BFI findings
Strategic Management
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Source: BFI inspection assessment
For an explanation about how to read this radar chart see Executive summary.
2.1 Benefits administration has to be set within the much broader context of a local authority’s overall strategies and responsibilities towards, for example, neighbourhood regeneration, alleviating poverty, preventing homelessness, helping people into work and enhancing consumer choice.
The Benefits Service strategic vision
2.2 A statement expressing the Benefits Service strategic vision for the local authority enables Members, managers and staff to have a clear sense of direction, purpose and focus for their work. It also allows the public to understand where the key priorities for the council lie and how these fit into the overall business aims for delivery.
2.3 The London Borough of Lambeth completed a self-assessment for this element of work, and said that it was not at Standard. We agree with this assessment.
2.4 Historically, the council has had a track record as a poor performing authority, which was evidenced during our first inspection. However, with the employment of a new Chief Executive in 2000, at a corporate level the council is now focused on what it wants to achieve and how it will do it. The mission for the council is documented in the Recovery Plan 2004 – 2006. This provides a vision for where the council wants to be in 2008, and says:
Lambeth Council will deliver, directly or indirectly, reliable, efficient and cost-effective, quality public services and provide value for money. It will listen to local people and work with them and its partner agencies to improve the quality of life of everyone living and working in the borough.
2.5 Underpinning this vision, the council has a range of corporate aims including several which will directly improve service delivery, such as:
· radically improving financial management
· improving corporate culture
· investing in new technology and business processes
· paying benefits on time.
2.6 Improving the overall service provided by the council is a recurring theme throughout the strategic aims and reflects the council’s priority, which is to improve service to customers.
2.7 The Corporate Services plan 2004 – 2007, supports the Recovery Plan and provides further high level aims and objectives. This offers another corporate mission statement, which is:
To deliver high quality, customer-focused services that meet the needs of Lambeth residents, council departments and members. To work in partnership to develop a sustainable future for the borough.
2.8 The service has 9 priorities, which all support the idea of continuous improvement throughout the directorate, but are non-specific to the Benefits service.
2.9 Members, senior officers and the Chief Executive are aware of these priorities and the subsequent high level targets and aims and receive regular feedback on progress against them. Although, in light of the failure to improve performance, we would question how effective this approach is.
2.10 The Corporate plan also includes a Benefits service-specific mission statement, which is to:
Provide a polite, reliable and accessible service that ensures everyone entitled to benefit gets the right amount at the right time.
2.11 This vision does provide a statement of intent. However, it does not document either a commitment to providing a service to the level contained in the Performance Standards, or a method by which the vision might be achieved.
2.12 We were pleased to see that the Benefit Investigation team has a policy statement, which reads:
The council will not tolerate fraud by an employee, either against the council or any other external benefit agency or any other local authority. Wherever fraud of any description is uncovered it will be investigated and appropriate disciplinary action is taken.
2.13 At the time of our inspection, the Benefits service did not have a business plan to translate these high level aims and targets into a meaningful operational approach. Although we were told that the Interim Divisional Benefits manager was drafting this plan, it has not been provided. However, the Executive Director did provide a draft Housing Benefit Strategy. This document details the necessary steps that the Benefits service has to take to improve its service.
2.14 The strategy includes the aim:
To transform Lambeth Benefits into a customer focused, efficient and accessible service.
2.15 It also includes 6 themes, which are:
· good customer service
· accurate and quick
· value for money
· tackling poverty
· well managed and motivated staff
· good communication.
2.16 Each theme is underpinned with a vision and service plan objectives. We are pleased to see that this covers many of the areas required to improve the Benefits service. However, it is imperative that this strategy is ratified by Members and underpinned by a formal lower level operational plan immediately.
2.17 The lack of an operational plan means that staff and managers are struggling to understand what is required of them on a daily or weekly basis. In place of a plan, the Interim Divisional Benefits manager regularly implements reactive changes to individual targets and working practices. This approach is creating instability and is not having the required positive effect.
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We recommend that the London Borough of Lambeth: · 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. |
Policy objectives
2.18 Authorities should support the strategic vision with high level policies and clear objectives for the Benefits service. Together these should:
· eliminate the need for senior managers to make recurring or routine decisions
· provide a systematic way of delegating operational decisions in a manner that will sustain consistency of approach and equity of service
· be linked to its high-level strategic and business plans.
2.19 The London Borough of Lambeth completed a self-assessment for this element of work, and said that it was not at Standard. We agree with this assessment. However, the council does have some strategic policies for the delivery of HB and CTB, including:
· a write-off policy
· a prosecution policy, which includes guidance on sanctions
· an anti-fraud strategy, including:
- a whistle blowing policy
- declarations of interest guidance
- a code of ethics
· a debt recovery strategy.
2.20 The corporate Recovery Plan, sets out certain annual targets for the Benefits service. We were pleased to see that they are drawn from the council’s vision and aim to eventually achieve the full range of Performance Standards.
2.21 The required outcomes documented in this plan for the Benefits service, include:
· improving claims processing time and eliminating the backlog through the strategy of clearing a days work in a day
· improving the customer experience by getting claims right the first time
· creating process efficiencies by combining e-government initiatives with the New Ways of Working agenda
· developing partnerships with stakeholders and developing joint service centres.
2.22 These are supported by a range of targets designed to improve performance. However, there is still no evidence that the Benefits service has an infrastructure that is capable of enabling the achievement of these targets or aims.
2.23 Although all plans are reviewed annually and are endorsed by Members, work is still required to bridge the gap between the Recovery Plan, the Housing Benefit Strategy and the current position.
2.24 To be at Standard, the council must draw up detailed plans to implement the Housing Benefit Strategy, then not only monitor progress towards achieving this strategy, but create a contingency plan which can be invoked, should the Benefits service fail to deliver its objectives.
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We recommend that the London Borough of Lambeth:
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Service delivery planning
2.25 Service delivery planning ensures that resources are effectively managed and monitored to deliver service standards and performance targets.
2.26 A service delivery plan for administering HB and CTB translates the council’s vision, policies and objectives into practical ways of providing a service. Effective service delivery plans will allow any changes that are required to improve the HB and CTB service to be managed.
2.27 Plans can only be effective if they are developed, used, monitored and adapted to meet changing circumstances. Managers and staff need to be convinced that the plans are realistic and achievable.
2.28 The London Borough of Lambeth completed a self-assessment for this element of work, and said that it was not at Standard. We agree with this assessment.
2.29 Corporate and service plans for all areas are produced by the council on an annual basis. These include high-level aims and targets, and are published and communicated to key stakeholders and interested parties.
2.30 The Recovery Plan contains Best Value performance indicators, and documents what is required of the Benefits service at a strategic level. We were told that a more specific operational plan would be drafted to fill the gap between the current position and this plan, but to date this has not happened and this is clearly an area of weakness.
2.31 The Corporate Services department produces a monthly Performance Digest listing progress against target for all key targets and projects, including those affecting the Housing Benefit Service. This Digest is considered monthly at departmental Management Team meetings and at the monthly Executive Director Performance Review meeting. This enables progress against targets and deadlines to be monitored and addressed. Housing Benefit targets also feature prominently in the council’s monthly Performance Digest, which is considered by the council’s Strategic Monitoring Board. As the council’s last failing service, the corporate programme office monitors delivery of HB projects, and exception reports are considered monthly by the Strategic Management Board.
2.32 It is vital that operational plans support the service by:
· documenting what is to be achieved, by when
· detailing how this will be achieved
· providing interim milestones and targets, which help monitor progress towards the annual target
· setting formal individual and team targets for all areas involved in delivering HB and CTB.
2.33 We consider that project management is crucial to the effective management of the change process and are pleased to see that the council makes use of change managers to implement and co-ordinate major changes.
2.34 The council does not have a comprehensive business continuity plan which outlines how the Benefits service will respond in the event of a major disruption. Such a plan needs to be developed and communicated effectively to staff. Regular reviews and testing should also be conducted. However, there are information technology arrangements in place that secure the system against failure and these are discussed in the information technology element of this report.
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We recommend that the London Borough of Lambeth:
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Service delivery targets
2.35 Service delivery targets support policy objectives and service standards and give staff a clear view of the desired outcome, and management clear accountability for providing effective and secure administration.
2.36 The London Borough of Lambeth completed a self-assessment for this element of work, and said that it was not at Standard. We agree with this assessment.
2.37 Target setting has been limited to Best Value performance indicators, which have been used to measure high-level performance and achievement across all areas involved in the administration of HB and CTB. We were disappointed to find that formal targets have not been set at an individual level and we discuss this further under Claims Processing, Counter-fraud and Overpayments.
2.38 Acting on the work and advice of the Performance Improvement Action team, clear targets were devised in March 2004, based on an initiative to clear a day’s work in a day. Because the Benefits service has not adhered to this methodology and not set the associated individual and team targets, the levels of on-hand work has stayed consistent and the backlog remains.
2.39 The Benefits service does have informal targets, although they are set on an ad hoc basis by the Interim Divisional Benefits manager and do not enable staff to achieve team and corporate targets. It was clear during discussions that some staff did not understand the changes that were being made or the rationale behind the target setting.
2.40 It is essential to have a level of consistency when setting targets. It is important that all areas involved in the administration of HB and CTB, work together to ensure that all staff are aware of:
· the strategic aims of the council
· Best Value performance indicators
· local team targets
· individual targets.
2.41 Staff need to understand how each of these levels are linked and contribute to the overall achievement of the council’s aims.
2.42 There is also a need to increase awareness of the planning and target setting methodology amongst all staff, especially at Team leader level. Targets set should be specific, measurable, achievable, realistic and time-bound. They should also be reflected in work programmes and job descriptions, which is not currently the case. By doing this, all staff will have a very clear understanding of what they are required to achieve to support the corporate aims and will make them more accountable at all levels.
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We recommend that the London Borough of Lambeth: · 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 · 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. |
Performance monitoring
2.43 Performance monitoring provides assurance to Members and senior officers that HB and CTB administration is effective and secure. It is important that Members and senior officers receive reports on performance against the Benefits Service strategic vision, objectives and plans to make the accountability process clear. Performance monitoring can also encourage a culture of continuous improvement.
2.44 The London Borough of Lambeth completed a self-assessment for this element of work, and said that it was not at Standard. We agree with this assessment.
2.45 The council does collect management information to monitor performance targets, specifically Best Value performance indicators. This information is communicated to all key stakeholders, when it is collated into the monthly Digests, which are produced for each area.
2.46 The total amount of work outstanding in the Benefits service is difficult to calculate because it has been split into 4 categories:
· backlog
· secondary backlog
· pending
· expired pending.
2.47 This makes establishing the overall amount outstanding extremely difficult. The levels of outstanding work are not reducing, but the way the information is presented makes it hard to find the reasons. More concerning is that the Benefits service has multiple priorities and must split staff time to ensure that all types of work are targeted and actioned.
2.48 During the on-site phase of this inspection we found that as the backlog figure declined, the secondary backlog figure increased. This gives an unclear picture as to the actual situation in the Benefits service for staff and stakeholders, as well as adding unnecessary complications for both monitoring and reporting. Consequently, neither staff, managers nor Members have a full understanding of the current position or how they will improve it.
2.49 We were disappointed to find that the Benefit Investigation team produces little information on levels of performance. This means that staff are unaware of the level of performance in their own area, and consequently are unable to report this type of information to their own manager or to stakeholders, senior managers or Members. We discuss this further under Counter-fraud.
2.50
The responsibility for handling
overpayments is split between the Benefits service and the Overpayments team.
We found that a lack of a
co-ordinated approach to monitoring and management checking means that the
Benefits service is missing an opportunity to gather and analyse data that
will assist with improvements. This is discussed further under Overpayments.
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We recommend that the London Borough of Lambeth: · 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. |
Organisational structure
2.51 Organisational structure plays an important part in the performance of a local authority administering HB and CTB. It is important that staff and other resources are structured in a manner that provides an effective Benefits service. Organisational design will obviously be influenced by council-wide policy on issues such as:
· service centralisation or decentralisation
· outsourcing
· the size and geography of the local authority
· the siting of benefits and counter-fraud work within Finance or Housing, or a combination within these or other departments.
2.52 It is important that the organisational structure adopted should not have an adverse impact on the administration of benefits. The Institute of Revenues, Rating and Valuation recommends therefore that the Benefits manager should occupy a senior position within the authority with a direct reporting line to the Section 151 Officer or, in Scotland the Section 95 Officer.
2.53 The London Borough of Lambeth completed a self-assessment for this element of work, and said that it was at Standard. We disagree with this assessment.
2.54 At
the time of our first inspection, the Benefits service was contracted out
to Capita, and was only one of several failing services within the council.
At the time of this inspection, HB administration had been brought back
in-house and the Benefits service was the final failing service in the London
Borough of Lambeth.
2.55 During the interim period, the council has witnessed a range of personnel changes, including the appointment of:
· a Chief Executive in 2000
· a temporary Interim Divisional Benefits manager in late 2003
· an Executive Director of Corporate Services in spring 2004.
2.56 Figure 2.2 shows the senior management organisation chart provided by the council.
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Source: London Borough of Lambeth
2.57 The Benefits service is shown in Figure 2.3. It is part of Corporate Services Directorate, has approximately 189 staff and is divided into 2 main operational teams, based on a public and private sector split.
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Source: London Borough of Lambeth
2.58 The Interim Divisional Benefits manager also has 5 other managers within the team, who are responsible for:
· Special Services, including Appeals, Court liaison and Complaints
· Special Projects (2 managers)
· Customer Services and Administration, which includes Post Opening and the Customer Services desk
· Finance and Contracts, which includes Overpayments and Human Resources
· Training, Policy and Quality.
2.59 The Interim Divisional Benefits manager reports direct to the Executive Director for Corporate Services, who in turn reports to the Chief Executive.
2.60 The structure of the Benefits service is not the most effective way to arrange the business, as many staff are unable to undertake the full range of assessment duties. By splitting the work in this way, the council is missing an opportunity to develop all staff to be able to assess all types of claims. This would then allow the Benefits service to be able to allocate resources to where they are needed most. In our first inspection, we recommended:
…to improve the effectiveness and efficiency of the benefits section, Lambeth:
- defines specific work allocations for staff
- periodically rotates staff responsibilities within the team.
2.61 Although staff in the Benefits service now have specific areas of work, they are not rotated around the different teams within the organisation.
2.62 The Chief Internal Auditor is responsible for internal audit and the Benefit Investigation team. These teams form part of the Finance department and have a different management chain to the Benefits service.
2.63 The Benefit Investigation team organisational structure can be seen at Figure 2.4. The team is managed by the Head of Benefit and Tenancy Fraud and has a deputy manager, 5 investigation officers, 2 visiting officers, an intelligence officer and a finance and administration officer.
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Source: The London Borough of Lambeth
2.64 Internal audit is a small in-house team made up of 5 staff, who report to the Finance Director via the Chief Internal Auditor. This team is supported by XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX who audit the majority of the benefit and fraud activities on an outsourced basis.
2.65 We were disappointed to see that there are no formal communication channels between the Benefits service and the Finance department. Although there are no reported problems with communications at present, it would be good practice to formalise and document any meetings or agreements.
2.66 The HB and CTB organisation structure does not support the effective or secure management of benefits. Although each area has some control over their own work and resources, there is little communication or teamworking across the organisation. This means that resource issues are not prioritised, operational issues are not identified and plans do not encourage joint working. An example of this is between Assessment and Overpayments staff, where no joint monitoring is conducted, meaning that issues and training and development needs are overlooked.
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We recommend that the London Borough of Lambeth:
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Procedural guidance
2.67 HB and CTB are important components of the national benefits system and it is important that staff and managers responsible for their administration are supported and guided by good procedures.
2.68 The London Borough of Lambeth completed a self-assessment of its performance in this element, and concluded that it is not at Standard. We agree with this assessment.
2.69 The council is not at Standard because it does not:
· have processes in place to ensure that practitioners and managers understand benefit delivery procedures
· incorporate
changes into the procedures and documentation within
10 days of their receipt into the council.
2.70 However, the council does have:
· HB and CTB delivery procedures that cover all aspects of the service with which the LA must comply
· delivery procedures that are:
- completely documented in manuals
- available to all Benefits service staff.
2.71 At the time of our on-site visit the council stored procedural guidance on a shared information technology directory. This gives all staff access to the guidance via their desktop workstations.
2.72 We
were pleased to find that this directory contained a wide range of version
controlled procedural manuals and information. The Training, Policy and Quality
team is responsible for developing and managing these documents and also for
incorporating changes. However, in its self-assessment the council stated
it did not incorporate changes within
10 days of receipt.
2.73 In discussions with assessment officers and the Training, Policy and Quality team we were told that the shared directory was unstable and was often not available. We were also told that there is not a user friendly index or search facility within the directory. Consequently assessment officers spend an inordinate amount of time searching for the procedural guidance they require to carry out their duties.
2.74 The Training, Policy and Quality team told us that they were in the process of transferring all of the procedural manuals onto an Intranet based system. This will be more stable than before and will include a search facility making it easier to navigate. We were also told that a procedural guidance icon will be put on every workstation and one-to-one training will be delivered to all staff during the roll-out of this new system.
2.75 Assessment officers told us that they sometimes find the guidance provided in the procedural manuals ambiguous and often have to seek clarification from the Training, Policy and Quality team. Assessment officers suggested that if they are included in discussions before new guidance is issued, then this problem could be resolved.
2.76 To be at Standard the council needs to introduce mechanisms to ensure that delivery procedures are understood by recipients and incorporate changes to procedures and documentation within 10 days of notification by the Department.
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We recommend that the London Borough of Lambeth: · 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. |
Management assurance
2.77 Members and senior managers who are accountable for the delivery of effective and secure HB and CTB administration, need assurance that the Benefits service and counter-fraud efforts are working as planned.
2.78 The London Borough of Lambeth completed a self-assessment of its performance in this element and concluded that it is not at Standard. We agree with this assessment.
2.79 Although errors are returned to staff for correction, Team leaders seem ill equipped to handle the necessary coaching and management functions required of them.
2.80 The Head of Tenancy and Benefit Fraud told us that they conduct regular informal checks on fraud cases. However, we could find no documentary evidence to support this.
2.81 The results of the checks in the Benefits service are submitted to senior managers. However, the lack of formal checking in the Benefit Investigation team does not allow the same information to be collated or publicised about fraud cases.
2.82 Without regular and comprehensive information being produced the council cannot highlight trends or processing deficiencies. We would expect this information to be produced and formalised. Regular reports should then go to senior managers and Members, as a matter of routine.
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We recommend that the London Borough of Lambeth:
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Local management information
2.83 Local management information provides a sound base for managers to evaluate the effectiveness and security of the Benefits system. It is a useful tool for management to make informed decisions on the day-to-day running of their sections and to keep Members informed of performance. It should not be used simply to generate a local authority’s current set of performance indicators.
2.84 The London Borough of Lambeth completed a self-assessment of its performance in this element and concluded that it is not at Standard. We agree with this assessment.
2.85 To reach Standard in this element, the council must develop and use internal HB and CTB management information systems which are reliable, formal, timely and structured. To date, the council has produced high-level management information to primarily fulfil its obligations against the Best Value performance indicators.
2.86 The Benefits service produces management information on a weekly basis, which covers:
· Best Value performance indicators
· workflow, detailing what is received and what has been cleared
· intake and outstanding figures from the document image processing system
· volume and age of cases.
2.87 The council produces this information on a weekly basis for the Benefits service. However, we found little evidence of anything more than a basic understanding of what the information was telling staff about the work position. Although we found evidence that the results were discussed at Management team meetings, we found nothing to demonstrate an awareness of the current work position amongst Team leaders or staff.
2.88 This information is collated to produce the statistical Digests, which go to senior managers and Members on a monthly basis. To supplement this, the Interim Divisional Benefits manager meets with the Executive Director of Corporate Services and the Chief Executive on a weekly basis to discuss progress against targets.
2.89 From discussions with staff and stakeholders at all levels, we were concerned to find a lack of awareness or understanding about the current position or the impact of working practices on claims clearance.
2.90 To date, the council has not been in a position to address areas of low benefit take-up. Although a policy document has been written, little statistical evidence has been gathered or analysed. This is largely due to the fact that the Benefits service needs to concentrate on clearing the backlog and existing claims, rather than pursuing more. However, it is important that the council clears all outstanding work, which will allow it to be able to implement the planned take-up campaign. This will help some of the most vulnerable people within the borough and support the council’s strategic aims.
2.91 During the course of the inspection we found that a range of management information was available but not captured, or captured but not analysed. Figure 2.5 shows the council’s collection and use of management information. We comment further on this in Customer services, Processing of claims, Counter-fraud and Overpayments.
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BFI findings |
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Customer services |
A range of management information is collected to analyse the council’s service to customers. However, much of this is not used effectively to monitor performance or set targets. Telephone queries are monitored in the call centre and are answered within target. Customer waiting time information does not capture the full waiting time and has not been used to inform resources or targets. The Area Housing offices do not follow the same processes as the main customer reception area in Olive Morris House. No management information is collected which could be used to compare performance across the office. Complaints information is collated centrally. Although there has been a marked increase in the length of time taken to process complaints since this team was disbanded, there has been no action taken to analyse or act on this information. Appeals information is gathered, but again the increase in response and resolution times has not been progressed. |
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New claims |
Information is produced on a weekly basis, showing the intake, work outstanding and the age of cases. Although this is circulated to all managers and discussed at a weekly meeting, there is little understanding. Consequently the information is not analysed or used to prioritise work. |
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Visiting |
The visiting officers now form part of the Benefit Investigation team and no information is produced to target welfare visits. |
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Changes of circumstances |
Insufficient management information is produced and no analysis occurs which would allow the Benefits service to prioritise processing in date order. |
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Management checks |
Management checks are carried out within the Benefits service to at least the required 10%. However, these checks should be moved to ensure that they are conducted pre-notification. Errors are returned to staff to amend, but Team leaders require further support to monitor, identify and implement any training or development needs. We were told that the work of the Benefit Investigation team is informally checked. However, as we could find no evidence to support this, the Head of Tenancy and Benefit Fraud must ensure that all checks are documented and evidenced on file. |
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Risk categories |
We were told that no management information is gathered or analysed on risk categories. None are set automatically on the information technology system as the council is not yet Verification Framework compliant. |
Source: BFI analysis
Training and development
2.92 Effective and secure delivery of HB and CTB depends on staff performance. The administration of these benefits is complex, and staff retention and recruitment are major issues for managers. Local authorities should offer effective training, career and personal development opportunities for all staff.
2.93 Investment in the training and development of staff plays a key role in:
· attracting new recruits
· retaining staff
· offering a career path for potential managers
· developing the management skills of more senior staff.
2.94 Investment in performance management can:
· bring greater consistency and fairness to the management of staff
· highlight where individuals need to develop or improve performance
· ensure that career advancement is based on demonstrable delivery of results and competence to take on greater responsibility.
2.95 The London Borough of Lambeth completed a self-assessment for this element of work and reported that it was not at Standard. Although we agree with this assessment we have identified a number of strengths.
2.96 The Benefits service has a Training, Policy and Quality manager and a small team of training and quality staff. This team has responsibility for:
· training programmes
· quality monitoring
· identifying training needs
· updating staff on legislative and policy changes in HB and CTB
· producing procedural guidance documents.
2.97 The manager also has responsibility for the training budget for the Benefits service. This represents a positive response to recommendations made in the first inspection.
2.98 We were pleased to see that the Benefits service has recently achieved Investors in People accreditation and provides both external and internal training for new and existing staff. Corporately, the council provides a training programme for new and aspiring managers through its Positive Action Programme.
2.99 We were pleased to see that the Benefits service has both a formal and informal approach to evaluation and uses this to review and revise its training programmes. All training courses are subject to a formal written evaluation through a two-stage process, once, immediately after completing the training and again, approximately a month later. Staff from the Training team will also attend team meetings to obtain verbal feedback from staff. The evaluation process is subject to a process of constant review and has been identified as an action point in the Training Business Plan Quarterly Return. We are pleased to note that this represents a positive response to recommendations made in the first inspection.
2.100 The council has an appraisal system and all staff have a personal learning and development folder which includes:
· the council's mission statement
· a brief background to the London Borough of Lambeth
· a programme of available training courses
· a personal record of courses attended
· information about the council's appraisal scheme.
2.101 Staff in the Benefits service told us that appraisals are held annually and staff receive additional performance feedback during monthly, one-to-one meetings. The outcomes of these meetings are formally documented and we were pleased to see that the format reflects differences in staff responsibility and grade.
2.102 A formal training needs analysis was undertaken in 2001. Since then training needs have been identified through a number of means, including:
· a process of quality monitoring checks
· one-to-one meetings
· appraisals
· feedback from Appeals and Complaints teams.
2.103 The Complaints and Appeals manager regularly attends meetings with staff from the Training, Policy and Quality team to provide feedback on the common reasons for customers' complaints and appeals. We are pleased to note that this is a positive response to recommendations made in the first inspection.
2.104 All staff have job descriptions which include work, but not personal objectives. Job descriptions also include the key corporate competencies which staff are expected to achieve and adhere to. However, these job descriptions are not reviewed and updated frequently enough, and fail to capture changes that occur if a member of staff alters their role. These job descriptions do not include comprehensive work objectives.
2.105 Specialist HB and CTB technical support training is available to all staff. However, customer reception officers are not trained to the same technical standard as assessors for completing assessments on claims. We were told that consideration has been given to providing customer service officers with this training and to rotate them onto the assessment section. However, it was decided that as they do not carry out assessments on a regular basis it was unlikely that they would retain this knowledge. To counteract this, a small team of benefit assessors work from the reception area and provide specific benefits knowledge. Customer reception staff told us that they have been able to access non-technical training, which has helped them handle customer service issues such as dealing with customers who have poor literacy skills. Fraud awareness training is not provided to all staff on an annual basis and this is an area that the council should address.
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We recommend that the London Borough of Lambeth: · 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. |
Information technology
2.107 Every local authority should make the most of available information technology to support an effective and secure HB and CTB administration, and the technology used should help the local authority make progress against the e-government agenda.
2.108 Automation of processes should improve efficiency, and provide reliable and timely management information to monitor performance and inform management decisions.
2.109 The London Borough of Lambeth assessed itself as not at Standard in this element, and we agree with this assessment.
2.110 The support of the Benefits information technology system is the responsibility of the council’s private sector partner, Capita. The Benefits information technology system in the council supports HB and CTB assessment, administration, payment, accounting and subsidy. The system provides sufficient data to ensure that timely and accurate subsidy returns and management information are submitted to the Department and all other relevant areas. However, we were disappointed to find that Departmental data has had missing or incomplete values for several years. The system also provides a file tracking system, and facilitates the production of reports from its quality database that support the 10% adjudication checks.
2.111 Although the information technology systems provide data to support the production of subsidy claims, the Audit Commission has qualified recent subsidy claims. Additionally, the audit trails of working papers that support subsidy claims have been criticised.
2.112 There has also been a failure to report overpayments information to the Department. We were told that the associated system report has been problematic. This is presently being addressed. A further report had already been produced while we were on-site, and this was undergoing scrutiny by both Capita and the council’s System Support team.
2.113 The debt recovery database, although separate from the Benefits information technology system, is linked to this system. It is used to track the recovery of overpayments. The Benefit Investigation team uses a stand-alone system to manage fraud referrals. Therefore all Benefits staff are fully supported by information technology systems in the council.
2.114 The Benefits information technology system is locally supported by the council’s System Support team, who are responsible for all fault logging. The team’s manager and 3 staff all have super-user access. This access includes the ability to add and remove users and to update claims to benefit. However, no one can remove records from the Benefits information technology system.
2.115 We were told that super-user access does not include the necessary system access to issue payments. This is commendable because it prevents fictitious claims being created and paid to bogus customers. Only the Payments team can create creditors on the system, and in turn, this team can not enter claim details onto the Benefits information technology system.
2.116 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 XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX
2.117 The Benefits information technology system interfaces effectively with most other networked council information technology systems. This includes interfacing with the Rent account system. However, there is no direct interface with the council’s main accounting system and this inhibits automated reconciliation between systems. A project is underway to develop such an interface. This is discussed further in Internal security.
2.118 The
audit trail on the Benefits information technology system is comprehensive,
covering every user intervention. We found that the user
set-up procedures require the completion of a form that identifies the necessary
level of access. This form must be completed and authorised by the user’s
manager. Capita’s Control team in Essex sets up users on the system and provides
the access level recommended by the individual’s manager.
2.119 Passwords are required for both the council’s network, and for the Benefits information technology system. This system prompts the users to change their passwords every 30 days, and the network prompts password changes every 90 days. Users are allocated a user group designed to allow access to the relevant system dialogues. We were told that access is reviewed
when users have a change of duty, or they transfer to another team. Profiles are also reviewed on an annual basis.
2.120 The Benefits information technology system is managed in a controlled technical environment with documented fallback and recovery plans, which are regularly tested. A disaster recovery plan for the restoration of the Benefits information technology system has been produced and was tested in December 2003. This test confirmed that the system could successfully be restored from the back-up tapes in the event of a disaster. However, no business continuity plan is in place to support users in ongoing provision of the benefits function in the event of a disaster.
2.121 The council set up a Business Continuity Plan project in February 2003, and a business continuity framework is now in place. A series of Business Continuity workshops for senior managers have been held. Master business continuity plan templates have been acquired and disaster recovery software has been purchased. It is intended to use these tools to produce a framework for the consistent production of business continuity plans across the council. However, no detailed work has yet been undertaken to produce a business continuity plan for the Benefits service.
2.122
The Benefits information
technology system is tested for integrity on a monthly basis. Capita is responsible
for capacity testing, and they report any problems to the Interim Divisional
Benefits manager. We were told that Benefits information technology systems
are currently running at between
98 and 99% availability. In the event of any system downtime, a full report
is provided for the Interim Divisional Benefits manager.
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We recommend that the London Borough of Lambeth: · 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. |
Internal audit
2.123 Internal audit provides assurance to management and Members about the effectiveness and security of HB and CTB administration.
2.124 The London Borough of Lambeth assessed itself as not at Standard in this element and we agree with this assessment. However, there are some areas of good practice, including:
· a clear programme of work based on a risk register, which is agreed and approved by Members and is a recommended approach of the chartered institute of accountants
· work programmes are devised using formal risk analysis
· audit reports are discussed with appropriate managers and passed to senior managers
· an audit tracker system is in operation, to monitor the progress of recommendations
· internal audit liaises with District Audit to co-ordinate programmes.
2.125 In the first BFI inspection we recommended that the council:
…reconsiders the level of IA activity in HB and CTB and increases activity to take account of the levels of spend and risk it presents.
2.126 The number of audit days spent on the Benefits service, does not correlate to the proportion of the gross revenue expenditure on benefits.
2.127 Figure 2.6 shows the number of internal audit days spent on the Benefits service during 2002/03 and 2003/04. The figures shown for 2004/05 are the number of days internal audit plans to spend on the Benefits service.
|
2002/03 |
2003/04 |
2004/05 (planned) |
|
|
Number of internal audit days allocated to the Benefits service |
25 |
25 |
25 |
|
Number of internal audit days allocated to information technology security |
25 |
0 |
0 |
|
Total number of internal audit days used on HB and CTB administration |
50 |
25 |
25 |
|
Total number of internal audit days available |
1,300 |
1,315 |
1,585 |
|
Percentage of total |
3.84 |
1.9 |
1.58 |
Source: The London Borough of Lambeth
2.128 As Figure 2.6 shows, the percentage of audit days allocated to HB and CTB has decreased since 2002/03, despite an increase in the available number of audit days.
2.129 Although the approach is risk-based and has been approved by District Audit, senior managers and Members, we are disappointed to see such a low number of days being allocated to the Benefits service. This is an area of particular concern, as it is the last remaining failing service within the council.
2.130 In the first inspection, we recommended that internal audit:
…use the findings from this report to target their resources.
2.131 As the number of internal audit days allocated to the Benefits service does not correlate to the amount of benefit paid and because of the ongoing problems within the organisation, this recommendation will remain.
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We recommend that the London Borough of Lambeth: · 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. |
External audit
2.132 External audit has statutory duties to report on the arrangements that the local authority has to secure economy, efficiency and effectiveness in its use of resources. It also gives independent assurance on matters relating to the accounts, and reports on the arrangements to secure propriety.Local authorities must act on this independent advice and assurance, while having their own systems of assurance. They cannot rely on external audit alone to identify faults.
2.133 The external audit function for the London Borough of Lambeth is provided by the Audit Commission in England (District Audit).
2.134 The London Borough of Lambeth assessed itself as at Standard in this element. We disagree with this assessment.
2.135 During discussions with District Audit, we were concerned to find that although the allocation of internal audit days is based on a risk process, District Audit do not scrutinise the methodology or its results, they are content that a process has been used. It is not within the remit of District Audit to challenge the detail of the process.
2.136 In 2003, the subsidy claim was qualified by District Audit, with Benefits service related issues including:
· backdated rent rebates
· overpayments
· backdated rent allowances
· rent allowance overpayments
· extended rent allowance payments.
2.137 We were told that resolution of these issues was at various stages of completion, but that the council does not have a good record of responding positively to recommendations. Consequently the certification process raises the same issues on an annual basis, despite the tracker system. In our first inspection, we recommended that:
…recommendations are implemented within agreed timescales…
therefore it is disappointing to find that audit recommendations continue to remain outstanding.
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We recommend that the London Borough of Lambeth:
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Cost of benefit administration
2.138 There is no definitive costing structure for benefits administration, although local authorities should be guided by the provisions in the Department’s circular S1/2000.
2.139 The London Borough of Lambeth assessed itself as at Standard in this element. We disagree with this assessment.
2.140 The council is not at Standard in this area because it does not calculate costs per claim at regular intervals. Although the council provided some evidence, it was based on an external consultancy report, dated June 2003. This document provided comparable information on cost per claim, comparing Lambeth with 3 other London authorities. However, this information was not based on the criteria set out in the Performance Standards and has not been updated since.
2.141 To reach Standard the council must:
· calculate the cost per claim at regular intervals
· use a costing structure that identifies staff, information technology, stationery and administrative overhead costs
· keep accounting records to show how the calculation is performed on each occasion.
2.142 We were told that this information would be made available before we completed the on-site phase of this inspection. However, to date it has not been provided.
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We recommend that the London Borough of Lambeth: · 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. |
Compliance with the Race Relations Act
2.143 Authorities must comply with the provisions of the Race Relations Act 1976, as amended by the Race Relations (Amendment) Act 2000. Under this legislation authorities are required to have a Race Equality Scheme in place by 31 May 2002. The Race Equality Scheme must cover all aspects of the authority’s business.
2.144 The Race Relations Act 1976 was amended in 2000 to impose a number of duties on all public authorities. Local authorities are required to fulfil:
· the General Duty, to eliminate unlawful discrimination and to promote equality of opportunity and good relations between persons of different racial groups
· the Specific Duty, to publish by 31 May 2002 a race equality scheme that sets out the arrangements they have made to satisfy this general duty
· the Specific Duty as an employer, to provide the tools to ensure that they satisfy the general duty in all aspects of their work.
2.145 The London Borough of Lambeth undertook a self-assessment for this element and reported that it was at Standard and we agree with this assessment.
2.146 The ethnic diversity of the population and HB and CTB customers in the council is shown in Figure 2.7. This information is based on the 2001 census and on information extracted from the Benefits services information technology system. Information regarding the ethnic diversity of an HB or CTB customer is entered onto the information technology system from information provided by the customer. This information is analysed by the Equalities Officer and is used to assess need within the service.
|
Ethnic Group |
As % of the total population of the London Borough of Lambeth 2001 |
As % of HB and CTB customers May 2004 |
|
White |
54 |
43 |
|
Black |
23 |
42 |
|
Asian |
4 |
5 |
|
Mixed |
4 |
6 |
|
Chinese/Other |
15 |
4 |
Source: London Borough of Lambeth
2.147 The Equality and Diversity Unit, which is part of the Office of the Assistant Chief Executive, monitors issues of equality and diversity in the council. This unit provides strategic support to Members and the Chief Executive and supports all departments in delivering the Equalities Agenda. At a department level the council manages equalities through an Equalities Policy Officer. The Benefits service has an identified officer with responsibility for the Equality Policy. This officer is responsible for communicating this to staff and for monitoring and reviewing equalities issues.
2.148 The council reviewed its existing policies as required by the Race Relations Act and complied with the 2002 deadline by having a Race Equality Scheme. This is supported by a timetabled Corporate Action Plan.
2.149 The council undertakes Race Equality Impact Assessments, and has an active programme for reporting and monitoring racial incidents. The Race Equality Scheme and the results of Equality Impact Assessments are published on the council's website and Intranet. However, the results of the Equality Impact Assessments should be communicated to a wider audience. This could be done by utilising the local media, using Public Library outlets and by providing information to local advice agencies and customer representative groups.
2.150 Guidance for staff on Race Equality Impact Assessments is provided on the Intranet and training has been provided to managers on issues of diversity and equality. The Benefit Investigation team has received Equalities and Diversity training. However, a programme for providing this training is in the process of being rolled out to all staff in the Benefits service.
2.151 The level of awareness about the Race Equality Scheme varies amongst the staff. However, we found that they have a high level of awareness of their responsibilities within the Race Relations Act and of the services provided by the council for ethnic minority groups. This awareness also included an acknowledgement and understanding of the diverse cultural needs of ethnic minority groups. The publication of the Equality Impact Assessment for the Benefits service should be used as an opportunity to refresh staff's knowledge of the Race Equality Scheme.
2.152 The council produces a quarterly Equalities Digest which has been developed with the aim of analysing service usage by ethnic groups and identifying current gaps in performance and service delivery. Information from the Equalities Digest is used to raise staff awareness, to enable them to take the necessary action to improve services for different groups in the borough. The Equalities Digest states:
The process that has been followed to collate information and produce the Digest has been used to:
- create awareness within the Council of the significance of having
structures in place for equalities and reporting.
- develop an understanding of how the analysis of equalities data that is collected by the organisation can be used as a tool to improve access to and provision of services to equalities groups.
2.153 To assess the language needs of HB and CTB customers, the Equalities Officer in the Benefits service utilises research undertaken by the Education department of the council. The Education department produces an Annual Pupil Survey, which identifies the range of languages spoken within the council's school population. This has been used to identify the language needs among the HB and CTB customer population. As an example of service provision, staff told us that there has been a recent increase in customers speaking Portuguese, and that action has been taken to provide extra interpreting services for this group.
2.154 The Benefits service has a Race Equality Action Plan which focuses on raising awareness amongst staff, recording ethnicity details on the information technology system and establishing a consultation programme with external partners. The Benefits service has been subject to an Equality Impact Assessment, and we were provided with a draft copy of the assessment. The assessment identified one of the main issues for the Benefits service as:
Ensuring procedures reflect an easily accessible front line service for all sections of the community.
2.155 It is clear that the council has a commitment to ensuring that issues of Equality and Diversity are considered when planning service provision. However, present good practices could be further developed by monitoring the provision of service to landlords from the ethnic community and by having procedures in place for accepting evidence in recognised community languages.
2.156 The council would be above Standard if it monitored the ratio of:
· appeals
· complaints
· successful and unsuccessful HB and CTB claims
by racial group, and ensured that there are no discrepancies between racial groups.
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We recommend that the London Borough of Lambeth:
· ensures all staff in the Benefits service access the training programme Valuing Diversity · uses the publication of the Equality Impact Assessment as an opportunity to update staff about the Race Equality Scheme · monitors its provision of service to landlords from the ethnic community · develops procedures for accepting evidence in recognised community languages · monitors:
and ensures that there are no discrepancies in the results between racial groups. |
Internal working arrangements
2.157 Local authorities need to manage their internal partnerships and relationships to support short and longer term policy objectives. Such management includes ensuring that common goals are set for an effective and secure HB and CTB administration.
2.158 The London Borough of Lambeth undertook a self-assessment for this element and reported that it was not at Standard. We agree with this assessment.
2.159 To be at Standard the council must:
· define the roles and responsibilities of those elsewhere in the organisation who are involved in Benefits administration
· review, and revise where necessary, communication channels between internal stakeholders.
2.160 We were disappointed to find that communications between areas within the Benefits service, such as Assessment and Overpayments staff do not exist on a formal level, and we have already discussed this in Performance monitoring. As part of the council’s work on Internal working arrangements, this should be resolved to improve internal liaison and joint working.
2.161 However, we were pleased to find that a good working relationship exists between the Benefits service and the Housing department. Because of the multiple links between rent income and HB and CTB awards, it is essential that this remains the case. Examples of the positive relationship include:
· a service level agreement that has been formally agreed
· job shadowing
· regular liaison meetings to discuss general issues and provide updates.
2.162 However, the service level agreement has not been formally reviewed since it was ratified in 1996. To be at Standard, this should be done at regular intervals.
2.163 Communications are poor between the Benefits service and the Benefit Investigation team. This is discussed further under Counter-fraud.
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We recommend that the London Borough of Lambeth: · 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. |
External working arrangements
2.164 Local authorities function within their own network of relationships with customers, stakeholders and other bodies in their communities. Effective partnerships with these organisations will provide mutual benefits through savings in administrative costs and benefit expenditure, and reduce the amount of fraud and error. Some stakeholders such as the Rent Service (or The Rent Registration Service in Scotland) and Jobcentre Plus play a key part in handling HB and CTB claims effectively and securely.
2.165 The London Borough of Lambeth undertook a self-assessment for this element and reported that it was not at Standard. We agree with this assessment.
2.166 We were pleased to see that the council has a service level agreement in place with the following key organisations connected with HB and CTB administration:
· The Pension Service
· the Rent Service
· Jobcentre Plus.
2.167 The service level agreements follow national models. However, we were disappointed to find that they have not all been formally monitored or reviewed on an annual basis.
2.168 The Benefits service also has a service level agreement with the Lambeth Housing Association Group, which is the largest group of Registered Social Landlords in the borough. We discuss this further under Working with landlords.
2.169 We were told that the council has other arrangements in place with:
· advice agencies
· the Appeals Agency
· the Ombudsman.
2.170 However, these are not reviewed or monitored on a regular basis, which would be required before the council can be at Standard in this element.
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We recommend that the London Borough of Lambeth: · 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. |
Contractors
2.171 A local authority may choose to outsource aspects of HB and CTB administration through a contractor, and the principles of Best Value requires it at least to consider the potential benefits of doing so. In some ways this may provide a more efficient service, but there is a risk that the contractor provides a service that is ineffective and insecure.
2.172 Under section 134(1) of the Social Security Administration Act 1992, HB is to be:
…funded and administered by the appropriate housing authority or local authority.
2.173 And Section 139(1) of the same Act provides that:
…council tax benefit…is to be administered by the appropriate authority.
2.174 In addition to these provisions within the Act, Housing Benefit Regulation 76(1) and Council Tax Benefit Regulation 66(1) state that:
…any matter to be determined under these regulations shall be determined by the appropriate authority.
2.175 The London Borough of Lambeth undertook a self-assessment for this element and reported that it was at Standard. We disagree with this assessment.
2.176 At the time of our first inspection the Benefits service was contracted out to Capita. Since then the main assessment and post opening functions have been brought back in-house, although the call centre remains under contract to Capita.
2.177 We were pleased to find that a contract exists between the council and Capita, with a named manager responsible for liaison and monitoring arrangements.
2.178 However, we were concerned to find that although the contract contains details of the frequency and type of monitoring that is required, this has not been undertaken to a satisfactory level. This means that assurance cannot be provided over the performance of the call centre and associated customer service targets. This is discussed further under Customer services.