Resource management
4.1 Benefit administration, including counter-fraud activity, has to be set within the broader context of a local authority’s overall strategies and responsibilities. Members, managers and staff should therefore have a clear sense of direction, purpose and focus for their work. Members and senior officers should also have assurance that HB and CTB administration is effective and secure.
4.2 The council met 12 of the 16 relevant enablers for Resource management.
Managing the Benefits service
4.3 Broadland District Council met all 3 enablers.
4.4 The Best Value Performance Plan 2006/07 and Annual Report 2005/06 included a priority to introduce benefit visiting to support homeless clients in temporary accommodation to assist them in maintaining their tenancies and:
- provided a baseline of performance against local and national targets
- set targets against these measures for the next 3 years
- set out the council’s priorities for improvement in 2006/07.
4.5 This plan was supported by the Revenues Services Performance Management Service Improvement Plan 2007/08, which detailed its service vision and documented its achievements in 2006/07. It also set priorities for 2007/08, which included:
to continue to improve the speed of processing and payment of benefit claims, changes of circumstances and also improve levels of accuracy… to continue to reduce levels of fraud in the system by investigating all potential fraud and taking appropriate sanctions as defined within the fraud prosecution policy… to provide regular benefit and fraud training to all staff.
4.6 In addition, the council had a number of targets relating to customer service, including:
- answering telephone calls within 9 seconds
- responding to written correspondence within 10 working days
- dealing with 100% of personal callers within 15 minutes.
4.7 Benefits performance information was recorded on a Corporate Performance Information Database and provided monthly to the Overview and Scrutiny Panel for review. A monthly Benefit Status Report was also circulated at the Cabinet briefing meeting.
4.8 The council was focused on improving in all areas and proactively monitored performance to ensure it continued to achieve its targets. In addition the Best Value Performance Plan 2006/07 and Annual Report 2005/06 detailed the council’s commitment to year on year improvement.
4.9 At an operational level, the Revenues Monthly Quality Meeting between the Head of Revenues, the Benefits Manager and team leaders ensured that day-to-day performance issues were raised and addressed quickly.
4.10 We reported under Security that the council’s Counter-fraud Business Plan was inadequate. It was therefore unable to provide assurance to elected Members on the quality of its investigation work.
4.11 The council had a corporate Business Continuity Plan, which included the Benefits service as a high priority due to its legislative obligations. There were emergency plans to provide alternative accommodation for staff to work from in the event of an emergency or disaster. Staff were aware of these plans.
4.12 The Benefits IT system was backed up daily by its service provider and back-up tapes were stored remotely to minimise any potential loss of work. Tests had been carried out to confirm that the system could be fully restored from the back-up tapes.
Monitoring performance
4.13 Broadland District Council met one (E54) of the 2 enablers.
4.14 Senior officers told us they met monthly to discuss progress against corporate priorities and performance against the Best Value Performance Plan 2006/07 and Annual Report 2005/06. We were told that any failure to meet targets was taken seriously. Service managers were required to explain reasons for deterioration in performance to Members and senior officers and to advise what actions would be taken to address performance.
4.15 The council provided timely data returns to the Department, reporting on Performance measures, management information and the Housing Benefits Matching Service.
4.16 Management information was collected and analysed to monitor the throughput of new claims and changes of circumstances taking over 21 and 9 days respectively. Although these arrangements challenged poor performance we report under Internal control mechanisms that the council needed to increase its checking of Performance measure data to validate its accuracy prior to submission to the Department.
4.17 Although Broadland District Council completed a self-assessment against Performance Standards, we had concerns regarding the reliability of its scoring. During our inspection we examined 42 enablers and found that the council met 19. The council’s self-assessment reported that it met 39.
4.18 We had a number of concerns regarding the council’s new claims returns. In our sample of 30 new claims we found 6 cases where the council had refused the claim because the customer had failed to provide all relevant information within a calendar month from the date of first contact.
4.19 If an incomplete claim was received Broadland District Council’s staff took the following action:
- if the claim was looked at after one calendar month had expired it was determined as nil entitlement
- if the claim was looked at within one calendar month, further information was requested from the customer but the time allowed for the customer to respond was restricted to one calendar month from the date of first contact by the customer.
4.20 In the second scenario the claim was determined as nil entitlement if the customer failed to complete the claim by the given date without the customer having had a full calendar month to provide the additional information.
4.21 Determining a claim without giving the customer adequate time to respond distorts performance figures. Although the council advised the customer what was still outstanding and allowed the customer a further calendar month to request a review or appeal, this failed to meet legal requirements and represented poor customer service. We noted that in 3 of the 6 cases where an early nil determination was sent, the customer did not pursue their claim. See recommendation 7.
4.22 The council told us that it had implemented this process following a visit to a Beacon Council, where it was considered good practice. We also found that a number of other councils in the area were following the same process. As a result we asked the Department to provide clear guidance on this area and a circular was issued in June 2007.
4.23 We found that in 2 of the 3 cases in our sample where the customer pursued the claim, the council treated the request for review as a new claim. We also found that the date of claim had been incorrectly recorded in 2 of the new claims in our sample. These findings indicated that new claims statistics were overstated and raised further concerns regarding the accuracy of reported performance. See recommendation 8.
Providing for a skilled and competent workforce
4.24 Broadland District Council met neither of the enablers.
4.25 The council had corporate policies and procedures covering recruitment, induction, training and appraisal.
4.26 Pre-appointment checks were carried out by the Personnel Department, for all new staff. These included verifying the applicants’ employment details for the previous 5 years and also taking up references from the most recent employer.
4.27 Staff were not asked to complete a declaration of interest form on appointment, or annually, even if they had no interests to declare. Where a declaration of interest was made, this was not reviewed.
4.28 While there was a clear corporate commitment to providing relevant training for all council staff, there was no structured training programme for Benefits staff. Training for new Benefits staff was adapted to meet their individual needs and previous experience levels. Our interviews established that some customer services staff providing benefits advice in the council’s information centres or the Mobile Information Centre had not received training on benefits administration.
4.29 The need for ongoing training for Benefits staff was identified as part of the appraisal process. Information regarding training requests and completed training events was retained by the Benefits Manager. In addition, Benefits staff received information from Departmental circulars through bi-monthly team meetings and a council publication called the Benefit Bugle. Neither minutes of these meetings nor copies of the Benefit Bugle were circulated to staff who worked in the council’s information centres or the Mobile Information Centre.
4.30 In addition, these 2 groups of staff had not been included in the verification and refresher training that was delivered to other Benefits staff in February 2007. Although plans were in place to do this, no dates had been agreed at the time of our inspection in May 2007. The lack of an inclusive training programme meant that the council had no assurance that claims were dealt with appropriately. This was a weakness and a risk to the safe administration of the Benefits service. See recommendation 6.
Value for money
4.31 Although there is no definitive costing structure for benefits administration, local authorities should have regard to Departmental guidance which does cover efficiency.
Performance enablers
Achieving value for money
4.32 Broadland District Council met both enablers.
4.33 The council undertook an annual review of the costs of providing the Benefits service. It benchmarked its costs against those of similar councils in the area who were part of the Anglian Revenues Partnership. The council also undertook annual customer surveys to review its costs against the levels of customer satisfaction with the service provided.
4.34 The council regularly considered joint working with other councils in the area. The majority of its more recent joint working was through sharing access to and the costs of training provision with other councils. The council had also participated in a joint bid for Performance Standards funding in 2005 to review letters produced by the Benefits IT system. It had also taken an innovative approach to tackling a backlog situation in 2005. The Benefits service negotiated with other nearby councils and secured the temporary loan of 2 experienced assessment staff to help clear the backlog. This option was more cost effective than employing agency staff.
IT systems
4.35 Broadland District Council met both enablers.
4.36 We found the council’s Benefits IT systems supported all aspects of paying and accounting for benefits, interfaced effectively with other relevant council IT systems, and produced a wide range of management information reports.
4.37 The council had introduced the full suite of applications from its IT provider enabling effective integration between council tax, fraud, debt recovery and quality assurance systems. Internal Audit had confirmed that its Benefits IT systems provided comprehensive control over benefits and counter-fraud administration.
4.38 The IT Support Officer had responsibility for escalating any issues relating to its Benefits IT system with its IT provider. An escalation process was in place, but this had not been required.
Assurance
4.39 Large numbers of HB and CTB payments pass through a council’s accounting and payment system. It is therefore essential that there are rigorous internal control mechanisms to provide assurance that the benefits system is secure.
Performance enablers
Internal control mechanisms
4.40 Broadland District Council met one (E62) of the 3 enablers.
4.41 The council had effective corporate procedures in place to secure its IT systems. New users were confirmed to the council’s IT network by the Personnel Department before being given access to its Benefits IT systems. This process meant that users were automatically deleted from the network and Benefits IT systems when their employment with the council ended.
4.42 An IT Support Officer provided access to the Benefits IT systems following authorisation from a nominated officer. We were concerned the council did not have a standard authorisation procedure and that requests were made by e-mail. Although we were told e-mails had not been deleted a lack of formal control meant that Broadland District Council had little assurance that access to its Benefits IT systems was adequately controlled.
4.43 Following our feedback the council immediately introduced formal procedures for authorising access to its Benefits IT systems to ensure that an effective audit trail of requests was maintained.
4.44 We were told staff were automatically suspended from the system following a period of 30 days of user inactivity. In addition an annual review of user access was carried out as part of the end of year account. This is good practice.
4.45 All systems were password controlled and staff were aware of the protocols required to maintain system security, for example, changing the password every 90 days and not using an easily identifiable password.
4.46 New releases for its Benefits IT system were virus checked and tested on its test system, before being loaded onto the live system. User-testing ensured that existing procedures were not affected by new releases.
4.47 Post opening operated under secure conditions and we observed that staff adhered to the council's procedures for secure control of all documents.
4.48 The council carried out a check on some performance measure data before submission to the Department. We found this was limited to new claims and changes of circumstances that had taken in excess of 21 days and 9 days respectively.
4.49 To ensure the integrity of reported performance, authorities are expected to complete a random check of all cases decided to validate that data provided by the Benefits IT system is accurate. Any irregularities should be noted and performance figures adjusted accordingly before submission to the Department. See recommendation 8.
Secure administration
4.50 Broadland District Council met both enablers.
4.51 Internal audit work was outsourced to an external provider and the council’s auditors had responsibility for overall management of the work. A comprehensive audit of the Benefits Service was conducted annually. The areas to be audited each year were based on risk assessments using the Chartered Institute of Public Finance and Accountancy control matrices. The audit report covered a range of benefits work including checking work practices for compliance with documented procedural guidance and legislative requirements.
4.52 To supplement the annual audit report, additional audits were carried out during the year. The areas to be audited were based on a risk assessment process. For example in July 2005 the Benefits IT system was audited to ensure it was both secure and effective.
4.53 Oversight of the work of Internal Audit was undertaken in a number of ways. Internal Audit reported on a six monthly basis to the Overview and Scrutiny Committee. This involved a Management Summary of the annual audit report in May, with a progress report on the implementation of recommendations in November. The Benefits Manager also provided a quarterly report on Benefits administration to the Cabinet, which included progress on audit recommendations.
4.54 As part of their annual audits both Internal and External Audit checked to ensure that relevant action on recommendations had been taken. If not, recommendations were carried forward to the next audit. An escalation procedure, through elected Members and the Chief Executive was in place for any recommendations not implemented within the agreed timescales. This had not been used in recent years as recommendations were implemented within required timescales.