We recommended in our 2001 report that

Lambeth's response

Met

Yes/No/Partial/
Superseded

BFI observation following the inspection in 2004

Strategic management:

Lambeth urgently reviews its current performance monitoring arrangements with Capita to clearly define the standards of performance required by processing staff. To do this it should:

S

Devise and implement procedures to check the validity of the statistical data provided by staff.

Y

To improve liaison at local level, Lambeth holds regular meetings with Balham Benefits Agency, to discuss operational issues, the exchange of information and monitoring of the service level agreement.

From 2001, the Private Sector Manager was responsible for attending regular quarterly meetings with the Benefits Agencies. Service level agreements were developed and signed, although not always renewed at regular annual intervals.

S

To ensure that performance standards are met, Lambeth:

The monitoring of the performance standards has been an area of weakness.

Although quarterly meetings with all the Benefit Agency representatives were attended, no special arrangements have been implemented with local offices.

S

To improve communication with Jobcentre Plus, Lambeth ensures that it:

Private Sector Manager was responsible for this area of work, although meetings with Jobcentre Plus have been sporadic.

S

Lambeth must review its management information needs in respect of liaison work to ensure it has sufficient information to know whether its strategies are working.

Y

Lambeth should review its management information needs in respect of the work carried out by the public liaison teams. The collection and analysis of appropriate data will help the local authority establish the effectiveness of its liaison arrangements and provide wider data on the quality and speed with which claims are being processed.

As stated previously, the provision of management information was completely reviewed in 2001. However, although the work of the Public Liaison team was covered in the weekly statistics, it was felt that the creation of the separate team would promote the concept of ownership and the achievement of agreed performance standards.

P

Lambeth ensure that it, in conjunction with Capita:

Work finished, all access is now in ordered security bands and reviewed quarterly. Guidance on P drive

A consultant was employed to review the system generated information produced from Academy to generate comprehensive management information.
Regular attendance at the Academy User Group ensures that best practice is shared.
On-line guidance is now available.
Audit of the Academy system concluded the system is secure.
Full range of management information is available from Academy. Automated processes for management information as well as manual interventions for specific reports are available.

P

Interviews with relevant parties and review of audit report confirms the systems are secure.

Although the issue of establishing effective segregation of duties has been greatly improved through the introduction of a group-based security structure, there are currently no controls in place to monitor the ongoing appropriateness of this structure or whether the groups to which users are assigned are commensurate with their job.

To ensure a more rigorous contract-monitoring regime, Lambeth:

S

To promote the benefits of staff appraisal and reinforce its commitment to it, Lambeth ensures that Capita management:

S

Capita introduces a formal system of evaluation to determine the effectiveness of the current training activities.

S

To improve line management accountability for training and development proposals for Capita staff, Lambeth should ensure that:

S

Lambeth reconsiders the level of internal audit activity in HB and CTB and increases activity to take account of the levels of spend and risk it presents.

Internal audit activity at Lambeth is determined by a risk assessment model, which included the size of HB/CTB measured in both volume/value terms and other relevant reviews (e.g. PIAT).

Also, the HB/CTB audit is done annually under the Audit Commission’s ‘managed audit’ whereby we have to use their methodology, so that they can rely on the audit work.

N

We can find no evidence that the allocated audit days match the associated benefits spend.

To ensure that recommendations made by internal audit and District Audit are within agreed timescales:

Y

Internal audit and District Audit use the findings from this report to target their resources.

Internal audit and District Auditdo co-ordinate their annual audit planning to avoid duplication and target emerging business risks.

N

There is no evidence that resources are targeted in line with the findings of earlier audits.

Lambeth undertakes further work to improve performance in relation to:

S

To help Capita and Lambeth make informed decisions about the quality and level of the service they offer to customers, Lambeth ensures that Capita:

S

To improve the effectiveness and efficiency of the Benefits section, Lambeth:

The initial reorganisation in 2001 and the reorganisation of procedures arising brought greater productivity and accountability. As the focus of the service has evolved, officers have been given the opportunity to expand their skills databases by working within other areas.

P

Customer services

To improve the quality of service provided to those who visit Olive Morris House, Lambeth ensures that Capita:

The number of staff in the reception area has recently been increased.

P

These became part of the weekly statistics

P

Only measures the waiting time for callers without an appointment.

Although reasons for visits are recorded on the customer record sheet an analysis is still not being done

Y

To improve the quality of service provided to those who contact the call centre, Lambeth ensures that Capita:

Y

Y

Y

Lambeth stops using the shortened renewal claim form immediately as it increases the risk of fraud and error entering the system.

S

Lambeth introduces a single claim form for all types of HB and CTB claims, including renewal claims, thereby ensuring that all relevant information is captured accurately efficiently and as well as fully meeting the requirements of the Verification Framework.

Y

Lambeth ensures that Capita puts in place procedures to control requests for further information and takes the necessary action to record the receipt of all information on the Academy system.

S

To be fully compliant with legal requirements, Lambeth:

Reason codes have been changed and the letters substantially amended.
The notification letters are acknowledged to be substantively compliant with Schedule 6 to the regulations in the BFI draft report.

N

N

P

Y

Y

Lambeth does not inform customers that they are entitled to a written explanation of the decision made.

Although Lambeth informs customers of the need to report changes of circumstances it does not inform customers of the consequences of not reporting changes of circumstances.

To ensure that customers are more aware of the need to report changes, in the longer term, Lambeth adds reminders to remittance notices and uses posters in the public areas of council offices.

Y

To improve the level of information available to customers, stocks of leaflets are made available at in the reception area at Olive Morris House. This will reduce the number of enquiries at reception and improve customer service.

Y

To ensure that staff are trained in the correct procedures to follow on reviews and appeals, Lambeth provides written guidance. This will assist staff and management as it will:

Y

To improve management information, Lambeth records all relevant information in the review process.

Done

P

Management information is collected for complaints and appeals. However, it is not used effectively to manage the workflow.

Lambeth urgently investigates the reasons for delay in review board procedures and takes steps to ensure that timescales detailed in legislation are adhered to.

S

To inform training needs, Lambeth analyses the outcome of first stage reviews and review boards. This could:

The allocated Training and Policy officer regularly attends the Appeals team meetings to identify trends and training needs. These are then fed back into the training plan.

P

The Appeals Manager liases with the Training and Quality team regarding the outcomes and reasons for appeals.

However, around 50% of reconsiderations made by the Appeals team are made in favour of the customers. This implies an un-addressed training need for assessment officers.

The Capita complaints and backlog complaint teams amalgamate to handle all complaints.

S

To measure performance effectively on MPs’ enquiries, Lambeth should:

Y

Y

Y

S

S

Y

S

Y

Y

To identify the training needs of staff more effectively:

Y

Y

Y

Y

Processing claims

Lambeth ensures that Capita:

In addition, to satisfy itself that the backlog of work is being cleared, Lambeth must:

S

To help Lambeth better secure the benefits service a more efficient and controlled filing and case control system must be provided. We recommend that Lambeth ensures that Capita fully implements the proposals for the revised filing system.

S

Lambeth stops using the shortened renewal claim form immediately as it increases the risk of fraud and error entering the system.

S

Lambeth introduces a single claim form for all types of HB and CTB claims, including renewal claims, thereby ensuring that all relevant information is captured accurately efficiently and as well as fully meeting the requirements of the Verification Framework.

Y

Lambeth ensures that Capita puts in place procedures to control requests for further information and takes the necessary action to record the receipt of all information on the Academy system.

S

Corporate Anti-Fraud team refers to the Benefits section details of all cases where residency has been verified.

Superseded following disbanding of Corporate Anti-Fraud team and creation of Lambeth Benefit Investigation team

N

We were told that the outcome of these visits is not always communicated to the Benefits service.

Lambeth reports the outcome of all visits to the Assessment teams

Corporate Anti-Fraud team liaises with Benefits Agency to develop a joint visiting programme and ensure information on visits is exchanged

Lambeth subjects rent rebate cases to the same scrutiny as rent allowance cases

The Housing Department are prevented from influencing the work of the HB section.

Superseded following disbanding of Corporate Anti-Fraud team and creation of Lambeth Benefit Investigation team

No

Y

Liaison with
Counter-Fraud Investigation Service has broken down.

We recommend that Lambeth ensures that Capita improves its verification procedures, and reduces the opportunity for fraud and error to occur, by:

New Verification procedures were drawn up and trained to all staff, including a large number of housing officers. We intend to be Verification Framework visits and reviews modules compliant by
January 2005

We now fully utilise the Remote Access Terminal in checking entitlement.

S

Lambeth ensures that Capita increases the coverage of checks and ensures the checking level does not fall below 10%. Also, it must introduce procedures to ensure checks are recorded and reported and used to determine instances of poor performance and training needs.

S

To comply with the legislation and reduce the opportunity for fraud and error to occur, Lambeth must immediately draw up and implement procedures with Capita to ensure that:

S

Lambeth ensures that Capita urgently reviews its processes to improve processing times as this delay in assessing claims causes hardship to customers. To do this it should:

S

Lambeth should ensure that Capita puts in place procedures, supported by documentary guidance, to refer all cases for payment on account determinations if a full determination has not been made by day 15. Lambeth should also ensure that Capita implements the necessary monitoring arrangements to make sure payments on account do not continue beyond a maximum period of 13 weeks.

S

To improve the quality, consistency and security of the DCI1 process, Lambeth ensures that:

S

Lambeth changes its arrangements for creating and sending Rent Officer referrals so as to ensure each referral is made by them and not by the contractor.

S

To ensure compliance with its statutory responsibilities, Lambeth monitors its performance in dealing with the Rent Officer.

Y

To strengthen its working relationship with the Rent Officer, Lambeth:

Procedures in place

Y

P

P

P

Y

To improve the efficiency of the administration of work involving the Rent Officer, Lambeth:

Y

N

Y

Lambeth ensures that Capita improves controls and management information in respect of renewal claims to ensure that:

S

To ensure that staff comply with legal requirements when setting benefit periods and understand and follow its own policies, Lambeth needs to:

Now superseded by abolition of benefit periods.

S

To ensure that changes of circumstances notifications are processed with the necessary speed and accuracy, Lambeth:

The review in 2001 addressed these issues. Procedures are in place. Quality Team checks undertaken. Implementation of Cave Tab filing system then Document Image Processing enabled assessments without a file to be phased out.

P

Y

Y

S

To ensure that customers are more aware of the need to report changes, in the longer term, Lambeth adds reminders to remittance notices and uses posters in the public areas of council offices.

Y

Working with landlords

Lambeth sets up landlord forums and develops landlord information packs, but initially it must ensure its keeps its list of registered landlords
up-to-date.

Y

To improve liaison with Housing Associations and private landlords, Lambeth works with the Housing Associations and major private landlords to agree the necessary mechanisms and formal working arrangements which:

Y

Lambeth must review its management information needs in respect of liaison work to ensure it has sufficient information to know whether its strategies are working.

Y

Lambeth develops internal management arrangements between the Housing Department and the Benefits section that cover the full range of liaison issues, including:

Y

Y

Y

N

There do not appear to be any performance targets that are met and actively monitored.

Lambeth introduces arrangements that ensure procedures are in place:

Weekly update from Housing information technology system

N

N

N

There are no clear arrangements in place to notify the Benefits section when a property is abandoned.

Lambeth maximises recovery from landlords by:

Y

N

Blameless Tenant recovery is still not undertaken.

Internal security

Lambeth reviews and introduces revised post opening procedures immediately. In particular, Lambeth should ensure that Capita addresses the identified weaknesses as detailed above.

Despite assurances from Capita we found significant weaknesses in the post procedure when this function was taken back in house in May 2004. These have now been addressed

N

A number of weaknesses identified in the first inspection had not been implemented. The post was not opened in a totally secured area which was free from clutter.

Lambeth improves the security of the payment process by:

This has now happened, July 2004

Y

N

No lockers are in place and personal belongings are still brought into the post room.

Lambeth improves the security of the payment process by:

Superseded as cheques production methods and procedures now changed

S

Lambeth improves the security of the payment process by controlling the issue and return of cheques and giros for enveloping and sealing.

S

Lambeth improves the security of the payment process by:

P

All Benefits staff have the facility to amend creditor details, although this triggers a report to the Payment team. Benefits staff cannot create the initial creditor record.

Lambeth improves the security of the payment process by deploying sufficient resources to clear the backlog of returned cheques.

Y

Lambeth improves the security of the payment process by:

N

Y

N

P

XXXX XXXX XXXX XX XXXX XXXX XXXX X XXXX XXXX XXXX XXX XXXX XXXX XXXX X XXXX X

There was no evidence that this is performed monthly. Payment reconciliation remains an issue for Lambeth.

XXXX XXXX XXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX

Uncashed cheques are not always referred to Lambeth Benefit Investigation team.

Lambeth should:

N

N

Although the facility is now available, we observed that locks were taped up. This negates the effectiveness of changing access codes.

The fraud area is insecure.

To help provide assurance as to the integrity of the information technology system and the data held in the system, Lambeth ensures Capita:

N

P

There is no systematic approach when staff contracts terminate was in evidence.

Although this is done, lists are not provided for checking. The council relies upon the user’s manager to arrange this deletion.

To improve the security and integrity of the benefit system, Lambeth monitors the recruitment activity of the contractor to ensure that:

S






Y

Y

Y

Lambeth urgently:

Y

Y

N

Dependent upon integrity of staff rather than management checks.

Counter-fraud

To improve the reporting of fraud, Lambeth ensures that Capita:

I am in contact with the call centre by e-mail and by phone. I have provided guidance to them on how to make referrals to fraud for investigation and also referrals for welfare visits to the visiting officers. I have provided guidance notes so that they are clear with Lambeth Benefit Investigation team procedures so that they can effectively field enquiries, in particular where claims are suspended or it is noted on Academy notes that an investigation is underway.

In my experience I am not aware that call centres provide any significant referrals by way of quantity or quality. Lambeth is participating in a London wide benchmarking exercise. If there is evidence that call centres elsewhere are a source of effective referrals then I shall review my stance.

P

Although procedures and a referral process are in place, little fraud awareness training is undertaken. Feedback is also sporadic.

Lambeth introduces arrangements that ensure procedures are in place:

A tenancy fraud team (Lambeth Housing Investigation team) has been set up. They work closely with Lambeth Benefit Investigation team and have carried out joint prosecutions.

The two visiting officers report back any discrepancies found.

INCASE manages investigations and recommendations to HB dept are always followed up.

Y

Y

Y

Lambeth:

The revised Verification Framework and Security Against Fraud and Error have superseded this.

Verification Framework will be adopted in 2004/05

Superseded by revised Security Against Fraud and Error

S

Lambeth reviews the requirements of the fraud case management system.

S

Lambeth reinstates frequent and regular fraud awareness sessions for all of Capita’s benefits staff.

N

Not yet

Lambeth improves the effectiveness of fraud publicity and the hotline by:

Not cost effective

As above

See current report

See current report

N


N

N

Y

N

N

No posters in evidence.

Referral forms are available but fraud awareness not yet done.

No monitoring is performed.

Lambeth obtains better quality referrals from the Benefits section by:

The decision to place Lambeth Benefit Investigation team within Finance was made by Finance Debt Management team in 2002

N

Y

N

Not yet.

Benefit Investigation team is located on a different floor, and temporarily located outside of Olive Morris House.

Referrals logged on INCASE - FACTS no longer used

INCASE is a modern fraud management system with a robust audit trail. It does away with the requirement to maintain paper files in all cases. Paper files are used mainly to store evidence gathered in the course of investigations and of course for prosecution and sanction cases

N

N

Y

P

Y

N

The facility is available but is not used.

Feedback is sporadic.

Fraud files are created for all referrals that are accepted for investigation.

Evidence of analysis is not available.

Lambeth:

This would be automatically captured as a referral source if there were any. ‘Do Not Redirect’ is a poor source of referrals. Although this does produce results in some areas, in many others it certainly does not. The volume and value of referrals from this source is insignificant in the extreme, compared to other areas of
counter-fraud activity.

N

N

N

This is not an HB issue. HB staff have been instructed not to refer ‘Do Not Redirect’ referrals.

This is not done.

It is recorded but is not monitored.

To improve the speed of investigations, Lambeth ensures that:

Again replaced by Performance Standards

Y

P

Although we were informed that reviews take place, they are not documented.

To improve the quality of management information, fraud managers should check investigation officers’ notebooks at regular intervals. This information can be used to inform on the effectiveness of its fraud investigation teams.

Notebooks are not used by Lambeth Benefit Investigation team. INCASE is used to record activity

N

No notebooks are in use.

To ensure the validity of non residency or ‘gone away’ Weekly Benefit Saving claims and to ensure that fraudulent overpayments are fully identified, Lambeth:

No longer relevant

N/A

Y

Y

Not relevant.

To improve the quality of fraud investigation techniques:

N

N

Training investigators are very experienced.

No documented management checks are in place.

Lambeth ensures that Weekly Benefit Saving claims are valid by:

N

No documented management checks are in place.

To improve the effectiveness of Lambeth’s fraud visiting programme:

Visiting Team disbanded with Corporate
Anti-Fraud team

N

These recommendations are not met. While we accept the team was disbanded, the recommendations are still relevant to fraud visiting officers.

To improve the effectiveness of management checks on fraud work, Corporate
Anti-Fraud team:

N

N

N

N

N

No documented checks.

No documented checks.

Not yet.

Not yet.

Closures are not authorised.

Y

Y

Lambeth develops a new counter-fraud strategy making reference to BFI’s Good Practice Guide, taking into account the changes within Corporate Anti-Fraud team, the changes in reporting lines and the new decision-making structure

the strategy:

Y

Y

Y


Y

Training and Policy will set up through invitation to Lambeth Benefit Investigation team at least
6 monthly refresher course on awareness in line with the Verification Framework

N

N

N

N

Y

Planned but not yet.

Liaison with
Counter-Fraud Investigation Service has broken down.

See above.

Lambeth, as a senior partner in counter-fraud initiatives with external bodies, invites Benefits Agency/Benefit Fraud Investigation Service and Benefits Agency Security Investigation Service to take part, to widen the representation and effectiveness of these bodies.

See response to current draft report. But also note that Benefits Agency Security Investigation Service no longer exists and that Howell opinion has limited the amount of joint working that is feasible.

N

No close working with Counter-Fraud Investigation Service.

Lambeth reviews its current various counter-fraud statements and business plans and formulates one coherent policy.

Y

Overpayments

Lambeth should withhold benefit while awaiting further information; either to confirm residency or that the tenant is no longer resident. This will ensure that HB is paid in accordance with legal requirements and minimise overpayments for which no subsidy is payable.

Visits undertaken for large value first payments

N

Lambeth does not withhold benefit while checks are carried out to confirm residency.

All recovery action should sit with one team to prevent duplication of effort.

Y

Lambeth reviews its current policy and procedures documentation to ensure that the various sources of documentation are brought together. There should be one up-to-date reference source covering:

Y

Y

Y

Y

P

The policy and procedures manual being written will detail guidance on when to recover a recoverable overpayment.

Lambeth thoroughly reviews the circumstances of each overpayment and ensures that the correct classification and periods of the overpayment are applied.

N

Overpayments are not thoroughly reviewed to ensure correct classification and periods of overpayment.

Y


Y

Y


Y

Lambeth provides guidance for staff to help them decide the best person to recover overpaid HB from.

Y

As a matter of urgency Lambeth develops a training plan to:

Y

Y

Y

Lambeth carries out an assessment of the suitability for recovery of all outstanding debts, where no recovery is currently taking place. Where recovery is likely to be possible Lambeth should reissue a notice of determination compliant with Schedule 6 and begin recovery action. This should form part of a rolling programme that will eventually assess the suitability of all debt for recovery and also guarantee that the legal basis for the recovery of these debts is sound.

Y

.

Y

N

N

The information technology system does not automatically update all recovery rates each time they are changed. Assessors have to do it manually when they encounter an out of date rate.

There is no management check undertaken to check that rates have been updated.

Lambeth formalises liaison arrangements by ensuring that:

The council has a corporate debt forum and monthly details of our debt are feed into this.

Work still ongoing

N

N

N

There are no formal links with other sections of the local authority to facilitate unilateral debt recovery.

Y

Y

Y

Lambeth maximises recovery from landlords by:

Y

N

Recovery under section 75(5)(b) does not take place.

Process was unsuccessful due to Department for Work and Pensions. Now being restarted

Y

Y

N

Y

Y

Lambeth does not recover from landlords under section 75(5) of the Social Security Administration Act 1992.

Lambeth explores the possibility of using debt collection agencies where all other means to trace and recover debt have failed.

Still under review due to the quality of information held on old debt. We have approached agencies and discussed but until the data base is cleared we can not support some of the debt with documentary evidence

N

No debt collection agencies have been used, although the council has said it will be looking at this recovery method.

Lambeth sets up procedures to make use of the powers provided under HB regulation 105 and CTB regulation 91.

This process was some what hindered by Department for Work and Pensions responses. With only a 1.5% success rate of trace and a 0% success of getting money as we were so far down a list of debtors. Now restarted with new initiative from Department for Work and Pensions

N

This recommendation has not been implemented. The council makes limited use of these powers.

Lambeth puts in place procedures to allow it to make use of section (75)(7) of the Social Security Administration Act 1992.

Y

As a matter of urgency Lambeth develops its procedures for taking debtors to court making full use of all available legislative powers.

Y

This is under review in the current report

Y

N

N

N

Authorised signatories are not reviewed regularly to take account of changes in staff and written-off debts are not part of the management checking regime.

During the inspection, there were moves to change procedures so that smaller write-offs can be authorised by officers other than senior staff.

Lambeth enhances its current management information to report on all aspects of the overpayment process as detailed in this report.

P

Management information covers all aspects of overpayments, although it is confusing and in many cases, irrelevant.

Lambeth reviews its current target-setting regime to ensure that it incorporates, as a minimum, those targets we have outlined in this report.

Y

Lambeth introduces a series of management checks at a minimum of 10%.

N

There are no formal management checks undertaken on the overpayments process.

The Council Wide Debt Forum observes the progress of the management of HB recovery by monitoring:

N

N

N

Although there are monthly reports on progress against targets and work in progress, there has been no plan to address the issues in the first report.