Section 2:
Management summary

Summary findings and conclusions

Administration

2.1 The main finding from our inspection of Inverclyde Council’s HB/CTB administration function is that it is not well managed. In our view, this situation is mainly due to a lack of any strategic planning over recent years. This leads us to the conclusion that a strategic review of the LA’s benefit delivery service is urgently required.

2.2 We did, however, find some examples of good practice during the course of our inspection such as:

• the LA has a core of experienced staff with good local knowledge and ideas for improving the service they provide
• there is a council-wide complaints procedure that is well publicised, although some applications for review are treated as complaints
• some positive steps are taken to raise awareness of HB/CTB
• the LA has recently introduced an improved and integrated HB/CTB claim form that:

- includes warnings about giving false information
- tells claimants information they provide may be used for data matching purposes

• historically, the LA has performed well against the national 14-day clearance target for new and renewal claims
• there are sound verification procedures in place that go some way towards meeting Verification Framework (VF) standards, although often staff do not take and keep photocopies of evidence seen
• the LA has a policy of tailoring benefit periods to the circumstances of individual claimants
• the extended payments (EP) scheme is generally well administered
• there is effective two-way communication with local Housing Associations (HAs)
• staff enjoy a good working relationship with the Rent Officer Service (ROS)
• there is effective liaison with BA.

2.3 However, there are some major weaknesses in Inverclyde Council’s administration of HB/CTB. Our view is that the LA could address these by, for example:

• reviewing the managerial strategy of moving towards a fully decentralised housing and benefits service
• increasing the resources allocated to the benefits service, particularly the processing of rent allowance claims
• making full use of the management reports that can be produced by the new information technology (IT) system recently installed by First Software
• introducing a range of management and supervisory checks and controls
• formulating a training strategy and supplementing this with a comprehensive HB/CTB procedural manual(s)
• reviewing its arrangements for the management of HB/CTB overpayments
• actively seeking the involvement of internal audit in HB/CTB administration.

Counter-fraud

2.4 Our examination of the counter-fraud effort within Inverclyde Council’s HB/CTB area indicated that this important aspect has not been adequately resourced and that management’s main objective appeared to be avoiding Weekly Benefit Savings (WBS) penalties.

2.5 Although almost totally reactive in its approach to countering HB/CTB fraud, the LA has taken some positive steps recently to deter the fraudster such as:

• obtaining publicity in the local press about fraud savings and the appointment of a visiting officer (secured through the Challenge Fund) to validate certain HB/CTB claims
• increasing the amount of training given to the Designated Fraud Officer (DFO)
• building up a relationship with BA’s Benefit Investigation Service (BIS).

2.6 This said, the effectiveness of the LA’s counter-fraud work is marred by the absence of:

• a comprehensive counter-fraud strategy and prosecution policy
• a fraud hotline to generate suspected fraud referrals from the public
• an IT-based case management system, together with separate fraud files, that would assist analysis of DFO performance and support prosecutions
• management checks to provide assurance about the Value for Money (VfM) and propriety aspects of fraud investigation work
• any involvement by internal audit in the objective assessment of the counter-fraud effort
• a permanent fraud team.

Liaison with other parties

2.7 Inverclyde Council has a good working relationship with both BA and the BIS. The relationship with ES is, understandably, a little less close, but is nonetheless satisfactory. Specific actions that would benefit the LA, BA and ES are set out in the recommended interface action plan at the end of this report (Appendix C15) and include:

• active management of the existing Service Level Agreements (SLAs) with BA and BIS, including the need to improve the exchange of information on

- potentially violent persons (PVPs)
- overpayments

• a re-negotiation of the SLA with ES to include aspects such as

- the introduction of Jobseeker’s Allowance (JSA)
- reference to the EP scheme
- monitoring of agreed performance targets

• increased liaison between the LA and BA on visiting programmes and fraud investigations to eliminate duplication of effort and increase the level of shared intelligence on fraud issues.

2.8 These suggested actions have been communicated to both BA and ES in separate reports. Both agencies have been asked to liaise with the LA over the implementation of the recommended interface action plan referred to above.

Recommendations

2.9 In Section 5 of this report, we make 15 major recommendations to Inverclyde Council. Implementation of these recommendations should help the LA improve both its administrative efficiency and the security of its benefit delivery by ensuring that:

• the risks identified by the Audit Commission as inherent within any decentralised service involving generic team working are effectively addressed by management
• the benefits administration and counter-fraud areas are adequately resourced
• a suitable management information system (MIS) and test checking procedures are put in place
• debt management is given greater priority
• staff receive adequate induction, refresher and remedial training
• internal audit is fully involved in the management of HB/CTB to provide assurance about VfM and internal controls
• there is a coherent approach to counter-fraud work supported by a comprehensive counter-fraud strategy.

Inverclyde’s response to the inspection