Appendix A: Summary of recommendations
The tables in this appendix show all the recommendations we have made under the 7 areas of Performance Standards.
Strategic management
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We recommend that the London Borough of Lambeth: |
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· drafts a vision for the Benefits service that includes a commitment to service delivery, encompassing all areas recommended in the Performance Standards · amends its vision for the Benefit Investigations team, to include a commitment to service delivery that complies with the standards set out in the Performance Standards · agrees and implements the Housing Benefit Strategy, as a priority. |
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· develops and introduces service-specific performance measures and targets across the range of council policy objectives that are specific, measurable, achievable, realistic and time-bound |
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· ensures that staff understand what is expected of them, by making better use of job descriptions to promote and monitor local targets for all areas · communicates all targets and reports results to key stakeholders. |
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· simplifies the classification of work within the Benefits service, to facilitate monitoring and reporting · ensures that clear, accurate, relevant performance management information is provided to Members and other interested stakeholders · provides training to senior managers and Members in key benefits issues to facilitate the challenge process necessary to drive performance to attain the Performance Standards. |
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· trains and develops
all assessment staff to the same level, and uses this additional flexibility
to target problem areas, such as the backlog
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· introduces processes to ensure that all staff understand the guidance provided and the procedural manuals are not ambiguous · converts the existing information technology directory of procedural guidance to an Intranet tool as planned as soon as possible · ensures that all changes are incorporated into procedures and documentation within 10 days of notification by the Department. |
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· provides Team leaders with the necessary skills to coach staff and take any further management action as required. |
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· updates and reviews job descriptions to reflect any changes in roles and responsibilities · develops up-to-date work objectives for all staff which take into account all aspects of performance, which are specific, measurable, achievable, realistic and time-bound · expands the specialist and technical training that is available for customer reception officers to enable them to deal with customer enquiries · ensures that all staff have annual fraud awareness training to help them identify potential fraud and make appropriate referrals to the Lambeth Benefit Investigation team · ensures that the planning of training specifically takes into account the avoidance of backlogs. |
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· ensures audit trails are produced and scrutinised for all users, including those with super-user access, at random · initiates a regular review of user access levels · produces a business continuity plan specifically for the Benefits service. |
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· ensures that internal audit includes an assessment against Performance Standards as a permanent item in the rolling audit programme. · reconsiders the number of internal audit days allocated to the Benefits service, to take into account an increase in work that assessment against the Performance Standards requires. |
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· implements District Audit recommendations, to address weaknesses in completing annual subsidy, and HB and CTB grant claims
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· requests that District Audit scrutinise the risk based methodology used by internal audit, on an annual basis. |
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· calculates the cost of HB and CTB claims on at least an annual basis · adopts Departmental guidance on calculating costs · reports cost per claim information to Members and senior managers. |
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· develops procedures for accepting evidence in recognised community languages
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· defines the roles and responsibilities of those elsewhere in the organisation who are involved in HB and CTB administration · specifies and formalises the internal communication channels to be used between parties within the council · reviews the effectiveness of all existing communication channels and makes changes where necessary · formally reviews the existing service level agreement between the Benefits service and the Housing department on an annual basis. |
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· puts in place formal performance monitoring and reporting procedures with all organisations where a service level agreement exists or is to be introduced · maintains regular documented contact with other external organisations where formal agreements have not yet been established. |
Customer services
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We recommend that the London Borough of Lambeth: |
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· ensures Registered Social Landlords obtain a regular, controlled supply of claim forms and, in consultation with the landlords, reviews its current procedure of supplying and monitoring claim forms to Registered Social Landlords · 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 |
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· monitors the call centre, as specified in its contract, with Capita and produces 3 quality audit reports in any 12 month period · monitors customer waiting times at the counter more effectively and analyses the results · uses the information about the reasons why customers visit the main customer reception, to improve service delivery and to reduce the number of callers · increases the target of the number of customers to be seen by customer service officers in a day, so that it matches the daily average number of customers visiting the main customer reception · improves the display of posters and leaflets so that they are more visible and accessible to customers · ensures
that posters informing the public about the council's · introduces a formal queuing system for customers, following the rationalisation of the Neighbourhood Housing Offices · monitors the number of letters that are replied to within the target time of 10 days, and specifies whether the target of 10 working days relates to a substantive or holding response · provides a consistent over-the-counter verification and receipt service at all enquiry points/reception areas · 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 XXX · monitors how quickly staff are able to access the relevant information when handling a customer enquiry |
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· ensures that the wording in its decision letters comply with Schedule 6 of the Housing Benefit (General) Regulations 1987 and the similar provision in the Council Tax Benefit (General) Regulations 1992 by informing customers of their right to a written explanation of the decision · works towards obtaining a plain English award for its decision letters · continues to work with local advice agencies in the development of its new decision letters · ensures all decision letters and forms undergo a legal quality assurance check · puts procedures in place which ensures multiple letters are amalgamated into one. |
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· reviews its opening hours for in-work customers · monitors that systems are working, to act on information received from Jobcentre Plus to make extended payments and fast-track claims. |
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· ensures that the Benefits service monitors its performance on complaints acknowledged within the target of 3 working days · ensures assessment officers have training to help them process complaints efficiently · continues to review and monitor the new process for handling complaints, ensuring that it does not have an adverse impact on the total backlog of outstanding complaints · recommences the monitoring of complaints by type, so that the service can take effective action to address and reduce the causes of complaints. |
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· sets a target for the implementation of decisions made by the Appeals Tribunal and monitors performance against this target · maintains the presence of a dedicated Appeals team that focuses on the processing of appeal submissions · ensures that management information is used to effectively manage the workflow, reduces delays in submitting appeals to the Appeals Tribunal · reviews the staffing resources allocated to the Appeals team and makes any necessary increases · ensures that the outcomes of appeals assessments are used to effectively inform assessors' training needs |
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end-to-end clearance. Performance against targets should be monitored, and reported though the management chain and used to improve the speed of processing appeal cases
and be subjected to a legal review prior to issue |
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Processing of claims
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We recommend that the London Borough of Lambeth: |
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· introduces procedures to identify cases where payments on account are required · ensures that payments on account are made in accordance with the Housing Benefit (General) Regulations 1987 · resolves any outstanding information technology issues that prevent payments on account being made on the authority’s information technology system and ensures that assessment staff are provided with updated procedural guidance on how to make payments on account correctly · produces a weekly report to monitor progress of cases where payments on account have been made and, where a payment on account has been running for more than 4 weeks, refers for further action. |
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· ensures that all cases are correctly classified on the Benefits information technology system. |
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· ratifies
its draft procedures and urgently implements its proposed plans
for increased Housing Benefit Matching Service · sets up a monitoring process to ensure that the requisite number of interventions are carried out. |
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· accepts only original documents to substantiate all elements of a claim · ensures all staff, particularly those who accept documents at first point of contact, are trained in the latest evidence requirements, including the use of ultraviolet scanners and identifying false documents · ensures that all photocopied original documentation is clearly stamped and certified as such and that the record includes the identity of the appropriately trained officer who has accepted the document and the date on which it was accepted · ensures that crosschecking is applied consistently and that all actions taken as a result of identifying discrepancies are recorded · updates current local verification procedures to include the above recommendations, in lieu of formal Verification Framework compliance · utilises management checking and introduces measures to ensure that all staff apply all aspects of verification guidance consistently. |
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· ensures that all residency crosschecks are recorded on the Benefits service information technology system · introduces closer liaison and more effective use of visiting officers to confirm residency. |
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· ensures that Remote Access Terminal checks are carried out in all appropriate cases · ensures that, in cases where there has been a break in previous entitlement, a current Remote Access Terminal check is carried out. |
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· ensures that capital and income is fully verified in all appropriate cases · ensures that all assessment officers are consistently applying verification guidance for capital and income. |
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· ensures that at least 10% of quality checks are carried out before the decision is notified to the customer · ensures that the Quality team clearly details reasons for errors returned to improve understanding · introduces closer working and improves the relationship between the Public and Private assessment teams and the Quality team · ensures that the Quality team, Benefits managers and team leaders introduce processes to monitor accuracy statistics and ensure continuous improvement · ensures that the appropriate number of post-decision management checks are continued to be carried out and reported promptly to the Department in line with Best Value requirements. |
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· ensures the service level agreement is set up promptly · liaises with The Pension Service to discuss the assessed income figure issue that is causing processing problems. |
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· makes better use of data available from the Benefits service information technology systems to record and analyse performance · analyses current postal processes for making referrals and considers alternatives, including the electronic interface, to improve delays in transit |
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· urgently agrees the 2004/05 service level agreement · works with the Rent Service to introduce formal monitoring processes, ensuring that targets within the service level agreement are continuously met. |
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Working with landlords
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We recommend that the London Borough of Lambeth: |
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· produces a Landlord Information Pack and issues it to all Registered Social Landlords, regardless of the number of properties controlled · writes at least once a year to all landlords giving up-to-date information on landlords’ responsibilities, encouraging them to co operate to prevent overpayments and fraud and setting out Lambeth’s policies of co-operation · issues an up-to-date Benefits contact list to all Registered Social Landlords. |
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· encourages landlords to make direct contact before taking court action by issuing written guidance to them, which could be included in the proposed landlord information pack · formalises guidance for staff on prioritising and dealing with potential eviction cases. |
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· provides detailed guidance to all landlords on minimising overpayments and on the council’s recovery policy. This should be included in the pack that is being drafted and issued to all landlords · makes interim arrangements to ensure all landlords are aware of overpayments and recovery policy until the draft is ready for issue · utilises Section 75(5) and (6) of the Social Security Administration Act 1992 and starts to recover overpaid benefit paid to landlords in respect of third party tenants. |
Internal security
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We recommend that the London Borough of Lambeth: |
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· ensures that a senior manager checks the recording and handling of valuables, and that all management checks that are undertaken are:
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· prevents access to records held on its Benefits system that relate to declarations of interest made by staff. |
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· ensures that the number of days allocated to the HB service reflects the size of the benefit payments made · arranges for internal audit to provide assurance about the security of payments by undertaking a formal review of the payment and reconciliation arrangements |
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· reviews its document imaging process to identify efficiencies that minimise delays and reduce backlogs in this area · gives training to staff responsible for scanning documents, to enable them to identify false documentation · produces and implements a document retention policy as a matter of urgency. |
Counter-fraud
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We recommend that the London Borough of Lambeth: |
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· revises its Prosecution policy to include guidance on the sum of potential or actual financial loss appropriate to the different sanctions · publicises its Anti-fraud Strategy to all council staff · reviews its procedural guidance to ensure it covers all aspects of investigation work · ensures procedural guidance enables new recruits to work effectively · includes targets for sanctions in its counter-fraud business plan. |
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· extends fraud awareness training to council staff employed outside of the Benefits service · enhances the fraud referral form to include all relevant information · ensures full and detailed procedural guidance is made available to all council staff, including call centre staff · ensures all relevant information is requested on the fraud referral form · produces a referral form for use by landlords and Housing Associations · produces anti-fraud posters that display the telephone number for use outside of office hours, and displays them at all customer outlet points · monitors hotline referrals for effectiveness · records the source and fraud type of referrals accurately to inform risk analysis, ensuring Council Tax and Housing Benefit staff referrals are separately recorded · provides feedback about referrals that fully explains the risk assessment process to all council staff, encouraging them to make more referrals · makes better use of all available management information · sets up a record on the fraud management system for all fraud referrals, and records reasons for closure in all cases · records the feedback given to the originators of referrals on fraud files and on the fraud management system, in all appropriate cases. |
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· actions its Housing Benefit Matching Service matches promptly · considers matching against other internal records. |
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· makes full use of the ‘Do Not Redirect’ scheme · identifies its Royal Mail contact point and liaises effectively with them · invites fraud referrals from staff involved in the ‘Do Not Redirect’ process. |
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· produces procedural guidance that describes the authorisation of officers and the monitoring and execution of their role · reviews its authorised officers to ensure this authorisation is necessary in their present duties. |
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· monitors performance against targets for sifting and starting investigations · raises a separate fraud file for each individual under investigation · ensures activity logs are completed at every stage in the investigation · sets up a separate fraud file for every alleged offender under investigation · ensures delays in investigation are reflected in recommended overpayment classifications. |
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· introduces a regime of management checking that is fully described in procedures · fully documents all management checks · reconsiders the practice of referring all living together investigations to the Department, to enable investigators to build up expertise in this area · introduces key review stages and fully documents all case direction on activity logs · ensures all closure sheets are authorised by team management · makes full use of all available management information · ensures all fraud files are stored securely, and introduces a clear desk policy · urgently reviews current storage of fraud files to ensure all files are accessible to investigators. |
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· ensures the Counter-Fraud Investigation Service is informed of all ongoing investigations being undertaken by the council · resumes liaison and monitoring arrangements regarding the Joint Working Partnership Agreement urgently. |
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· considers offering a caution in all cases that meet with its sanctions criteria · asks its Legal department whether cases intended for caution meet the evidential test for prosecutions. |
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· offers an administrative penalty to all those who satisfy its relevant sanction criteria. |
Overpayments
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We recommend that the London Borough of Lambeth: |
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· simplifies monthly statistical returns · designs and instigates official overpayments training course. |
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· ensures that at least 80% of changes of circumstances that result in a reduction or cessation of benefit are processed before the first payday following the date sufficient information is received · introduces procedures to ensure that such changes that have not been processed after 7 days are given priority and reasons for delay established. |
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· takes
steps to ensure that overpayments are calculated within · identifies
overpayment calculations that take longer than · introduces management checks to ensure that staff are correctly applying underlying entitlement provisions · prevents the issue of recently produced HB cheques, still held by the authority, where their encashment will result in a further overpayment. |
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· urgently introduces management checks to provide assurance that overpayments are classified correctly, using training where necessary · collects and uses details of classification categories, so that it has more meaningful management information to gain insight into the levels of fraud and error and the underlying causes · introduces a more stringent checking regime covering all aspects of overpayments. |
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· ensures that staff are aware that they should record reasons for decisions on whether or not to recover overpayments in every case, through training where necessary · introduces a check of decisions on recoverability into its management checking regime. |
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· amends its decision notices to inform customers that they may request a written explanation · ensures that decision notices are sent to all customers after a decision on the overpayment has been made. |
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· ensures all overpayment cases, where relevant, have the appropriate standard rate deduction applied through the relevant information technology update · routinely and regularly analyses the reports produced on the status of all HB overpayments · establishes all overpayments classified as fraud and takes immediate action to instigate recovery as a priority · introduces Blameless Tenant Recovery for all landlords and communicates its intentions to them · considers using debt collection agencies · introduces and regularly reports on the amount of benefits debt recovered by the different methods used. |
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· reviews the levels of write-off authorisation · ensures that debt is written off only in appropriate cases · engages extra resources to look solely at write-offs · improves processes to ensure the resurrection of a written-off debt when a further claim to benefit is made. |

