal claim is both received and processed is significantly increased. Our sampling highlighted that in every case where the renewal claim was sent out less than 6 weeks before the expiry of the benefit period the claim was not renewed on time.

4.73 The findings from our renewal claims sample confirm the main delay in processing occurs after Knowsley Council had received all the information. These cases must be identified and given a higher priority to ensure they are processed before the expiry of the benefit period.

Claim forms accepted when incomplete

4.74 It is essential in all cases that the claim form, which is the gateway to benefit, is completed correctly and that Knowsley Council ensures its processes are stringent and do not allow fraud and error to enter the system at the front end of the process. The claim form is also the main way of collecting the initial evidence on which the claim is based.

4.75 XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX X the council was accepting and making payment on claim forms that were incomplete XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X

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	X	X
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX X	X	XXX
XXXX XXXX XXXX XXXX	X	XXX
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXX	X	XXX
XXXX X	X	X

XXXX XXXX XXXX XXX

4.76 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX

4.77 We were concerned to find that claim forms were not being scrutinised effectively to ensure that the first line of preventing fraud and error entering the system was rigorous. It is vital that all claim forms are thoroughly checked to ensure they have been fully completed, that every question has been answered in full or crossed through as not applicable and that the handwriting and colour of ink used is consistent. Incomplete claim forms provide no basis for a claim to be determined.

4.78 Failure to complete sections of a claim form may be a deliberate act on the part of a customer to conceal, for example, capital, income, or other people living in the same accommodation. If a case is later found to be incorrect, or the Benefit Investigation Unit becomes involved in an investigation, incomplete claim forms may prejudice or prevent a successful sanction being applied.

Recommendations

We recommend that Knowsley Council ensures that all staff involved with the acceptance of claim forms are reminded of the importance of checking the completeness of the forms and that all sections have been answered or crossed through.

Verification policies and procedures

4.79 Local authorities must verify information supplied by customers to decide entitlement to benefit. This is an essential part of securing the gateway to the HB and CTB systems. Regulation 73(1) of the Housing Benefit (General) Regulations 1987 require that:

…a person who makes a claim shall furnish such certificates, documents, information and evidence in connection with the claim…as may be reasonably required by the appropriate authority to determine that person’s entitlement to housing benefit…

4.80 There is a similar provision in regulation 63(1) of the Council Tax Benefit (General) Regulations 1992.

4.81 The Department has developed the VF, which sets out the minimum standards of verification that authorities should apply when processing HB and CTB claims.

4.82 Knowsley Council did not meet Standard in the following areas of Verification policies and procedures.

4.83 Knowsley Council adopted the VF on 1 March 2000. Our examination of documentation and interviews with staff confirmed the VF Procedures guide and the Department’s Circulars were available to staff on the council’s Intranet and hard copies were also held on individual sections.

4.84 The council used a document image processing system rather than paper based files. All original documents in support of the claim were photocopied and returned to the customer either at the one stop shop or by post, dependent upon the point of receipt of the documents. Registered social landlords also photocopy supporting documentation and return the original to the tenant before sending the claim form and supporting photocopied evidence to the council. The documentation is then sent to an external contractor for scanning on to the document image processing system.

4.85 Knowsley Council had implemented the registered social landlord Verification Framework scheme which allowed registered social landlords to verify claims and accept evidence on behalf of Knowsley Council. This partnership arrangement existed with 6 of its larger registered social landlords and Knowsley Housing Trust.

4.86 Benefits assessment staff, Accessible Services personnel and registered social landlords responsible for verification duties were all aware of the need for documentation to be supplied in support of claims to benefit. They were also aware that documents should be in their original form and all copies of them should be stamped, signed and certified as such.

4.87 To achieve Standard Knowsley Council needs to:

· have up-to-date policies, procedures and practices to ensure all appropriate documentation is provided to support claims

· provide ultraviolet scanners for all staff responsible for verification of documents and train them how to identify false documents

· ensure that evidence supplied is at least to the standard of the VF and any discrepancies identified are followed up, resolved and reasons documented

· consistently and correctly perform management checks.

4.88 We found that Knowsley Council applied a series of checks, detailed on a VF management control sheet to ensure appropriate documentation had been received to support claims to benefit and to confirm authenticity. However, weaknesses in the process made some of these checks meaningless.

4.89 The council’s one stop shops in Halewood, Huyton, Kirkby and Prescot all had ultraviolet scanners, although, we found that Accessible Services staff responsible for accepting and scanning evidence had not had appropriate awareness training to identify counterfeit or forged documents.

4.90 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 X

4.91 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 XX XXXX XXXX XXXX X We look at this in greater detail under the individual areas of verification and Internal Security - document management later in this report.

4.92 Several separate procedural notes and guidance had been produced relating to the operation of the VF including:

· training session notes on the claim form

· use and retention of Remote Access Terminal and Electronic Transfer of Data information

· management control sheet checklist

· application form information leaflet

· control sheet procedures notes

· IT Systems Guide

· information note for voluntary agencies.

4.93 We found that only the Systems Guide and VF Guide were dated or had a version number. All other procedural notes and guidance were undated and had no version control. We found one document that stated evidence of identity was not required in cases where IS/JSA(IB) was in payment and were told this should have been taken out of circulation some time before. There was no one individual assigned with responsibility for controlling guidance relating to verification policies, procedures and practices and therefore individual members of staff did not know if they were using up-to-date material or not.

4.94 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 XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX

4.95 Figure 4.10 provides an overview of Knowsley Council’s performance for verification of evidence in our new and renewal claims sample.

Fig. 4.10: BFI’s assessment of Knowsley Council for verifying evidence provided in support of claims
Verification item	Number requiring verification	Number where sufficient evidence held on file	% verified
National Insurance number – customer	40	38	95
National Insurance number – partner	4	4	100
Identity – customer	40	31	78
Identity – partner	4	3	75
Rent liability	40	36	90
Residency	40	34	85
IS/JSA(IB)	26	19	73
Income	14	8	57
Capital	7	2	29
Non-dependants	6	6	100

Source: BFI analysis

4.96 From our interviews with staff involved in the verification process, including Knowsley Council assessment staff, customer services personnel and registered social landlords it was apparent that refresher training was required on the requirements of the VF and the acceptance of documentation from members of the public.

4.97 Knowsley Council’s procedures for verifying evidence in support of claims did not provide an adequate level of security against fraud and error entering the Benefits system. The following sections detail its serious failings in this area.

Recommendations

We recommend that Knowsley Council:

· instigates a programme of training and awareness for all staff responsible for accepting, photocopying and scanning evidence to facilitate the identification of forged or counterfeit documents, and to ensure that when copies of evidence are taken, they are clearly stamped and signed to confirm authenticity · ensures that all registered social landlords responsible for verification of documents use ultraviolet scanners and are trained to the same level as its own staff · produces a series of guidance notes and procedural instructions that are dated and have version control to ensure staff are working uniformly · develops a rigorous process to ensure that where discrepancies are identified or additional evidence is requested it is documented and resolved before benefit is awarded.

Verification of identity

4.98 Since 6 September 1999, sections 1(1A) and 1(1B) of the Social Security Administration Act 1992 (as amended) requires HB and CTB customers and any partner included in a claim to provide:

· a statement of their National Insurance number and information or evidence establishing that the number has been allocated to them, or

· information or evidence enabling the National Insurance number allocated to them to be ascertained.

4.99 If a person does not have a National Insurance number, they should apply for one and provide all the necessary information or evidence to enable such a number to be allocated to them.

4.100 Knowsley Council did not meet Standard but had strengths in the following areas of Verification of identity.

4.101 Discrepancies identified through crosschecking of information in relation to identity were followed up and resolved and any action taken was recorded on the VF management control sheet.

4.102 To achieve Standard Knowsley Council needs to:

· show through its management checks that it is satisfied that the customer is eligible to receive HB or CTB before making a decision on a claim and that it complies with sections 1(1A) and 1(1B) of the Social Security Administration Act 1992 for HB and CTB claims

· improve its understanding and application of identity verification procedures to satisfy at least the standards of the VF.

4.103 Although the council’s verification procedures met the standards set out in the VF our sampling identified that they were not being applied consistently.

4.104 Figure 4.11 shows the results of the council’s verification of National Insurance numbers from the cases in our sample.

Fig. 4.11: Verification of National Insurance numbers of customers and partners in sampled new and renewal claims
Type of case	Number of cases requiring verification	Verification satisfactory
		Number	%
New claims – customer	30	28	93
Renewal claims – customer	10	10	100
New claims – partner	3	3	100
Renewal claims – partner	1	1	100

Source: BFI analysis

4.105 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 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 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 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX

4.106 Evidence of identity should be verified by examining 2 original documents supplied by the customer.

4.107 Our sampling identified 13 cases where the council used birth certificates, passports or driving licences to verify identity. We consider these as primary sources of evidence. The use of these primary sources of evidence constitutes a more thorough check of identity and we would encourage wider use of these sources. 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 XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX

4.108 We noted that Knowsley Council used documentation from previous claims for verification purposes. This practise is acceptable, however, Knowsley Council should have a policy or guidance in place to inform staff when to seek fresh evidence. For example when a passport has expired or if a driving licence contains an old address. It would be prudent and not unreasonable to request to see verification documentation again periodically.

4.109 XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX The process would be more secure if primary evidence was requested XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XX

4.110 Figure 4.12 shows the results of verification of identity in our sampled new and renewal claims.

Fig. 4.12: Verification of identity – in sampled new and renewal claims
Type of case	Total number of cases requiring verification	Verification satisfactory
		Number	%
New claims – customer	30	21	70
Renewal claims – customer	10	10	100
New claims – partner	3	2	67
Renewal claims – partner	1	1	100

Source: BFI analysis

4.111 Hostel dwellers, as defined in HB Regulations, are excluded from this requirement by virtue of HB (General) Amendment (Number 2) Regulations 1999.

4.112 Figure 4.13 provides analysis of the 10 cases in our sample of new and renewal claims where the process undertaken or evidence for verification of identity was not satisfactory.

Fig. 4.13: Analysis of failures relating to verification of customers’ and partners’ identity in HB and CTB claims – identified from new and renewal samples
Reason for failure	Number of new claims – customer	Number of renewal claims – customer	Number of new claims – partner	Number of renewal claims – partner
Evidence not stamped – certified true copy of original	2	nil	1	nil
Stamped as certified true copy of original but stamp not legible	4	nil	nil	nil
Insufficient evidence provided	1	nil	nil	nil

Benefit books accepted with old address and no Remote Access Terminal check	2	nil	nil	nil
Claim determined not entitled without any verification of identity	1	nil	nil	nil

Source: BFI analysis – one claim failed on two counts

4.113 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 XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX

4.114 We found 2 cases where IS/JSA(IB) payment books had been accepted with a letter from British Gas in one case and a benefit certificate in the second. 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 XXX

4.115 We obtained information relating to Knowsley Council’s Remote Access Terminal usage for the period April 2003 – June 2003 and compared it with information from 2 other councils of a similar size and ratio of IS/JSA(IB) claims to standard claims. Figure 4.14 provides details. These comparative statistics support our view that Knowsley Council is not maximising the potential of the Remote Access Terminal to provide up-to-date verification.

Fig. 4.14: Remote Access Terminal usage
Authority	Live load – February 2003	Remote Access Terminal usage April – June 2003
Authority A	16,180	5,104
Authority B	17,350	10,711
Knowsley Council	17,090	4,365

Source: BFI comparable data

4.116 It is important that staff are aware of the need and reasons for Remote Access Terminal checks. Our interviews with Benefits staff and Jobcentre Plus confirmed refresher training would be beneficial. The need to check all IS/JSA(IB) cases to confirm the HB and CTB indicator is correctly set is vital to ensure both Jobcentre Plus and The Pension Service are aware of the council’s interest in the claim and that changes in benefit are notified promptly.

4.117 XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX Although Knowsley Council requested that a new and up-to-date payment book should be produced benefit was awarded before the evidence had been received. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XX

4.118 The majority of the errors identified in our sampling appeared to be elementary mistakes, carelessness or an oversight. It is crucial that sufficient verification of identity is obtained in every case to ensure an individual is who they say they are.

Recommendations

We recommend that Knowsley Council:

· undertakes a programme of VF refresher training for all Benefits staff, Accessible Services one stop shop personnel and registered social landlords · develops a policy to ensure staff responsible for verification of documents know when to seek fresh verification and when to accept documents provided with previous claims · makes regular checks to ensure that all photocopies of original documents are signed and dated by the officer receiving them and that they are suitably and legibly endorsed as certified true copy of original · undertakes Remote Access Terminal checks in all appropriate cases · ensures all claims contain sufficient credible verification of identity to decide on the balance of probability that a person is who they claim to be.

Verification of residency and liability to pay rent

4.119 Section 130(1)(a) of the Social Security Contributions and Benefits Act 1992 provides that a person is entitled to HB if:

...he is liable to make payments in respect of a dwelling in Great Britain which he occupies as his home

4.120 Similarly, section 131(3) of the Social Security Contributions and Benefits Act 1992 provides for CTB:

The main condition for the purposes of subsection (1) above is that the person concerned –

(a) is for the day liable to pay Council Tax in respect of a dwelling of which he is resident.

4.121 These sub-sections mean that, before a local authority can award benefit, it has to be satisfied about both residency and liability to pay rent and or Council Tax.

4.122 Knowsley Council did not meet Standard but had strengths in the following areas of Verification of liability to pay and residency.

4.123 Our sample of claims confirmed that Knowsley Council followed up and resolved discrepancies related to verification of residency and liability to pay rent, identified through cross-checking of information and results were recorded on the VF management control sheet.

4.124 To achieve Standard Knowsley Council needs to:

· confirm the customer’s liability to pay rent and residency to at least the standard of the VF

· ensure procedures and practices are in place, to show with confirmation gained through management checking that:

– the customer is liable to pay rent at the address they state is their home

– resides at the address.

4.125 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 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 XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX X

4.126 Knowsley Council worked in partnership with 6 other registered social landlords who acted as agents undertaking verification of documents in support of benefit claims. We considered this changing relationship in our analysis of verification of liability to pay rent and accepted documented telephone calls, between Knowsley Council and 3 registered social landlords as verification of a further 5 tenants rent liability. It is vital that Knowsley Council develops policy guidance for staff to ensure procedures for the verification of liability to pay rent are clearly understood and correctly applied following the involvement of selected registered social landlords in the verification process. In these cases we consider documented telephone calls containing contact names were acceptable.

4.127 Knowsley Council should ensure that appropriate verification is sought and recorded on all other claims from tenants of registered social landlords not involved in the verification process, Housing Associations and private landlords.

4.128 We found 4 new claims with tenancy agreements and one letter from a landlord all stamped and annotated appropriately.

4.129 However, our sample also contained 4 cases where we considered verification fell below the standard required by the VF. Figures 4.15 and 4.16 show the standard achieved within our sample of cases and the reasons for failure.

Fig. 4.15: Verification of rent liability in sampled new and renewal claims
Type of case	Number of cases requiring verification	Verification satisfactory
		Number	%
Rent allowance new claims	30	26	87
Rent allowance renewal claims	10	10	100
Total	40	36	90

Source: BFI analysis

Fig. 4.16: Analysis of failures relating to the verification of rent liability – identified from new and renewal samples
Reason for failure	Number of new claims	Number of renewal claims
No evidence requested – (claim determined not entitled)	1	nil
Tenancy agreement dated 2001 for 6 months accepted	1	nil
Tenancy agreement stamped as true copy of original but not legible	3	nil

Source: BFI analysis – one claim failed on two counts

4.130 In our sample of 10 renewal claims verification of liability to pay rent was satisfactory in every case.

4.131 By stamping and signing documents as true copies of originals and by ensuring the stamping is legible, Knowsley Council will increase the number of cases with a satisfactory level of verification.

4.132 Figure 4.17 shows Knowsley Council’s performance for verification of residency.

Fig. 4.17: Verification of residency in sampled new and renewal claims
Type of case	Number of cases requiring verification	Verification satisfactory
		Number	%
Rent allowance new claims	30	24	80
Rent allowance renewal claims	10	10	100
Total	40	34	85

Source: BFI analysis

4.133 It is not sufficient to provide a rent book, tenancy agreement or letter from a landlord to satisfy verification of residency. The authority must also be satisfied that the customer is residing at the property. Confirmation of residency can be obtained in a number of ways. The most reliable way to check if a customer is occupying the accommodation is to undertake a home visit, however, obtaining recent correspondence containing the customer’s name and address is also acceptable. Recently paid utility bills are a good example, although other documents received through the post are also acceptable and should be judged on their respective merit, for example bank statements or letters from solicitors.

4.134 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 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX 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 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 XX 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 XX

4.135 The Visiting Team conducted a range of visits on behalf of the Benefits assessment section. In addition to new claims visits, 2,243 effective verification visits and 519 effective welfare visits had also been undertaken during the period April to November 2003.

4.136 Our sample of 10 renewal claims included 5 cases where a visit had been undertaken and 5 cases where sufficient documentation had been produced to verify residency.

4.137 Our sample of 30 new and 10 renewal claims contained 6 cases where the level of verification of residency was not satisfactory. Figure 4.18 highlights the reasons for failure.

Fig. 4.18: Analysis of failures relating to the verification of residency – identified from new and renewal claims
Reason for failure	Number of new claims	Number of renewal claims
Expired tenancy agreement	2	nil
Current Tenancy agreement supported by documentation containing old address	2	nil
Stamp confirming true copy of original not legible	2	nil
Total	6	nil

Source: BFI analysis

4.138 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 X 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 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 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX

4.139 The risk of fraud and error entering the system is not exclusive to any customer group or type of claim. Each case should be judged on its individual merits and an assessment of risk undertaken.

4.140 We accepted that residency had been verified in the 23 registered social landlord cases due to the partnership arrangements in place between Knowsley Council, Knowsley Housing Trust and the 6 other registered social landlords taking part in the Registered Social Landlord Verification Framework scheme. However, there was no policy in place to say what should happen in these cases and how staff should treat them. It is the council’s responsibility to ensure it has the necessary policies in place to provide assurance that all claims are genuine.

Recommendations

We recommend that Knowsley Council:

· ensures all tenancy agreements, rent books, letters from landlords or other evidence provided to verify liability to pay rent, are checked and copies appropriately signed and dated by the officer receiving them and are suitably and legibly endorsed certified true copy of original · obtains the same level of evidence for all claims, whether they are registered social landlords or private landlords · requests recently paid utility bills to confirm residency wherever appropriate when a visit is not appropriate · examines the circumstances of all claims to consider the level of risk and appropriateness of a visit.

Verification of receipt of IS/JSA(IB)

4.141 The Housing Benefit (General) Regulations 1987, Schedule 3, paragraph 10, Schedule 4, paragraph 4 and Schedule 5, paragraph 5, provide that when the customer receives IS or JSA(IB) the local authority must disregard a customer’s income, earnings and capital. There are similar provisions in the Council Tax Benefit (General) Regulations 1992. Before a local authority can assume the customer has no income or capital, it must obtain confirmation from Jobcentre Plus or The Pension Service that the customer is in receipt of IS or JSA(IB).

4.142 To achieve Standard Knowsley Council needs to:

· confirm entitlement to IS/JSA(IB) prior to determining entitlement to HB and CTB

· verify through management checking that confirmation of IS/JSA(IB) is obtained

· follow up and resolve discrepancies identified through crosschecking and record the actions taken.

4.143 Figure 4.19 shows the standard achieved for Verification of IS and JSA(IB) in our sampled cases.

Fig. 4.19: Verification of IS and JSA(IB) entitlement in sampled new and renewal claims
Type of case	Number of cases requiring verification	Verification satisfactory
		Number	%
New claims	18	13	72
Renewal claims	8	6	75
Total	26	19	73

Source: BFI analysis

4.144 In linked IS and JSA(IB) cases the council is not required to check a customer’s income, earnings and savings providing it obtains confirmation of entitlement from Jobcentre Plus or The Pension Service. This represents a significant reduction in the checking process when compared to standard claims. It is essential therefore that all IS and JSA(IB) linked claims are confirmed correctly.

4.145 Our sample contained 5 new and 2 renewal claims where evidence of IS and JSA(IB) failed to meet the required standard. Figure 4.20 highlights the reasons for failure.

Fig. 4.20: Analysis of failures relating to the verification of IS or JSA(IB) entitlement – identified from new and renewal claims
Reason for failure	Number of new claims	Number of renewal claims
Benefit book provided with old address and no Remote Access Terminal check made	2	nil
Statement of benefit provided and no Remote Access Terminal check made	1	1
Electronic Transfer of Data from the Department not received until after claim determined and no Remote Access Terminal check made	1	nil
Benefit book only accepted as verification of receipt of IS/JSA(IB) – stamp not legible and no Remote Access Terminal check made	1	1
Total	5	2

Source: BFI analysis

4.146 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 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 XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X 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 X

4.147 Undertaking Remote Access Terminal checks and ensuring that the stamping and signing of documentation is legible are both important elements towards achieving Standard in this area of Processing of Claims.

4.148 The need to develop a policy for dealing with IS/JSA(IB) claims is vital and should be complimented by a programme of refresher training. Our sampling confirmed that the present level and volume of management checking and control did not provide Knowsley Council with the necessary assurance that verification of IS/JSA(IB) was being obtained or that follow up action to resolve discrepancies was being taken.

4.149 We were concerned to find that Knowsley Council did not have any named contact points in Jobcentre Plus. If Benefits staff needed to contact Jobcentre Plus no direct lines or extension numbers were available. All calls were made through the public switchboard and staff were often asked to send a facsimile request before information was forthcoming. Knowsley Council needs to develop its relationship with Jobcentre Plus to ensure appropriate lines of communication are available to facilitate the exchange of information within the rules governing disclosure of information and the requirements of the Data Protection Act.

4.150 The additional effort that is required to remedy this situation is relatively straightforward and will build quality into the process.

Recommendations

We recommend that Knowsley Council:

· ensures documentation to support a claim provided by customers in receipt of IS/JSA(IB) is carefully scrutinised to ensure it is up-to-date and contains all relevant information · makes Remote Access Terminal checks on all claims where IS/JSA(IB) is stated to be in payment · establishes named points of contact through official liaison channels with the Department to facilitate the resolution of issues · ensures that all copies of documentation are signed and dated by the officer accepting it and that it is suitably and legibly endorsed certified true copy of original · implements an appropriate level and volume of checking to provide management assurance that confirmation of IS/JSA(IB) is being obtained and follow up action is being taken and recorded.

Verification of income and capital

4.151 In cases when HB and CTB customers are not in receipt of IS or JSA(IB), the local authority must verify the income and capital of the customer and any partner.

4.152 To achieve Standard Knowsley Council needs to take action in the following areas.

4.153 We were told that Knowsley Council follows the policies and practices outlined in the VF to verify all income and capital of both customers and their partners.

4.154 Our sample of 30 new and 10 renewal claims identified 14 cases that required income to be verified. Figure 4.21 highlights that in only 8 cases did we consider verification had been carried out to a satisfactory standard.

Fig. 4.21: Verification of income in sampled new and renewal claims
Type of case	Number of cases requiring verification	Verification satisfactory
		Number	%
New claims	12	7	58
Renewal claims	2	1	50
Total	14	8	57

Source: BFI analysis

4.155 Our analysis in Figure 4.22 highlights the reasons why the other 6 cases failed to reach Standard for verification of income. Legibility and a failure to stamp documents as certified true copies of originals was the issue in 4 cases. If stamping of documents had been satisfactory then the overall percentage of cases in our sample considered to meet the standard for verification of income would rise to 93%.

Fig. 4.22: Analysis of failures relating to the verification of income in standard HB or CTB claims – identified from new and renewal claims
Type of failure	New claims	Renewal claims
Stamp certifying documents true copy of original not legible	3	1
Benefit book provided with old address – new book requested – not provided and benefit paid	1	nil
Payslip accepted – not stamped	1	nil
Total	5	1

Source: BFI analysis

4.156 We found 2 cases in our claims sample where documents submitted in support of a claim to benefit had been identified by assessment staff as not meeting the required standard. XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX

4.157 We went onto consider verification of capital. Our sample of new claims contained a case where a customer had recently been bereaved. XXXX 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 X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X It is obviously important to treat such cases with sensitivity and tact; however, this should not detract from the need to ask additional questions to be satisfied that the verification of capital is satisfactory.

Fig. 4.23: Verification of capital in sampled new and renewal claims
Type of case	Number of cases requiring verification	Verification satisfactory
		Number	%
New claims	7	2	29
Renewal claims	nil	–	–
Total	7	2	29

Source: BFI analysis

4.158 Figure 4.23 highlights the number of claims we considered capital to be verified to a satisfactory standard

4.159 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 XXX 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 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX

Fig. 4.24: Analysis of failures relating to the verification of capital – identified from new and renewal claims
Type of failure	Number
Pay slip shows wages paid into bank account – bank details requested but not received and not followed up	1
Bank account details not stamped as certified true copy of original	2
Bank statements stamped but not legible	2
Total	5

Source: BFI analysis

Recommendations

We recommend that Knowsley Council:

· ensures that all documentation is signed and dated by the officer accepting it and it is suitably and legibly endorsed certified true copy of original · ensures that documentation provided by customers in support of their claim as evidence of income and capital, is carefully scrutinised to ensure that: - it meets the requirements of the VF - any discrepancies are followed up and claims are not paid until the issues raised are resolved · increases its level and volume of management checking to an appropriate standard.

Verification of non-dependant’s circumstances

4.160 HB and CTB are reduced for each non-dependant normally living with the customer. It is in the customer’s interests to provide details of
non-dependants because the amount of any deduction depends upon the circumstances of the non-dependant and, if they are in remunerative work, that person’s gross income. If a customer does not provide details of a
non-dependant’s income the highest relevant deduction must be applied.

4.161 Knowsley Council did not meet Standard but had strengths in the following areas of Verification of non-dependant's circumstances.

4.162 We found 4 cases in our sample of new claims where non-dependants had been declared in the household. In 2 cases the income of the
non-dependant was confirmed as IS/JSA(IB). A third case did not immediately confirm that the non-dependant was in receipt of IS/JSA(IB) and the higher level of deduction was initially applied and revised when IS/JSA(IB) was later verified. The fourth case did not supply details of the non-dependant's income and the higher rate deduction was assumed. This case was later annotated that the non-dependant had left the household. Action and verification was undertaken to a satisfactory standard, as appropriate, in all 4 cases.

4.163 Our renewal claims sample contained 2 cases with non-dependants, in one case the non-dependant had an apprenticeship allowance and in the second case 2 non-dependants were both students. Income had been verified to a satisfactory standard in both these cases.

4.164 To achieve Standard Knowsley Council needs to introduce an appropriate level and volume of prepayment management checks.

4.165 The council had identified in its own self-assessment that it did not follow up and resolve discrepancies identified through cross-checking of information or record the actions taken as a result.

Recommendations

We recommend that Knowsley Council:

· introduces an appropriate level and volume of management checking to provide management assurance · ensures its management checks confirm the income of all non-dependants and that an audit trail of discrepancies identified and follow up action taken is in place.

Management checks

4.166 Effective management checks provide information about:

· the integrity and security of benefit processes

· the quality of work such as the evaluation of performance against legislative and other requirements

· training and development needs of staff

· weaknesses in processes.

4.167 The Audit Commission, in Countering Housing Benefit Fraud – a Management Handbook, recommends that local authorities quality check at least 10% of claims as a way to prevent errors entering the process at the beginning. The check should take place before a decision notice is sent to a person affected.

4.168 Knowsley Council did not meet Standard but had strengths in the following area of Management checks.

4.169 The council performed accuracy checks across its caseload using the checking and sampling methodology in accordance with the Department’s instructions. The level of accuracy determined from the results of these checks was assessed as 100%. Knowsley Council had a target of 100% accuracy based on its 2002/03 out turn figures. However, there were no accuracy targets in place for individual members of staff. The Quality Assurance and Control team undertook the 125 Best Value checks each quarter and recorded the results.

4.170 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 X 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 XX

4.171 The Quality Assurance and Control team also undertook a variety of other checks including all new landlords created, all payment schemes created, 10% of manual benefit transactions and 10% of suspended claims. These checks were mainly concerned with internal security and assurance and did not involve full claim checking.

4.172 To achieve Standard Knowsley Council needs to:

· check 10% of assessment work before notifying the customer of the decision to confirm the assessment is lawful and the calculation is correct

· perform 10% checks at a level not below Senior Benefit Officer.

4.173 Our sample of 30 new and 10 renewal claims did not include any cases that had been subject to a management check. We confirmed through our interviews that assessment staff checked 10% of each other’s work and new or inexperienced staff were subject to increased checking of up to 100%. If any errors were found then the case was returned to the individual making the error for correction. Records of all cases checked were retained and the Assessment Team Leaders performed a 10% check of all the cases checked by assessments staff.

4.174 We confirmed that Team Leaders were therefore undertaking management checks on 1% of all cases processed. Any errors that were identified were recorded and returned to the assessor responsible for correction before returning to the Team Leader to note.

4.175 We were told that VF management control sheets were completed in all cases each time a claim was processed. Details to be recorded included all evidence supplied in support of the claim. Our sample of 30 new claims contained 5 cases where no control sheet could be found.

4.176 The volume and level of checking was insufficient to provide management with adequate assurance that claims were being processed correctly and in line with regulations. We were told that when the new Benefits organisation is in place the 4 new assessment sections would each have a Senior Benefits Officer who will be responsible for management checks and the Team Leaders will continue to check 10% of the checkers work. We were unable to obtain an implementation date for the new organisational structure from Knowsley Council and we discuss this under Strategic Management – organisational structure.

4.177 We noted that the council’s performance against the BVPI for the level of accuracy for claims processing was 100%. We expressed our reservations at this reported level of accuracy in view of our earlier findings in this report. Benefits management told us that they were equally concerned and intended to re-examine a number of checked cases a second time.

4.178 It is good practice to re-examine 10% of cases checked by both the Quality Assurance and Control team and Team Leaders one week in every 4. This provides an increased level of assurance that checking is being performed correctly and something Knowsley Council will gain from.

4.179 Management checking is a key component in the overall management and control of Benefits processing. Results of checking and the outcome of appeals cases, including those that are superseded are rich sources of information for management to gauge the overall performance of the Benefits service.

4.180 Analysis of this information can be used for a variety of purposes including:

· target setting

· training and development needs

· potential changes to working practices and processes

· staff appraisal.

4.181 The need for accurate and comprehensive management information gained through checking cannot be overstated. Failure to adequately manage and monitor performance at all levels is a barrier to continuous improvement.

4.182 The routine provision of quality management information gained through comprehensive management checking across the whole spectrum of Benefits related work and reinforced by randomly re-performed checks, provides senior managers and Members with increased assurance that Benefit payments are being made correctly and in line with Regulations.

Recommendations

We recommend that Knowsley Council:

· develops a process to ensure that management checks are made pre-notification · implements a checking regime at an appropriate management level to ensure 10% of all assessment work processed is randomly checked and that: - the work of all staff is included - the level of checking is increased when a higher risk of inaccurate decisions exists · undertakes a random management check to re-examine 10% of all cases checked by the Quality Assurance and Control team and Assessment Team Leaders one week in every 4.

Tailoring of benefit periods

4.183 Regulation 66 of the Housing Benefit (General) Regulations 1987 and regulation 57 of the Council Tax Benefit (General) Regulations 1992 require that awards are to be for a fixed period, which, when originally determined, must not exceed 60 weeks. Paragraph (2) of each of those regulations requires that:

The benefit period shall be such number of benefit weeks, as the relevant authority shall determine having regard in particular to any relevant circumstances that the…relevant authority reasonably expects may affect entitlement in the future.

4.184 These legal requirements on benefit periods take priority over any generalised risk categorisation procedures followed. However, when they have been applied, the VF gives guidance on the length of benefit periods that should be allocated to customers in different risk groups.

4.185 The legal requirements on benefit periods mean that, as well as taking risk groups into consideration, local authorities must also take account of potential or known changes of circumstances that could effect entitlement to benefit.

4.186 Knowsley Council did not meet Standard but had the following strengths in the area of Tailoring of benefit periods.

4.187 Our sampling and examination of documents confirmed that the council did not have benefit periods that exceeded 60 weeks and that benefit periods were only extended in line with the regulations. Knowsley Council also produced a quarterly exception report to ensure no cases had a benefit period exceeding 60 weeks.

4.188 To achieve Standard Knowsley Council needs to take account of known or anticipated changes when determining benefit periods.

4.189 Figure 4.25 provides details of our findings from sampling new and renewal claims.

Fig. 4.25: Benefit periods not set in accordance with regulations
Reason for non-compliance	Number of new claims	Number of renewal claims
Tenancy agreement end date not taken into account	3	nil
Future expiry of Working Tax Credits not taken into account	1	nil
Expected birth of child	1	nil
Total	5	nil

Source: BFI analysis

4.190 We found 3 cases in our sample of new claims where the expiry of a tenancy agreement had not been taken into account when awarding the benefit period and one example where the future expiry of Working Tax Credit had been overlooked.

4.191 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 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 XXX The customer should be provided with the opportunity to declare the changes in her circumstances at the earliest time given the potential significance of the change. Various benefits or some other form of income may become payable as a result of the birth of the child. A partner may join the household and the risk group may require amendment.

4.192 The abolition of Renewal claims in April 2004 will require Knowsley Council to reconsider its approach as customers will no longer be prompted to declare changes in their circumstances through a renewed declaration.

Recommendations

We recommend that Knowsley Council:

· provides refresher training to ensure that all staff understand the need to identify any future changes and take account of them when deciding benefit periods · develops guidance to provide consistency in decision making and to emphasise the need to consider all the facts and reasonableness of the information put forward.

Pension Credit

4.193 As part of its strategy to eradicate pensioner poverty, The Pension Service, which is an executive agency of the Department, has introduced Pension Credit.

4.194 Pension Credit came into effect from 6 October 2003 and replaced Minimum Income Guarantee. The key elements of Pension Credit are:

· guarantee credit, to ensure a minimum level of income to those customers aged 60 and over

· savings credit which will, from age 65, provide an additional income for pensioners who have made some provision for their retirement by having, for example, a small second pension or savings.

4.195 Local authorities need to work closely with The Pension Service in dealing with HB and or CTB claims that are linked to Pension Credit.

4.196 Where a customer is entitled to guarantee credit or guarantee credit and savings credit, The Pension Service will notify the local authority, and the customer will automatically receive full HB and or CTB.

4.197 When guarantee credit is in payment local authorities will award full HB and or CTB for as long as entitlement to the guarantee credit continues. If the customer is entitled to savings credit only they will have to claim standard HB and or CTB.

4.198 Local authorities are required by legislation to use The Pension Service’s assessment of the pensioner’s income and capital (the Assessed Income Figure). This means that for standard HB and or CTB claims when savings credit only is in payment, local authorities will not need to collect details of a pensioner’s income and capital. Instead they will rely on the figure provided by The Pension Service. Pensioners will only need to report changes in their circumstances, apart from those that are tenancy related, to The Pension Service.

4.199 Knowsley Council had a current, signed service level agreement in place with The Pension Service. The National Model had been adapted to suit local needs. We confirmed with The Pension Service that regular quarterly meetings were held between the two organisations. The Pension Service had conducted Pension Credit awareness sessions for a selection of Knowsley Council’s Benefits staff.

Tax Credit

4.200 Following on from Working Families' Tax Credit and Disabled Person's Tax Credit the Government introduced a new system of tax credits in
April 2003. The New Tax Credits comprise two elements:

· the Child Tax Credit

· the Working Tax Credit.

4.201 The introduction of New Tax Credits means that the Inland Revenue and local authorities will share a joint customer base comprising of HB and or CTB customers and Tax Credit customers. It is important that both agencies work together to meet the needs of their common customers and to administer both HB and or CTB and Tax Credits effectively.

4.202 To achieve this a Business Partnership Agreement was agreed in
April 2003 that sets out the minimum standards to be achieved by each party.

4.203 No formal discussions or structured meetings had taken place between Knowsley Council and the Inland Revenue and neither had an agreement been signed. Any contact with the Inland Revenue was by the Tax Credit Contact Line.

4.204 However, Knowsley Council had purchased and provided external Tax Credit training for its Benefits staff.

Recommendations

We recommend that Knowsley Council:

· establishes a forum with the Inland Revenue to create effective liaison arrangements and to facilitate appropriate exchange of information · formalises its working relationship with the Inland Revenue by agreeing and signing up to a Business Partnership Agreement.

Risk assessing and checking customers’ circumstances

4.205 Estimates in the second Housing Benefit Review: Main Stage Report, 1998 indicate that around 70% of fraud and error occurs as a result of customers or landlords failing to report changes of circumstances. It is essential therefore that local authorities carry out checks on customers’ circumstances. The frequency and type of check may be determined by a number of factors, such as:

· the risk associated with the type of claim

· whether or not HB is linked to IS/JSA(IB) entitlement

· the method used to pay benefit.

4.206 Knowsley Council did not meet Standard for Risk assessing and checking customers' circumstances. However the councils risk management process for the setting of risk groups was aligned with that set out in the VF.

4.207 To achieve Standard Knowsley Council needs to:

· assess the risk of fraud and error in every claim and confirm through management checking that the risk has been assessed correctly

· conduct checks on customer’s circumstances to at least the level required by the VF and record the outcome.

4.208 Our sample of 30 new and 10 renewal claims showed that the council was failing to allocate risk groups correctly as detailed in Figure 4.26. We found 7 (17.5%) cases where the risk group was incorrect. In 6 cases the risk category was set higher than the circumstances of the claim warranted. In one case a category D risk group had been assessed as a category E. It is important to ensure risk categories are reviewed on any change of circumstances and benefit periods should also be reconsidered.

Fig. 4.26: Allocation of risk categories to claims
	Cases allocated correct risk group	Cases allocated incorrect risk group
New claims	26	4
Renewal claims	7	3
Total	33	7

Source: BFI analysis

4.209 We found that Knowsley Council’s VF management control sheet included a check of the risk group allocated to a claim, however, Team Leaders checked only 1% of all cases processed and not all cases in our sample contained a VF management control sheet. The level of checking that was being applied was clearly not sufficient to ensure all claims had been correctly risk assessed.

4.210 The abolition of benefit periods for pensioners from 6 October 2003 and for people of working age from April 2004 will have an impact on risk assessing and checking customer’s circumstances. The key features of the replacement for benefit periods are open-ended claims with an in-claim management regime based on improved data matching, targeted interventions and interventions triggered at points of predicted change. These changes will be included in the VF and a revised version of Performance Standards.

Recommendations

We recommend that Knowsley Council confirms through its management checks that the risk attached to every claim has been assessed in line with the requirements of the VF and that the outcome of all checks is recorded.

Requirement to refer to Rent Officer

4.211 The Housing Benefit (General) Regulations 1987 require a local authority to refer certain rent allowance claims to the Rent Officer (or The Rent Registration Service in Scotland) for a determination to be made on the level of rent eligible for HB. The local authority is required to make this referral within 3 working days or as soon as practicable. The regulations also provide for an application to be made for a pre-tenancy determination.

4.212 Knowsley Council did not meet Standard but had strengths in the following areas of the Requirement to refer to The Rent Officer.

4.213 Applications for pre-tenancy determinations were referred to the Rent Officer by facsimile within 2 working days of receiving a request. A weekly report was produced to monitor the progress of all referrals and to ensure determinations were returned from the Rent Officer.

4.214 Cases where a payment on account had been in place for over 28 days were identified by the Quality Assurance and Control team and a recommendation report made to the Benefits assessment section for information and action to take. The period of 28 days was extended to 42 days due to delays following The Rent Service’s change of IT systems. We confirmed with The Rent Service when we were on site that it was up to date with referrals. We advised Knowsley Council and it reverted to identifying cases over 28 days.

4.215 To achieve Standard Knowsley Council needs to:

· meet its legal requirements to make applications to The Rent Service within 3 working days of receiving a claim or as soon as practicable thereafter

· agree and sign a service level agreement with The Rent Service

· re-establish quarterly meetings with The Rent Service and to ensure monitoring of the service level agreement takes place.

4.216 Our new claims sample was taken from the period April to June 2003, during which time Knowsley Council’s records showed the average time to process a new claim was 57.4 days. Our sample identified that cases were not being promptly referred to The Rent Service and decisions were not being made within 2 working days of the receipt of a Rent Officer determination. Figure 4.27 highlights the time taken between the various stages of the process for the 4 cases correctly referred to the Rent Service.

Fig. 4.27: Time taken to administer claims referred to the Rent Officer
	Average days taken	Range days
Date claim received to date of referral to Rent Officer	38.3	25 – 59
Date of referral to date of determination by Rent Officer	6.5	5 – 8
Date of determination by Rent Officer to date received by council	1	1
Date received by council to date action taken by council	75.5	5 – 138

Source: BFI analysis

4.217 The average number of days taken from the date the claim was initially received to the day the council processed the claim following the Rent Officer’s determination was 121.3 days. Our analysis showed the cases in our sample had taken between 73 days and 170 days to process. This level of performance is unacceptable. We did not see any locally produced records of the time taken to administer claims referred to The Rent Service and Knowsley Council had not undertaken any analysis of where the delays were within the process to enable comparisons to be made. Cases requiring referral to the Rent Officer should be identified at the outset of the claim and a referral made without delay. In this way payments on account are minimised and potential hardship reduced.

4.218 Knowsley Council had made improvements in the following areas since the April to June 2003 period that we examined during our sampling:

· reported average new claims processing time for July to October 2003 was 34.2 days

· a weekly monitoring report for payments on account had been introduced

· Rent Officer decisions were returned to the IT system pending trays of the originating assessment officer.

4.219 We were unable to assess the impact of this action during the on-site phase of our inspection. However, the steps taken by Knowsley Council in this weak area of Processing of Claims were positive and provided a basis for performance improvement.

4.220 Our new claims sample contained a case that had been referred to The Rent Service incorrectly. This case was received by Knowsley Council on
3 June 2003 and referred to The Rent Service on 5 June 2003. The Rent Service contacted the council on 14 August 2003 and advised that a Rent Officer decision had been made on 21 January 2003 and that this should remain in place for 52 weeks, as there had been no material changes to the accommodation. This action added an unnecessary 72 days to the process.

4.221 We confirmed with Knowsley Council that registered social landlord and Housing Association cases are considered for referral to The Rent Service if the rent is considered unreasonably high for the accommodation or if the customer appeared to be living in accommodation that was considered larger than required. The Rent Officer provides Knowsley Council with monthly indicative rent levels and these were confirmed to be generally higher than the rents being charged by registered social landlords and Housing Associations.

4.222 Knowsley Council told us that agreeing and signing the service level agreement with The Rent Service was imminent and regular meetings with the Rent Officer were to be reintroduced. We also make reference to Knowsley Council’s working relationship with The Rent Service under Processing of Claims – payments on account.

4.223 Identifying cases that are appropriate for referral to the Rent Officer at the outset of the claim ensures that delays in claims processing are minimised and has a positive impact on performance indicators.

Recommendations

We recommend that Knowsley Council:

· ensures a service level agreement with the Rent Officer is signed, dated and in place to start at the beginning of the financial year · ensures that claims appropriate for referral to the Rent Officer are identified at the outset of the claim · takes prompt action to process claims on receipt of Rent Officer decisions · re-instigates quarterly meetings with the Rent Service to facilitate monitoring of the service level agreement · monitors performance against the service level agreement to ensure that cases are being processed within prescribed time limits · provides refresher training and guidance notes to re-enforce the need to identify cases suitable for Rent Officer referral at the outset of a claim.

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