Security
2.1 It is important that councils have effective measures and processes to prevent, deter and detect fraud. Councils should verify information supplied by customers and reconcile conflicts identified through data matching. Sufficient resources must also be employed to investigate suspected fraud thoroughly and professionally, and appropriate sanctions should be applied. Broadland District Council explained that this would be difficult to achieve, as the impact of the latest announcement on Administration Grant would mean a 5% real-term reduction in each of the next three financial years.
2.2 The council met 6 of the 21 enablers for Security.
Security of administration
2.3 This section reports on the arrangements for interventions and the verification of claims. The performance measures are designed to measure the impact of the council’s performance in detecting fraud and error.
Performance measures
2.4 Figure 2.1 shows the council’s own calculation and assessment of its performance in the Security of administration for 2006/07, as reported to the Department.
|
Performance measure |
Description |
Target 2006/07 |
Performance 2006/07 |
Score |
|---|---|---|---|---|
|
PM 10 |
Number of interventions for which review action completed since 1 April |
2,960 |
3,341 |
Excellent |
|
PM 11 |
% of data matches resolved within 2 months |
100% |
100% |
Excellent |
|
PM 12 |
Number of claimants visited |
1,320 |
1,835 |
Excellent |
Source: Broadland District Council
2.5 Broadland District Council had 2 visiting officers who undertook interventions activity to ensure that its targets against PM 10 and PM 12 would be met. In addition a designated officer dealt with data-matches received from the Department’s Housing Benefit Matching Service to ensure that referrals were dealt with quickly.
2.6 The council exceeded its interventions targets for 2006/07. It operated a policy to conduct the majority of interventions by visit. We were told that this was to minimise the amount of fraud and error in its caseload.
2.7 The Department introduced a new Performance measure PM 10 from 1 April 2007. This measures the number of reductions in benefit entitlement, rather than setting targets for completed interventions.
2.8 Broadland District Council had a documented strategy on how it would meet its target against this new measure. This included the identification of cases that had not been subject to intervention activity in the past. At the time of our inspection, the council had identified 537 cases in this category and was concentrating its intervention activity on these cases in the first quarter of 2007/08. Early indications suggested a high proportion of these cases required adjustment following the intervention.
2.9 Its strategy also included targeting specific client groups where analysis suggested a change of circumstances was more likely to have occurred. Broadland District Council needs to actively monitor performance in this area to ensure its target will be met.
Performance enablers
Dealing with enquiries and compliance with HB/CTB Security Guidance
2.10 We increased the scope in this section to include the User focus enabler E43.
2.11 Broadland District Council met one (E43) of the 3 enablers.
2.12 We interviewed staff to establish the level of training received on the verification requirements detailed in the HB/CTB Security Guidance. All staff who accepted claim forms and assessed benefits had received training when the scheme was introduced or on induction.
2.13 We were concerned that refresher training had not been provided for Customer Service Officers and the council did not have a documented verification policy. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX See recommendation 6.
2.14 The council’s 2 largest Registered Social Landlords were designated offices for the receipt of claims and carried out verification on behalf of the council. Interviews confirmed Registered Social Landlord staff had received appropriate training on the verification of documents and evidence requirements.
2.15 Benefits assessors had responsibility for assessing the quality of verification undertaken by Registered Social Landlord staff. They told us the level of verification was high and few issues were raised.
2.16 To establish the level of compliance with the requirements of the HB/CTB Security Guidance we examined a sample of 30 new claims and 10 changes of circumstances decided between 1 January and 31 March 2007. Figure 2.2 shows the results of our analysis of the new claims sample.
|
Verification item |
Number requiring verification |
Number where sufficient evidence held on file |
% verified |
|---|---|---|---|
|
National Insurance number – customer |
30 |
30 |
100% |
|
National Insurance number – partner |
8 |
8 |
100% |
|
Identity – customer |
30 |
30 |
100% |
|
Identity – partner |
8 |
8 |
100% |
|
Liability to pay rent |
30 |
30 |
100% |
|
Residency |
30 |
26 |
87% |
|
IS, JSA (IB) and Pension Credit |
9 |
9 |
100% |
|
Income – customer |
17 |
16 |
94% |
|
Income – partner |
6 |
6 |
100% |
|
Capital – customer |
16 |
12 |
75% |
|
Capital – partner |
6 |
6 |
100% |
|
Non-dependants’ circumstances |
2 |
2 |
100% |
|
Total |
192 |
183 |
95% |
Source: BFI analysis
2.17 A council needs to gather a wide variety of documentation to satisfy verification requirements. In our sample we reviewed 192 items that had been provided as evidence to support the 30 new claims examined.
2.18 Broadland District Council used its Document Image Processing system to record which documents had been used to verify each aspect of a claim. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX
2.19 These documents alone are insufficient to verify a customer’s residency. Where a council is unable to visit a customer or obtain a recent utility bill, showing the property is occupied, it should use a number of different sources to verify a customer’s residency.
2.20 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X
2.21 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX A council should take immediate action to resolve such issues before putting benefit into payment. Failure to do so increases the possibility of fraud and error entering the system.
2.22 We also found a case where the council had failed to fully verify a customer’s income on starting work. As the customer stated the hours to be worked would be regular, a decision was made, on 20 March 2007, to put benefit in payment using the 2 weekly payslips provided. The customer was asked to provide the next 3 payslips by 19 April 2007. Although this was a reasonable decision only one additional payslip had been received and no follow-up action had been taken at the time of our inspection on 2 May 2007.
2.23 We found that all 10 changes of circumstances sampled had been verified correctly. Verifying claims correctly helps to reduce the amount of fraud and error entering the system.
2.24 The council’s main caller facilities were located in Thorpe Lodge in Thorpe St. Andrew. Customers could also call in to one of the council’s information points situated in Aylsham and Wroxham libraries. In addition a Mobile Information Centre provided weekly surgeries in 11 locations across the district.
2.25 All locations provided an over-the-counter service for customers to present claim forms and other evidence. Photocopies of original documents were taken and annotated to show the original had been seen. Original documents were returned immediately to the customer. Observations confirmed staff took action to deal with any discrepancies in the information provided by customers.
2.26 Staff located in Thorpe Lodge had access to the Benefits IT system to deal with enquiries. Although staff in the other locations did not have access, they had direct telephone lines to the Benefits service to obtain answers to customers’ enquiries.
Compliance with data integrity
2.27 Broadland District Council met this enabler.
2.28 The council had provided the Department with all required data in an appropriate format and within specified timescales. The Housing Benefit Matching Service confirmed there were no incidents rated 1 or 2 during the period 3 April 2006 to 23 February 2007.
2.29 The Housing Benefit Matching Service also confirmed that 99.9% of customer and 99.8% of partner National Insurance numbers matched with Departmental records during the same period.
Counter-fraud activities
2.30 This section reports on the council’s efforts to detect and deal with fraud.
2.31 To assess the quality, speed and effectiveness of counter-fraud work we randomly selected 20 fraud files closed during 2006/07.
2.32 Figure 2.3 shows the council’s reported performance for its Counter-fraud activities in 2006/07.
|
Performance measure |
Description |
Performance 2006/07 |
|---|---|---|
|
PM 13 |
Number of fraud referrals per 1,000 caseload |
47.5 |
|
PM 14 |
Number of fraud investigators employed per 1,000 caseload |
0.15 |
|
PM 15 |
Number of fraud investigations per 1,000 caseload |
41.4 |
Source: Broadland District Council
2.33 Broadland District Council considered its exposure to fraud was low risk. Although it had no specific evidence of this, it had made the link with its crime statistics, which showed its crime rate was low nationally. It had, therefore, chosen to operate a very small fraud team. Its Counter-Fraud Section comprised one Fraud Officer supported by a Fraud Clerical Assistant, which meant its investigator to caseload ratio was amongst the lowest in the country. The Fraud Officer reported directly to the Benefits Manager.
2.34 The Counter-Fraud Section received 333 referrals during 2006/07. 286 of these were passed for investigation. We consider this to be an unmanageable load for one investigator and comment on its impact in subsequent sections, although it was clear from the standard of many cases in our sample that a significant number should not have been passed for investigation or closed at an early stage.
Enablers
Fraud referrals
2.35 Broadland District Council met one (E21) of the 2 enablers.
2.36 Benefits and Council Tax staff had all received a Housing Benefit Fraud Manual and attended fraud awareness sessions in the first 3 months of 2007. We were told these sessions would eventually be offered to Housing staff, other council employees and Registered Social Landlord staff with an intention to repeat the sessions on an annual basis.
2.37 We were encouraged to find 3 (15%) referrals in our sample of 20 closed cases had originated from the Council Tax section. Referrals received from Benefits staff suggested a good awareness of potential underlying fraud. However, visiting staff we interviewed were still unclear about their responsibilities if the suspicion of fraud arose during an intervention visit.
2.38 We noted that 152 (46%) of the 333 referrals received in 2006/07 had originated from Benefits staff. Referrals from Benefits staff were made using a free-text entry facility on the document image processing system. Referrals from other council departments were accepted by e-mail. Both these methods increased the risk of potentially important information being omitted from the referral. We were also concerned that the details of referrals from Benefits staff were viewable by all staff with access to the document image processing system, seriously undermining the security of the process.
2.39 Feedback to the referral source was routinely provided at regular intervals and at the closure of an investigation. This is good practice.
2.40 Steps taken to maximise referrals from the public included the provision of guidance on the council’s website and publicity of its dedicated telephone hotline in council publications. Benefits staff were provided with clear guidance to ensure important information was obtained from callers. We found the hotline answer phone message was clear and comprehensive.
Risk profiling referrals
2.41 Broadland District Council met neither enabler.
2.42 Only 8 (40%) of our sample of 20 closed cases showed evidence of initial risk assessment and scoring on the fraud file. The council’s system for risk profiling and scoring referrals was integrated with its fraud management system. Our analysis and interviews with staff revealed that this process was ineffective and had consistently failed to eliminate poor quality referrals. We were also concerned the referral process was not subject to any routine management intervention.
2.43 We were told that most of the referrals that were risk assessed scored over the threshold set by the council and were therefore accepted for investigation. The score at which referrals were accepted was not routinely adjusted to reflect available resources, the volume of referrals received or successful outcomes. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX
2.44 The limited resources allocated to counter-fraud work in Broadland meant it was important to organise work as efficiently and effectively as possible. Our findings showed that the failure to score and eliminate poor quality referrals had resulted in the Fraud Officer holding a caseload of over 250 live investigations at the time of our inspection. We consider this excessive and made it extremely difficult to identify and progress good quality cases quickly and effectively.
2.45 We found detailed files were raised and prepared by the Fraud Clerical Assistant. However, basic background checks were not performed before cases were risk assessed and information from discrete intelligence sources such as the Department’s Operational Intelligence Unit or National Anti-fraud Network was not routinely requested.
2.46 We identified 14 (70%) cases in our sample of 20 closed cases where no actual investigative activity took place. We consider this to be a symptom of the high number of low-risk cases that were accepted for investigation and highlights the need for the caseload to be better managed. Where an allegation is considered suitable for investigation at the outset and no other explanation or evidence is provided, then we consider as a minimum response that the customer should be interviewed informally and a statement obtained.
2.47 Allegations sent to and accepted for investigation by the Department that contained a HB or CTB interest were forwarded to the council to consider a joint investigation. We found that although these were treated as referrals and recorded as live investigations by the council, no further action was taken by its investigators until the Department notified the result of its investigation.
2.48 We analysed management information regarding accepted fraud referrals in 2006/07 and found 18% of cases were eventually categorised as ‘fraud proven’. No local targets had been established to monitor the effectiveness of investigations.
2.49 We also noted and were concerned that only one of the 39 anonymous or hotline referrals received in 2006/07 had resulted in a ‘fraud proven’ result. Ongoing analysis of the quality of referrals received from the public and a review of the council’s approach to the investigation of unsupported allegations need to be undertaken to ensure the effective use of scarce resources.
2.50 It is essential risk assessment and scoring
procedures are regularly reviewed to ensure only worthwhile cases are selected
and accepted for investigation. The process should be based upon the effective
use of intelligence sources and ongoing analysis of investigation results.
See recommendation 2.
Action on referrals
2.51 Broadland District Council met neither enabler.
2.52 Targets to risk assess referrals within 10 days and commence investigations within 10 days were included in the Fraud Team Business Plan 2006/07. Performance was not actively monitored to ensure these targets were met and we were told that the referral process would be adversely impacted when staff were absent or workloads increased. Senior officers told us that the council would prioritise payment of benefit over anti-fraud work should there be workload or staffing issues, in view of the reduction in the Administration Grant. We noted that in the 8 cases in our sample that had been risk assessed, this had taken an average of 5 working days.
2.53 Once accepted, it is important investigations are undertaken promptly to ensure action is taken on relevant and up-to-date information and to protect the rights of those subject to investigation. See recommendation 3.
2.54 We identified long delays in subsequent action and found there were unnecessary delays at different stages of the investigation in the majority of cases in our sample. For example, in the 6 sampled cases where an investigation was pursued, it took an average of 23 working days before the first action was taken following risk assessment. The 20 cases in our sample were eventually closed in an average of 112 working days. There were a variety of factors involved. Lack of prioritisation, monitoring and control, high caseloads, lack of cover, inefficient processes and customer delays were all contributing, but not all were in evidence on every case.
2.55 The audit trail to record the action taken on investigations was clear and comprehensive on the majority of cases we examined. Cases were logged onto the fraud management system and also recorded on a spreadsheet to track progress.
2.56 We found there was no management intervention at key stages of the process and it was left to the Fraud Investigator to decide whether to continue with an investigation or to end it. Case reviews were not routinely undertaken at key stages of the process to ensure further action was warranted or likely to prove effective. See recommendation 1.
Fraud investigators’ code of conduct
2.57 Broadland District Council met none of the 4 enablers.
2.58 Both the Fraud Officer and Fraud Clerical Assistant had received investigative training including Professionalism in Security accreditation. We found the 2 investigative staff lacked procedural guidance or sources of advice to ensure a consistent approach to investigations.
2.59 In addition, the absence of regular management intervention failed to provide assurance that investigations were being conducted professionally and in accordance with relevant legislation. We were told that the council operated with minimum levels of management capacity and had adopted a method of trusting staff to undertake the duties that they were employed for. This method of working was underpinned by a stringent twice-yearly formal appraisal system, which was tied in to performance-related pay.
2.60 Our sampling showed only 7 (35%) of the 20 cases we examined resulted in an interview with the customer before the case was closed. This involved either an interview under caution or an informal interview to discuss the change in the customer’s circumstances. Informal interviews were not adequately recorded. They failed to record whether the customer was aware the Fraud Officer was conducting the interview or that the customer was advised they did not have to answer questions regarding the allegation.
2.61 We looked at a joint interview under caution with the Department’s investigator where the council had failed to introduce material evidence into the interview. This had a direct bearing on the outcome of the investigation and eventually led to the inappropriate offer of an administrative penalty to the customer, which was accepted. The council told us that it would take urgent action to contact the customer to apologise and withdraw the penalty.
2.62 We were concerned that an anonymous but identifiable referral source was disclosed to the suspect in one interview transcript we examined. In another, the interview was brought to a swift conclusion by the investigator because the tape had almost run out. The circumstances of this case and the course of the interview suggested the customer had more relevant information to disclose. It is important that customers are given the opportunity to provide a full explanation for their actions.
2.63 Other weaknesses we identified included 3 interviews conducted in customers’ homes without any recorded explanation as to why this was necessary and 2 interviews in which a partner or representative answered questions put to the customer about the allegation. There were delays in arranging interviews under caution in 2 cases we examined and in one case the interview under caution took place before sufficient evidence had been collected. The decision to interview suspects under caution was not subject to management intervention. See recommendation 1.
2.64 The council maintained a separate fraud file for each referral. We found effective controls had been established for the storage and security of evidence, fraud files and interview tapes. Counter-fraud staff were located in the main benefits section and therefore lacked a discrete environment to work on files or discuss cases.
2.65 We found entries in QB50 notebooks were not comprehensive and were not subject to any management check. It is important that detailed records of investigations are maintained to protect counter-fraud staff and the subjects of investigation, particularly when interviews are conducted away from the office. See recommendation 1.
The council fraud policy
2.66 Broadland District Council met 2 (E32 and E34) of the 5 enablers.
2.67 Broadland District Council had developed an Anti-fraud and Corruption Strategy which was available on its website. This stated the council’s commitment:
to encourage prevention, promote detection and identify a clear pathway for investigation.
2.68 The Fraud Team Business Plan 2006/07 failed to describe how the strategic aims of the council would be assisted by the operational activities of its counter-fraud staff. Nor did it explain how the progress, quality and outcome of investigations would be monitored. See recommendation 5.
2.69 Although elected Members were provided with quarterly updates regarding performance against sanctions targets, we found measures taken to monitor the standard and quality of investigations work were inadequate. Without an adequate checking regime in place, the Benefits Manager lacked assurance regarding the activities and performance of counter-fraud staff. As a result elected Members and senior officers also lacked assurance that:
- quality investigations and sanctions were being progressed
- the council’s counter-fraud strategy was working
- trained investigative resources were being deployed effectively.
See recommendation 1.
2.70 In April 2007 the Fraud Officer had completed training and received authorisation to request information under Section 109B of the Social Security Administration Act 1992 as amended. Measures to monitor the use of these powers and establish clear divisions between the investigative and information gathering functions had still to be established at the time of our inspection in May 2007.
2.71 We were told that the council’s senior officers were considering using a centralised intelligence resource for information gathering, such as the National Anti-fraud Network. We were told no investigation had so far required contact with the Department’s Operational Intelligence Unit for information to be requested from Her Majesty’s Revenues and Customs.
2.72 The council operated the Do-not Redirect scheme effectively by ensuring all Benefits post was despatched in designated envelopes. Very few referrals had been generated by returned mail.
2.73 Although both the council and the Department’s Fraud Investigation Service reported a positive and improving working relationship, we found no evidence of a joint approach to investigations. All referrals received by the council where the customer was found to be in receipt of Income Support or Jobseekers Allowance were raised as investigations but then passed to the Fraud Investigation Service for the Department to begin enquiries.
2.74 We were told the council lacked the resources to participate in this type of investigation and had instead decided to concentrate on cases where only HB or CTB were in payment. This meant that opportunities for an organised approach to joint working, where the action taken to investigate allegations could be planned and shared, were missed.
2.75 Where the Department’s investigation uncovered fraud, the council’s Fraud Officer was invited to attend a joint interview under caution arranged by the Department’s investigators. We noted that the council recorded 3 joint prosecutions and 5 joint sanctions in 2006/07.
2.76 Arrangements for liaison with other local fraud practitioners were effective and included quarterly meetings at the council’s offices for all Norfolk councils and their Departmental counterparts.
Sanctions
2.77 This section reports on the arrangements for applying sanctions against benefit fraudsters.
Performance measures
2.78 Figure 2.4 shows the council’s reported Sanctions performance for 2006/07.
|
Performance measure |
Description |
Performance 2006/07 |
|---|---|---|
|
PM 16 |
Number of successful sanctions per 1,000 caseload |
4.9 |
Source: Broadland District Council
2.79 Broadland District Council reported 4 successful prosecutions, 24 formal cautions and 5 administrative penalties. However, this inspection identified serious weaknesses in the council’s administration of sanctions.
Enablers
A balanced sanctions policy
2.80 Broadland District Council met 2 (E36) and (E37) of the 3 enablers.
2.81 The council had created a sanctions panel to decide which sanction should be applied when evidence of fraud was identified. Members had adopted a Housing Benefit and Council Tax Benefit Fraud Revised Prosecution Policy in March 2006 to provide:
a framework to ensure a fair and consistent approach to the use of formal sanctions.
2.82 We found this policy failed to identify key roles and responsibilities including how evidential and public interest tests should be considered or applied. See recommendation 4.
2.83 Our sample of 20 fraud files included 4 cases where a sanction had been administered. We found the audit trail to support the decisions of the council’s sanctions panel was inadequate on these cases. We also found fundamental weaknesses in 3 (75%) of the 4 cases. These included:
- an administrative penalty issued when there was no evidence of fraud
- a formal caution offered but no reliable admission of guilt was obtained during the interview under caution
- a formal caution issued when the circumstances of the case indicated a prosecution was appropriate.
2.84 Our concerns at these findings led us to examine a further 5 sanction cases also closed during 2006/07. Our additional sampling highlighted similar serious weaknesses. These included 3 cases where a formal caution was issued but no reliable admission of guilt was obtained during the interview under caution. Two of these cases also contained evidential weaknesses, which would have made prosecution unlikely had the formal caution been refused.
2.85 More details regarding one of these cases are provided in the following case study.
|
Case study 1 |
BFI comments |
|---|---|
|
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2.86 The council should refine its Housing
Benefit and Council Tax Benefit Fraud Revised Prosecution Policy and develop
comprehensive procedures to support the activities of its sanctions panel.
Safeguards need to be established to ensure sanctions are issued in appropriate
circumstances and in accordance with legislation, Home Office and Departmental
guidelines.
See recommendation 4.
2.87 Checks had been made with the Department’s Fraud Investigation Service Technical Support for previous sanctions before formal cautions and administrative penalties were issued. Checks for previous convictions were also made and details of successful sanctions were notified to the Department.
2.88 The Housing Benefit and Council Tax Benefit Fraud Revised Prosecution Policy described the council’s intention to pursue a prosecution if the offer of a sanction was refused, although this situation had yet to occur.