Findings (continued)

Getting it right

2.18 Getting it right means benefit payments should be correct from the start. This means that:

· there must be a secure gateway to the benefit system

· claimants should not have to deal with unnecessary red tape

· the organisation provides a modern, integrated, high quality service.

Benefit service accessibility and awareness

2.19 Section 123(3)(a) of the Social Security Contributions and Benefits Act 1992 states that every authority granting HB:

…shall take such steps as appear to them appropriate for the purpose of securing that persons who may be entitled to housing benefit from the authority become aware that they may be entitled to it.

Requirements in respect of CTB are in section 123(4)(a) of the same Act.

2.20 LAs can promote the legitimate take-up of benefit by:

· advertising the HB and CTB scheme through the local media and throughout council offices

· working with other organisations, such as Jobcentre Plus, welfare groups and landlords.

2.21 We found that RBK had a clear commitment to providing a good service to its customers. For example as part of its BV Review, completed in March 2002, it:

· conducted a council tenants survey

· initiated a benefit focus group which included 12 claimants

· obtained feedback on the quality of its existing benefits leaflets and posters from a variety of stakeholders such as the Citizen’s Advice Bureau (CAB), Housing Associations (HAs), libraries and leisure facilities. These documents were also sent to 30 local ethnic and minority groups

· carried out a survey of benefit claimants who were leaving the main reception area

· sought the opinion of the local CAB.

2.22 Having carried out this review it was important that RBK translated the findings into reality. To this end Members fully endorsed the Revenues and Benefits BV Option Appraisal which included many recommendations for service improvements.

2.23 In the following paragraphs we report our findings and we concluded that this area was a particular strength for RBK in which they demonstrated many aspects of good practice.

Customer services

2.24 Benefit claimants were able to contact RBK by telephone or by visiting its main reception area at Guildhall. RBK had a dedicated telephone call section staffed by experienced benefits staff on a rota basis.

2.25 RBK’s 4 housing offices held claim forms and assisted claimants in their completion of them. In addition we found that all benefit notifications quoted a direct line for benefit related enquiries. This is good practice.

2.26 RBK also had a nominated officer who carried out welfare visits when appropriate. For example we were told that visits were made to those claimants who were elderly or infirm and needed assistance to complete benefit application forms. This was also good practice.

Benefits reception area

2.27 We found that the RBK main reception area at the Guildhall was small but bright and uncluttered. There was an automated queuing system in place and 2 rooms were available to claimants who wished to discuss their claims in private. This is good practice.

2.28 As part of its recent BV Review and to support the introduction of VF the reception area will be extended and upgraded in the summer.

2.29 We made a number of un-notified observations of the area during our on-site visit throughout the week commencing 22 April 2002. We noted that there were a number of good practices in place within the reception area. On display were:

· an extensive variety of DWP benefit leaflets

· a wide variety of posters advertising both benefit take-up and fraud prevention

· information on the need to report changes of circumstances

· a stock of claim forms

· posters on evidence required to support claims

· posters giving advice on appeals and complaints procedures

· posters giving advice on other LA and CAB services

· information on the availability of language services.

2.30 As part of its of its BV Review published on 27 March 2002, RBK tested customer satisfaction with its reception service and in a response from 77 callers (30% of questionnaires issued) concluded:

· 97% of claimants found waiting times to be short or reasonable

· 98% of claimants found that the quality of service provided was good.

2.31 We also found that RBK provided a good service to its claimants. We observed the reception process on 6 occasions during our on-site inspection. These observations were ad-hoc and lasted between 10 and 30 minutes. We monitored claimant waiting times and found the longest claimant waiting time during our observations was 7 minutes.

2.32 There is however scope for improvement. For example we found that the existing caller management information could be improved. The only management information collated was the number of callers. The reason for calling is not monitored.

We recommend that RBK monitors the reason why claimants or their representatives call in and routinely analyses this information.

If it does so it will gain an insight into the make-up of caller traffic and should also be able to identify potential service issues that may contribute to the claimants’ need to call in the first place. Subsequent remedial action will provide opportunities to improve efficiency and effectiveness.

2.33 We found that although RBK had a caller waiting time target of seeing 95% of claimants within 15 minutes of arrival, it had not publicised this target and neither customer service staff or benefit staff were aware of it.

2.34 There were no routine management checks in place to monitor the target. In its BV review RBK had identified the need to introduce a reception queue monitoring system however RBK did not have a date for its implementation.

2.35 In the interim period we believe that RBK could carry out clerical checks, which would allow performance against the target to be monitored.

We recommend that RBK:

· informs customer services and benefits staff of the caller waiting time target

· implements simple management checks to monitor the caller waiting times at reception, by clerically recording caller arrival and departure times.

If they do this RBK will gain assurances on the extent to which it meets its committed caller waiting times target.

2.36 RBK responded positively to the above recommendations and told us that it intended to put the necessary management checks in place when the new reception area is finished in the summer.

Giving advice and providing accurate information

2.37 We conclude that the advice given to claimants at reception was clear and accurate and in line with the views of claimants who completed the above caller satisfaction survey.

2.38 We found that benefit take-up was encouraged but that appropriate steps to secure the gateway were also in place. The reception was staffed by 2 customer service officers, (CSOs) who had been trained in VF and forged document procedures. They demonstrated during our observations a sound knowledge of evidence requirements and fraud awareness. For example we noted that the CSOs:

· gave receipts for, and obtained signatures to confirm, evidence supplied by claimants

· only accepted original documentation

· refused to accept evidence that did not meet VF requirements

· gave general advice on other DWP benefits such as Working Families’ Tax Credit (WFTC) and Income Support (IS)

· gave advice on single person discounts

· reminded claimants of the need to report changes of circumstances.

2.39 Although RBK was not yet fully compliant with VF, management told us that from January 2002 they had accepted only original documentation at the reception area. To test compliance with this procedure we examined 30 pieces of post received on the morning of 25 April 2002 at reception. We found that all evidence had been photocopied and annotated that the original had been seen. We found that both receptionists had signed and dated these copies, using a stamp designed for this purpose. However the space provided to write the officer’s name in full was not completed on 3 pieces of evidence.

We recommend that RBK reminds its customer service staff to record their name in full when noting details of evidence seen, if they do this they will have a more complete audit trail and as such more assurance on the integrity of the system.

2.40 We found evidence of fraud awareness by CSOs during our examination of fraud referrals. The following case study illustrates this.

Fig. 2.5: Case study 1 – Securing the gateway at reception – contrived tenancy

A claimant called at the counter to make a claim for benefit. He stated that his landlord was his cousin and that he had lived at the tenancy for the previous 6 months. He wished to make a backdated claim to benefit. He was advised by the CSO that he would have to provide evidence of his tenancy. The claimant returned the next day to reception. He stated that he did not have a lease but produced a rent book, which showed entries for the previous 6 months. The CSO was not content that the evidence was genuine. The rent book was new and all entries were in the same ink and style. She was of the view that the book had been constructed after the claimant’s visit to reception the previous day. She made a referral to the fraud section. The claimant was interviewed by a fraud investigator and as a consequence withdrew his claim to benefit. BFI Comment This is an good example that demonstrates how fraud can be prevented from entering the system, through fraud aware reception staff.

Source: BFI analysis

Telephone enquiries

2.41 RBK operate a benefits telephone enquiry section, which is staffed by two experienced benefits staff on a rota basis. In its benefits team plan for 2001/02, RBK had set a target to answer 90% of all calls within 5 rings.

2.42 The limitations of RBK’s telecommunications system meant that it could not measure its performance against this target. Details were kept of the number of telephone calls received, but we were told that these details were not monitored. In its benefits team plan for 2001/02 RBK outlined that it intended to:

· review the number of telephone lines available

· introduce an out of hours answering machine

· pursue improved management information.

2.43 At the time of our on-site visit no action had been taken to implement these initiatives. However RBK told us that it planned to install a new switchboard in summer 2002 which will enable it to make progress in this area.

Internet

2.44 Benefit service information is available on the RBK Internet. Since March 2001 the website has included a copy of the claim form which can be downloaded and the hardcopy signed and submitted by the claimant. However to date no claimant has made use of this facility.

Claim form

2.45 HB Regulation 72(1) states that:

Every claim shall be in writing and made on a properly completed claim form…

2.46 The same provision for CTB is in regulation 62(1) of the CTB Regulations.

2.47 A good claim form for both new and renewal claims plays a vital part in ensuring administrative efficiency, securing gateways into the benefit system and providing a better quality of service to claimants.

2.48 After wide consultation, BFI has developed a national model claim form. It sets a minimum standard for LAs to follow when designing their own claim forms, and takes account of VF requirements and good practices that BFI has identified during its inspections.

2.49 RBK developed a new claim form based on the national model. This form had been used for all new claims to HB and CTB since January 2002.

2.50 At the time of our on-site inspection in April 2002, RBK was however still using 3 of its old forms in respect of renewal claims for:

· HB and CTB council tenants

· HB and CTB private tenants

· CTB only.

2.51 These were the forms that had been used for new and renewal claims prior to the introduction of its new claim form in January 2002.

2.52 We found from our sampling that the old claim forms severely hindered the effective collection of evidence in particular areas such as identity, non-dependants’ income and capital. This resulted in RBK having to request additional information. We found that in new claims RBK had to request additional information in 26 of the 30 cases sampled, an alarming 87%. In the renewal cases sampled RBK had to request further information in 7 (23%) cases.

2.53 Not only does this rework have significant resource implications for RBK, it also had an adverse impact on its performance against speed of claims processing targets and ultimately its service to claimants. We make comment on this later in this section.

2.54 We compared the 4 claim forms RBK was using against BFI’s model claim form. Our analysis is at Appendix B.

New claims claim form

2.55 We found that the new claim form introduced in January 2002 for new claims was in line with the national model and we identified only 2 areas for improvement. These were:

· to include the print run on all forms

· to provide advice that if evidence of earnings is not provided that the employer will be contacted.

Renewal claims claim forms

2.56 Our findings from our analysis of the renewal claim forms were less positive. In particular we found that the forms:

· did not specifically ask yes/no questions therefore making it weak in design because the claimant is not required to answer all appropriate questions. Any subsequent fraudulent claims would be difficult to prove

· were out of date and did not reflect the current range of DWP benefits. As a result RBK could not be assured that it was obtaining all the relevant information on the claimant’s benefit income

· failed to gather sufficient information regarding capital for both the claimant, partner and dependants

· failed to gather sufficient information on non-dependants income

· did not fully comply with VF requirements.

2.57 We discussed these weaknesses with RBK management who advised us that it had originally intended to introduce its new claim form for all claims from mid May 2002, but this had now slipped until June 2002.

2.58 It had not done so earlier because it had been developing an additional notification to claimants in advance of VF, which advised them of the importance of returning claim forms on time and with the required evidence.

2.59 We welcome this, however since renewal claims are issued 8 weeks in advance of the expiry date, RBK will continue to receive these claims from claimants up to late July 2002.

We recommend that RBK revises its new claim form in line with our detailed comments in Appendix B. It should also withdraw its old style forms in favour of the new claim form on all cases as a matter of urgency.

If it does so it will be able to comply with the minimum standards contained in the VF. And in doing this its single claim form for new and renewal claims will become a more secure means of protecting the gateway to prevent fraud.

Verification work

2.60 Regulation 73(1) of the HB Regulations requires that:

…a person who makes a claim…shall furnish such certificates, documents, information and evidence in connection with the claim…as may be reasonably required by the relevant authority to determine that person’s entitlement to…housing benefit…

There is a similar provision in the CTB Regulations.

2.61 In addition, the DWP has also developed the VF. This sets out the minimum standard of verification that LAs should apply when processing HB/CTB claims and is designed to help prevent fraud and error entering the system at the claim stage.

2.62 Though requiring the provision of such evidence is, in itself, a major tightening to the gateway to benefit, it is not enough that processing staff mechanically ensure the right evidence is gathered. They need to consider its implications, in particular whether or not it established the point at which verification was sought and obtained. Then they need to cross check the claim form and evidence submitted in every area to ensure the basis for assessment of benefit is reliable.

2.63 In the following paragraphs we look at how RBK verifies claims and the extent to which legal requirements and minimum verification standards are met. Then we consider the general arrangements for gathering and checking information and evidence necessary to process claims.

Collecting and recording information and evidence

From April 2002

2.64 We were told that following advice issued by DWP in December 2001, which allowed LAs to achieve full VF compliance incrementally, RBK took the decision to implement VF from 1 April 2002. It had decided to adopt all 3 VF modules incrementally, by tenure type, with a view to achieving full compliance by October 2002. It began with:

· hostel dwellers and supported accommodation, from 1 April 2002

· HAs were planned to be included in June 2002

· the final 2 phases were planned to include private and council tenants.

2.65 Implementation dates for the final 2 phases are to be developed when the first 2 phases have been evaluated.

2.66 As part of its implementation plan RBK had set up a VF section comprising a group manager, a deputy group manager and 2 benefit officers.

2.67 Before implementation RBK had developed new verification guidance. This new guidance included a list of acceptable evidence for individual elements of a claim. Whilst we found that, in general, it complied with VF requirements it needed to be improved by making certain requirements more specific, for example:

· including all areas of verification that should be cross checked

· outlining the process to follow to ensure that all identified discrepancies are followed up.

2.68 We discuss these issues in detail later in this section when we comment on verifying individual elements of the claim.

2.69 We found that the guidance emphasised the need for original documentation and authentication. Staff were advised in the guidance that if they had any reason to doubt the authenticity of any documents they must not assess the claim but should discuss it with their group manager or deputy.

2.70 In early April 2002 all RBK benefit and customer services staff attended 2 training courses, both delivered by external providers. The first of which was one day on VF principles and the second, a half-day on recognising forged documents. Since the training RBK has been authenticating evidence collected for all claims. This has included those tenures for which VF has not yet been fully adopted. This is a big improvement on its previous procedures which did not require an audit trail to VF standard.

2.71 To test this we examined the post received at reception one morning during our visit. We found that all evidence had been date stamped, authenticated and signed by customer service staff to show that original documentation had been seen.

2.72 All information and evidence that was collected for adopted VF claims was recorded on a summary sheet. The purpose of this sheet was to record:

· evidence collected to verify individual elements of the claim

· a chronological history of activity on the claim.

2.73 Additionally the benefit officer completed the verification checklist from the VF, to confirm that all appropriate evidence had been collected and cross checks had been made. The use of this summary sheet and checklist was also included in RBK’s verification guidance. Staff were advised to complete each box of the VF Checklist section, marking sections ‘not applicable’ if necessary.

2.74 By phasing-in VF implementation RBK told us they had been able to check 100% of adopted VF cases. Authenticating and recording of evidence formed part of this management check. However as VF rolls out and the number of cases requiring full VF compliance increases this 100% check may be difficult to sustain. We make further comment on this later, under Checking assessment quality.

2.75 We conclude that RBK had effective processes in place for its initial phase of VF, covering the authentication of evidence, evidence collection and recording an audit trail. However we suggest staff who become involved at the later stages of implementation are given refresher training and made aware of their responsibilities regarding collecting, authenticating, recording and cross-checking evidence.

Verification prior to April 2002

2.76 As our visit commenced late March 2002 our testing of RBK’s verification performance concentrated on its processes prior to VF implementation.

2.77 When doing so however we did not underestimate the huge task RBK management and staff had faced when the service was brought back in-house in February 2000. We were told that a backlog of protracted and very complex claims was inherited.

2.78 It was to RBK’s credit that as well as tackling these protracted and complex cases it developed at the same time new verification guidance. We were told that this was an attempt to balance speed of processing with a greater emphasis on quality.

2.79 The guidance issued in October 2000 included:

· evidence to be collected for new claims

· evidence to be collected for renewal claims, but this was less stringent

· a list of acceptable evidence that could be used to support identity.

2.80 It met VF requirements in most elements of claim verification except in areas such as:

· capital, where only the current balance was required

· IS or income-based Jobseeker’s Allowance (JSA(IB)) linked claims, where no evidence was required to prove on-going entitlement for renewal claims.

2.81 To help us comment on RBK’s performance in respect of gathering evidence and processing claims we sampled 30 new and 30 renewal claims. These were selected from all claims decided during the quarter ended December 2001. A breakdown of these claims is shown in Figure 2.6.

Fig. 2.6: Breakdown of sampled claims
Type of claim	Standard	IS/JSA	Total
New RA	7	8	15
New RR	5	10	15
Renewal RA	6	6	12
Renewal RR	8	10	18
Total	26	34	60

Source: BFI analysis

2.82 In determining how strong its performance was in terms of securing the gateway to HB and CTB we tested all cases against VF standards as well as RBK’s own guidance so that we could identify any gap between them.

2.83 Overall RBK collected sufficient evidence as defined in its own guidance in a total of 48 (80%) cases. However when measured against the VF only 32 (53%) cases met that standard. The difference could be explained, in part, by the more stringent standards of VF.

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2.85

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Source: BFI analysis

2.86 Although all 6 cases adhered to RBK guidance in gathering evidence it demonstrates that much more thought must go into the scrutiny of evidence as required in the VF. This is an essential part of the verification process to secure the gateway which RBK must ensure is carried out.

2.87 In summary 80% of the cases we sampled complied with RBK’s own verification guidance and that with the use of greater intelligence they could have been closer to VF standard. Nonetheless there was non-compliance with its own guidance in 12 (20%) cases and this must be of concern to RBK.

2.88 We analysed these 12 cases but there were no trends and the failures occurred over most elements of the claim. Figure 2.8 outlines the number of comments we made in these cases.

Fig. 2.8: BFI comments on verification failures
Claim element	New claims	Renewals
Identity	3	0
Rent liability	2	3
IS/JSA	2	0
Income	4	2
Capital	1	0
Total	12	5

Source: BFI analysis

Recording of evidence

2.89 As part of RBK’s own procedures evidence and information should have been documented on a summary sheet. However staff told us, and our sampling confirmed, that this summary sheet had not been used for some time and in most cases had not been used at all. Where it had been used it provided a valuable audit trail.

2.90 In recognising the merits of this form RBK told us that they had relaunched it in April 2002 and were using it to record all activity on claims subject to full VF checks.

2.91 In the following paragraphs we detail RBK’s performance in verifying the individual elements of a claim and its performance on making intelligent use of the information it gathers.

Verifying NINO and identity

2.92 Since 6 September 1999, sub-sections 1(1A) and 1(1B) of the Social Security Administration Act have applied to claims for HB and CTB. This requires a claimant and any partner included in a claim to provide:

· a statement of their National Insurance number (NINO) and information or evidence establishing that the number has been allocated to them, or

· information or evidence enabling the NINO allocated to them to be ascertained.

2.93 RBK’s old procedures in this important area required the same standard of evidence as those required for VF.

2.94 Our analysis of RBK’s claim forms at Appendix B shows that none of the forms used during the period from which our sampling was selected requested evidence to establish identity. Despite this claim form failure, by actively pursuing the appropriate evidence, RBK were fairly effective in this area. Figure 2.9 outlines our findings.

Fig. 2.9: Verifying NINOs and identity of claimants and partners in sampled new and renewal claims
Type of case	Number of cases requiring verification	Cases where evidence as per VF held on file
		Number	%
New claims – claimant	30	28	93
Renewal claims – claimant	30	30	100
Total claims – claimant	60	58	97
New claims – partner	4	3	75
Renewal claims – partner	5	5	100
Total claims – partner	9	8	89

Source: BFI analysis

2.95 RBK fully verified the claimant’s NINO and identity in 97% of the cases we examined and partner’s NINO and identity in all but one case.

2.96 We found that in all cases where identity had been established RBK had collected and considered evidence in line with its guidance. Combinations of evidence used included:

· bank statements

· benefit payment books

· birth certificates

· driving licence

· passport – current and valid

· utility bills – paid in the person’s name for last quarter

· payslips

· Remote Access Terminal (RAT)

· Jobcentre Plus notices.

Verification failures

2.97 In one case, from a boarder, the identity was established for neither the claimant nor partner. The only evidence collected in the entire claim was a stencil completed by Jobcentre Plus confirming a previous award of JSA(IB). It is a requirement of the regulations that when a claimant states their NINO they are also required to provide evidence that the NINO was allocated to them. There was no such evidence in the claim papers. The partner’s NINO was not quoted on the claim form and RBK took no action to confirm if one had ever been issued.

2.98 In the second failure RBK had collected a tenancy agreement and IS and Child Benefit order books. However the identity details contained on the front cover of the order books had not been photocopied or scanned into the data image processing system. We did not consider that, on its own, the tenancy agreement provided sufficient evidence to establish identity.

2.99 In summary, of the 60 cases sampled there were only 2 cases where there was insufficient evidence on file to establish identity. There is scope to improve the audit trail by ensuring that the existing evidence summary sheet is used in all cases. As reported earlier RBK has accepted this finding and has reintroduced this process.

Verifying liability to pay rent

2.100 Section 130(1)(a) Social Security Contributions and Benefits Act 1992 provides that a person is entitled to HB if:

he is liable to make payments in respect of a dwelling in Great Britain which he occupies as his home;

Similarly, section 131(3) Social Security Contributions and Benefits Act 1992 provides, for CTB,

The main condition for the purposes of subsection (1) above is that the person concerned -

(a) is for the day liable to pay council tax in respect of a dwelling of which he is a resident;

2.101 These sub-sections mean that, before RBK can award benefit, it has to be satisfied both as to the residency and liability to pay. It is important to remember that these are separate statutory requirements.

2.102 VF sets out the sort of information and evidence that should be gathered and cross checks that should be carried out to help confirm rent and residency.

2.103 We have commented at Appendix B on the claim form in use during the period of our sample. In the area of residency and rent liability it requested in full 6 of the 11 VF requirements but did not collect the remaining 5, which included:

· the date the claimant moved into the address and the date the tenancy commenced

· previous address

· type and period of tenancy

· other joint tenants and the claimant’s share of the rent

· details of a main home somewhere else.

2.104 Figure 2.10 outlines our findings from the 60 HB cases we examined.

Fig. 2.10: Verification of rent liability
Type of case	Number of cases requiring verification	Cases where evidence as per VF held on file
		Number	%
RA new claims	15	13	87
RA renewal claims	12	9	75
RR new claims	15	15	100
RR renewal claims	18	18	100
Total	60	55	92

Source: BFI analysis

2.105 The duty to verify rent liability in new and renewal claims is exactly the same. However our sampling revealed that RBK’s performance in verifying rent liability in RA cases was not as effective in renewal claims as it was in new claims. Overall RBK fully verified rent liability in all RR cases and in 81% of RA cases.

2.106 Guidance in this area was clear and concise. For RA claims staff were instructed to obtain either a formal tenancy agreement or a letter from the landlord. In addition their guidance specified what the evidence had to show. This was in line with VF and was as follows:

· the full name and business address of the landlord

· the date the agreement started

· the amount of rent payable

· services included in the rent

· the payment period or frequency.

2.107 In addition RBK required proof of rent payment in the form of a rent book, rent receipts, rent statements or the last 3 months’ bank statements showing rental payment by direct debit or standing order.

2.108 Rent liability had been confirmed in all RR cases through the rent account. When creating a new claim to RR, users were required to access the rent account to obtain the rent reference number which was then input to the benefit system. The electronic interface between the 2 systems would not allow the user to proceed to build the claim if there was no rent liability. The process was identical for the CTB and Council Tax system.

2.109 RBK had gathered proof of rent liability in all but 2 new RA claims. The evidence gathered for the 13 cases complied with both VF and RBK guidance and was as follows:

· tenancy agreement in 6 cases

· letter from landlord in 7 cases.

2.110 In the 2 cases where rent liability was not fully evidenced RBK had collected evidence but had not fully scrutinised it. Had it done so it would have determined that neither the tenancy agreement collected in case one or the letter from the landlord collected in case 2 detailed the services included in the rent.

2.111 RBK had gathered proof of rent liability in 9 out of the 12 renewal RA claims we sampled. The evidence gathered for the 9 cases complied with both VF and RBK guidance and was as follows:

· tenancy agreement in 7 cases

· letter from landlord in 2 cases.

2.112 In the 3 cases where rent liability was not fully confirmed RBK had collected evidence but only in the form of rent books in 2 cases and a bank statement showing a standing order to a landlord in the third.

2.113 None of these documents confirmed the necessary details as defined in the VF or RBK’s own guidance. Additionally there was no record of a tenancy agreement or a letter from a landlord having been provided for any of the previous claims.

2.114 We conclude that the RA claim form lacked clarity for claimants in terms of specifying what details had to be included for evidence of rent liability. These failings will however be addressed by RBK’s new claim form used for new claims from January 2002 and planned for renewal claims due from August 2002.

2.115 Guidance in this area was clear and staff effectively collected in most cases the type and range of evidence that was required to verify rent liability. However RBK needs to ensure that acceptable evidence of rent liability is collected and scrutinised for all RA claims by reminding staff of the guidance in this area.

2.116 Establishing rent liability does not prove residency. The best method for this is by visit. RBK plans to start home visits to check residency from June 2002.

Verifying IS and JSA(IB) entitlement

2.117 HB Regulations (Schedule 3, paragraph 10; Schedule 4, paragraph 4; Schedule 5, paragraph 5) prescribe that, where the claimant receives IS or JSA(IB), the LA must disregard a claimant’s earnings, income and capital. There are identical provisions in the CTB Regulations.

2.118 However, it is essential in all IS/JSA(IB) linked cases that the LA confirms the claimant’s IS/JSA(IB) entitlement.

2.119 We sampled 18 new and 16 renewal cases where the claimant was said to be in receipt of IS or JSA(IB). Figure 2.11 outlines our findings.

Fig. 2.11: Verification of IS/JSA(IB) entitlement
Type of case	Number of cases requiring verification		Cases where evidence as per VF held on file
			Number	%
New claims		18	15	83
Renewal claims		16	13	81
Total		34	28	82

Source: BFI analysis

2.120 RBK fully verified IS/JSA(IB) entitlement in 82% of cases we examined. There was little difference between its performance in new and renewal claims.

2.121 Figure 2.12 details the verification failures in this area.

Fig. 2.12: Failures relating to the verification of IS/JSA(IB) entitlement – identified from new and renewal samples
Type of failure	Number of new claims	Number of renewal claims
Insufficient evidence collected	1	3
Jobcentre Plus award notice did not show date entitlement to IS commenced	1	--
Scanned copy of IS OB did not show identity details	1	--
Total	3	3

Source: BFI analysis

2.122 Of the 6 cases that failed to meet VF standard, 3 related to the issue of RBK not requiring confirmation of ongoing entitlement to IS/JSA for renewal claims. This has been addressed in RBK’s new VF guidance.

2.123 More importantly the remaining 3 cases that did not comply with VF related to confirmation of IS/JSA at the outset of a claim.

2.124 Staff were instructed, in RBK’s guidance, that to confirm IS/JSA(IB) entitlement for new claims they had to collect the following:

· IS order book

· DWP award letter – less than 8 weeks old

· IS/JSA(IB) system print (NHB3).

2.125 A RAT enquiry was not included in this list and we only saw one case in our sample where a RAT enquiry had been used to confirm IS/JSA(IB). We consider a RAT enquiry to be a better form of evidence in this area as not only does it confirm IS/JSA(IB) entitlement at the start of the award but in the absence of NHB3 system prints it can be checked to ensure that the HB and CTB indicators have been set to facilitate the effective exchange of information with Jobcentre Plus. Had RBK considered its use in the 3 new claims above, verification failures could have been avoided.

We recommend that RBK amends its guidance to inform staff that it is best practise to verify IS/JSA entitlement by using an NHB3 or, in its absence, checking by RAT.

If staff follow this practice the period of entitlement can be confirmed and the Jobcentre Plus system checked to ensure that the HB/CTB indicators are set. This will help RBK get the payment correct in the first instance and it will also help it keep that payment correct thereafter.

2.126 RBK confirmed IS/JSA(IB) entitlement, in line with its own guidance, in 32 (94%) of 34 cases. By incorporating the changes we have recommended above it will ensure a better performance against VF standards.

2.127 We detail the type of evidence obtained for those claims in our sample where entitlement had been confirmed in Figure 2.13.

Fig. 2.13: Evidence used to confirm entitlement to IS/JSA(IB)
Evidence type	New claims	Renewal claims
NHB/ETD system prints	9	0
RAT	0	1
DWP award notice	5	2
IS order book	1	10
Total	15	13

Source: BFI analysis

2.128 We have commented earlier in this section that it is not sufficient for an LA to mechanically collect evidence. To ensure that it is securing the gateway it must also make intelligent use of all evidence available to it.

2.129 Regulations and the VF instruct an LA that if it suspects that a claimant is not entitled to IS or JSA(IB), it should consider suspending payment of benefit under HB and CTB (Decisions and Appeals) Regulations 2001 and refer the matter to the Jobcentre Plus for its decision.

2.130 We found 2 cases in our sample where entitlement to IS/JSA(IB) had been confirmed but where the claimant had produced bank statements which detailed unexplained credits. In both cases the credits amounted to a substantial sum and indicated the possibility of an additional income. As such both these cases should have been referred to DWP.

We recommend that RBK amends its guidance to include:

· the requirement to fully scrutinise bank statements when provided in IS/JSA(IB) cases for unexplained credits and possible additional income

· the action required in such cases to follow up any discrepancies identified

· the requirement to document the outcome of such enquiries.

If it does this RBK staff will be more aware of the need to view a claim holistically and not simply mechanistically.

Verifying income

2.131 If an HB/CTB claim is not linked to IS or JSA(IB) entitlement, the LA must verify income.

2.132 RBK’s claim forms used at the time of our sample were poor in the area of requesting information on income. They failed to collect more than half of VF requirements in the area of earned income, DWP benefits and any other income. However its new claim form addressed these weaknesses.

2.133 We outline our findings from the standard claims we examined in Figure 2.14.

Fig. 2.14: Verification of income
Type of case	Number of cases requiring verification	Cases where evidence as per VF held on file
		Number	%
New claims	12	4	33
Renewal claims	14	12	86
Total	26	16	62

Source: BFI analysis

2.134 This figure shows that overall RBK fully verified income in line with VF standards in 16 (62%) of a total of 26 cases. However of the 10 cases that failed to meet VF standards, 4 complied with RBK’s guidance. Overall it verified income in line with its own guidance in 20 (77%) cases.

2.135 In the 10 cases that failed to meet VF standards we did not identify any trends and could only attribute the deficiencies to either human error or not making best use of the evidence gathered, particularly in the scrutiny of bank statements for regular income. There were, however, 2 significant issues which RBK needs to address.

2.136 Firstly, RBK’s guidance needs to be specific on the use of payslips required to verify earned income. Rather than requiring the most recent payslips the guidance should specify that they should cover the period immediately prior to the claim.

2.137 Secondly, RBK needs to decide which grade of officer has responsibility for deciding that all reasonable effort has been made to establish the facts of a claim. Figure 2.15 outlines a short description of one such case.

Fig. 2.15: Case study 3 – Where insufficient evidence collected to verify income

In this new claim from a single parent, the income was declared as WFTC, Child Benefit and maintenance. WFTC and Child Benefit were evidenced by order books. Additionally an NHB3 in the case showed that IS had been claimed from 02/11/01 but that income exceeded requirements. The claimant’s partner had refused to confirm the amount of maintenance in payment and the benefit officer had accepted the claimant’s statement as sufficient evidence of maintenance. The VF states The DWP recognises that there may be individual cases where full compliance with the requirements of the VF is not possible. In such cases the LA must be able to demonstrate that it has made all reasonable effort to establish that the facts are more likely than not to be as stated by the claimant on their application form. In any case where the level of verification will fall short of that required by the VF, the LA must record its reasons for accepting the lower standard of evidence. The LA must consider each such case on an individual basis and not apply blanket exemptions. BFI comment We consider that RBK should have made further enquiries in this instance. A crosscheck could have been made with DWP to ascertain what maintenance had been declared to them and additionally what evidence was provided. Additionally, the fact that the partner was unwilling to confirm this maintenance should have raised some concern regarding the validity of the claim and the possibility of fraudulent activity. Importantly however we do not consider that the decision on all reasonable effort should sit with the benefit officer.

Source: BFI analysis

We recommend that RBK amends its guidance to:

· include, that where acceptable evidence to VF standard cannot be provided:

- staff discuss the issue with their group manager or assistant group manager

- the outcome of such a discussion is fully documented in the case

· specify that to verify earned income, payslips are required for the appropriate period, for example 5 weeks or 2 months immediately prior to the claim.

If it follows this practice RBK will tighten further its security of the benefits gateway by complying fully with the minimum VF standards.

Verifying capital

2.138 In cases where an HB/CTB claim is not linked to IS or JSA(IB) entitlement, the LA must verify capital to establish if any capital held exceeds the prescribed amount.

2.139 RBK claim forms were weak in the area of capital. They did not require the claimant to answer ‘Yes or No’ as to whether they, their partner or dependants had any bank, building society accounts or any other form of capital. Instead they asked the claimant to list any ‘monies, savings and investments’ they or their partner had. Additionally they did not collect, in full, any of the VF requirements.

2.140 In the 26 standard cases we examined we found the following:

· 17 claimants declared capital and savings

· 7 claimants did not declare any capital or savings

· 2 claimants did not declare any capital or savings but evidence suggested otherwise.

2.141 RBK should have confirmed capital in a total of 19 cases. Overall it fully confirmed capital in line with its own guidance in 18 (95%) of a total 19 cases but in line with VF it confirmed only 6 (32%) cases.

2.142 RBK’s guidance detailed acceptable evidence of capital. Specifically statements were required to evidence bank, building society and post office accounts for both new and renewal claims. They were required to show the current balance and be no more than 3 months old. Acceptable evidence to confirm all other forms of capital were listed, however further evidence was not required for renewal claims where the amount declared on the form had not changed from that declared on the previous application.

Cases where capital declared

2.143 We found that of the 17 cases where capital had been declared RBK had collected evidence as defined in its guidance in 16 of them. In the remaining one claim it had failed to collect any evidence of capital at the date of assessment, but had collected it at a later date. However its performance was poorer when compared to VF standards.

2.144 Figure 2.16 outlines our findings in the cases where capital was declared.

Fig. 2.16: Verification of declared capital
Type of case	Number of cases requiring verification	Cases where evidence as per VF held on file
		Number	%
New claims	7	1	14
Renewal claims	10	5	50
Total	17	6	35

Source: BFI analysis

2.145 This poor performance, in declared capital, can be attributed entirely to the fact that RBK did not require bank statements covering at least a 2 month period. However we have illustrated earlier in this section that it is not sufficient to check only the balance of accounts. In our sample we found 4 cases where the transactions shown on bank statements indicated the possibility of an additional income.

2.146 RBK’s new guidance for VF addressed these issues and specified that bank statements must cover a period of at least 2 months and that staff should check for unexplained credits and transfers.

Cases where no capital declared

2.147 Of the 9 cases where no capital was declared there were 2 cases that should have prompted further enquiry. In one claim the questions on capital had not been answered but bank statements had been provided. These bank statements did not cover a period of at least 2 months.

2.148 In the other case, in our sample of renewal claims, capital had not been declared on the current claim but had been declared and confirmed in the previous claim. The payslips provided also indicated the existence of a bank account. RBK had failed to make further enquiries on this discrepancy.

We recommend that RBK amends its guidance to include:

· the requirement to fully scrutinise all payslips for possible undeclared bank accounts

· the action required in such cases to follow up any discrepancies identified

· the requirement to document the outcome of such enquiries.

We recommend that RBK amends its guidance to ensure that information and evidence provided for a renewal claim is checked against those given in the previous claim.

If it follows this practice RBK will consider claims more holistically and not as a mechanical process.

Non-dependants

2.149 HB and CTB are normally reduced for each non-dependant normally living with the claimant. Regulation 63 of the HB Regulations and regulation 52 of the CTB Regulations set out whether a deduction needs to be made. The amount of any deduction depends upon the circumstances of the non-dependant and, if they are in remunerative work, their gross income. If no information is given other than presence of the non-dependant, then the LA must apply the highest rate.

2.150 Under the VF LAs must get evidence of a non-dependant’s income wherever possible. We found only one case in our sample where a non-dependant had been declared and in that case the income had been properly verified.

Rent Officer referrals

2.151 Regulation 12(A) of and Schedule 1A to the HB Regulations require LAs to refer certain RA claims to the rent officer (RO) to determine the level of rent eligible for HB. The law also provides for LAs to apply, at the claimant or potential claimant’s request, for pre-tenancy determinations (PTDs).

2.152 RBK had agreed and signed a Service Level Agreement (SLA) TRS on 14 February 2002. This was based on the national model and set out the quantifiable targets, monitoring arrangements and some local agreements on referral forms and telephone access. As specified in the SLA, RBK had a nominated liaison officer who attended the quarterly meetings.

2.153 Staff we spoke to were aware of the SLA with TRS and that any problems with referrals could be reported to the liaison officer who would raise and discuss them at the quarterly meetings.

2.154 However despite agreeing to quarterly monitoring RBK reported that no monitoring activity had been carried out and that it had no plans to do so. The only control RBK had in place was an IT system spreadsheet on which it simply recorded the numbers of RO referrals issued and returned.

2.155 As well as the general requirement to refer most deregulated private sector tenancy claims, paragraph 3 of Schedule 1A to the HB Regulations requires LAs to refer HB claims from HA tenants to the RO where they consider:

· the claimant and other members of the household are living in accommodation that is too large for their needs; or

· the rent paid for the accommodation is unreasonably high.

2.156 RBK’s RO referral policy for HAs complied with these regulations. In our sample of 27 RA claims we identified 13 housing association cases. Although RBK had not made a referral to the RO in any of these cases its policy had been correctly applied given that the HA accommodation was neither unreasonably expensive nor larger than that required by the claimant.

2.157 Figure 2.17 outlines our findings in the 13 claims where an RO referral was appropriate.

Fig. 2.17: Requesting RO determinations – in sampled RA cases
Type of case	Number of cases requiring RO determination	Cases where RO determination was obtained
		Number	%
New claims – other landlords	7	7	100
Renewal claims – other landlords	6	6	100
Total	13	13	100

Source: BFI analysis

2.158 Our findings showed that RBK’s performance in this area was good and that a referral had been made to TRS in all appropriate cases.

2.159 Regulation12A(3) of the HB Regulations require LAs to refer RA claims within 3 working days of receipt or as soon as practicable thereafter. RBK had signed up to meeting referral targets in the SLA. Using the cases in our new claims sample we tested its performance against this target. The following figure outlines our findings.

 

Fig. 2.18: Achievement against SLA targets
	Target	Number where target achieved
Referrals to RO within 3 working days	75%	0
Referrals to RO within 5 working days	95%	0

Source: BFI analysis

2.160 These figures clearly demonstrate that RBK had some way to go to achieve the targets it had agreed to in the SLA. None of the 7 cases was referred to TRS within 3 or 5 working days, the average delay for referral was 30 days with a range from 8 to 57 days.

2.161 In terms of legal requirements RBK only referred 2 (29%) cases as soon as practicable thereafter. In the remaining 5 cases it had taken initial action on the claims before eventually referring to TRS. In 2 of these cases referrals were not made until the date of decision.

2.162 These results were not surprising as staff were unsure when a referral should be made. Staff told us that practices included:

· refer as soon as possible

· refer only after a tenancy agreement had been produced

· refer only after all evidence has been provided.

2.163 Importantly RBK guidance incorrectly advised staff to await a tenancy agreement before referring to TRS.

2.164 The existing practices and processes will not only affect the interface with TRS they may also contribute to processing delays, avoidable payments on account and any additional work required as a result of such payments.

We recommend that RBK:

· revises its processes and procedures to ensure that cases are referred to the RO within the time limit set out in the regulations

· makes staff aware of these revised procedures

· monitors the quantifiable targets defined and agreed in the SLA with TRS.

If it does this staff will know what they must do in this area and RBK will be able to identify any remedial requirements from its checking.

2.165 By undertaking quarterly monitoring, as defined in the SLA, RBK would have important management information available. This can be analysed to identify:

· if any changes or additions are required to procedural guidance

· any remedial training needs.

2.166 Performance targets and monitoring are discussed in full later, under Making sure the strategy works. RBK has to ensure that staff are aware of the targets contained in the SLA.

We recommend that RBK includes the TRS targets in its benefits business plan. By doing so RBK will ensure that:

· staff are aware of their existence and the standards they contain

· achievement against them can be monitored.

Accuracy of data inputting for assessments

2.167 Having tested the thoroughness of RBK’s verification process in terms of the completeness and reliability of evidence gathered, we moved on to examine how accurately RBK used this evidence.

2.168 We found 2 cases where acceptable evidence had been gathered but where RBK had failed to use all the information and evidence available to it when processing the claim:

· a single parent’s income with earnings and WFTC but only the WFTC was input to the benefit system

· a claim for a new tenancy was awarded from the date the tenancy started. This was incorrect as the claim was received later than the week in which the tenancy had actually commenced.

2.169 In addition we found in our sample of 60 cases that there were 11 cases where claims had been determined on claim forms that had not been fully completed. RBK can have no assurance that in these cases the assessment accurately reflected the claimants’ true circumstances. RBK’s revised verification procedures make staff aware of the requirement for full completion of claim forms in all cases and the process to follow to ensure this.

Checking assessment quality

2.170 The Audit Commission (AC), in its publication Countering Benefit Fraud – A Management Handbook, recommends that LAs quality check at least 10% of claims. Checks should cover all activities, including new claims, renewal claims and changes of circumstances. Checks can be used to gauge performance standards, and identify training needs.

2.171 The Revenues & Benefits Service Team Plan for 2000/01 showed that the 5% quality check planned for October 2000 had been put in place. However we found that only 2 of the 3 benefit groups had implemented the checking from that date.

2.172 In recognising this, RBK relaunched its management checking programme from 27 February 2002, with a view to ensuring consistency across the 3 groups. The check was extended to include pre and post payment checks and was selected as follows:

· 5% of all closed and diaried activity in the DIP work management system

· 5% of all calculations on benefit administration system.

2.173 RBK told us the cases selected from both sources were checked for procedural and financial error.

2.174 During our on-site visit we examined the records for checks undertaken by the 3 benefit groups. Specifically we looked at:

· how cases were selected for checking

· what the checking process involved

· the outcome of these checks.

We outline our findings in the following paragraphs.

Selection of cases for checking

2.175 The IT and Control section issued 2 separate weekly reports for each benefit group which listed the work done by individual benefit officers. The cases for checking were identified by selecting one case from every 20. This approach was to ensure a balance between each benefit officer as opposed to a balance of work types. In one group the manager selected the checks, whilst in the other 2 the assistant group managers selected them.

2.176 It was unclear from RBK’s records which cases had been identified from the benefit administration system or the DIP system. Consequently RBK had no management assurance that the required percentage of cases had actually been identified.

2.177 Additionally, the check records showed 463 cases had been identified during the 5 week period from 27 February to 31 March 2002, only 269 cases had been checked.

2.178 To put that figure in context we looked at the number of HB decisions and changes of circumstances decided by RBK in the quarter ended March 2002. The numbers involved are shown in Fig 2.19.

Fig. 2.19: HB decisions and changes of circumstances processed during quarter ended March 2002
Type	Number
New claims	977
Renewal claims	1,513
Changes in circumstances	2,043
Total	4,533

Source: RBK

2.179 To follow AC guidelines, RBK should have undertaken at least 453 checks during the quarter ended March 2002. We cannot give an exact figure as RBK could not isolate and identify the number of CTB only cases.

2.180 Given that the revised management checks did not start until 27 February 2002 we estimate that for RBK to check 10% of claims it should have checked at least 174 cases during the 5 week period to the end of the quarter. It had in fact checked 269 cases during this period. The issue for RBK however is that had it actually checked all the cases that had been identified the total would have been 453. This figure appears high and may well indicate that RBK has set itself too high a target in checking 5% of the activity on the DIP system.

2.181 By recording the cases selected from each source separately RBK would have been able to compare the figures from each. Whilst we accept that checking cases from DIP may allow a timely intervention to progress a case to decision, RBK has to consider the merits of checking the numbers required to meet the 5% DIP system target against the benefits and improvements such numbers bring.

2.182 To meet the 10% claims target RBK should select 5% of cases from the benefit administration system report and the same number, not percentage, from the DIP report. By comparing the numbers selected in this way with the numbers that would have been selected to meet the 5% DIP requirement RBK could gauge whether its current target is too ambitious.

2.183 RBK implemented its revised checking programme in February 2002 but had no formal reporting process in place. As a result it had no management assurance that the required number of checks had been identified or carried out.

We recommend that group managers take overall responsibility for management checks and that each manager should:

· maintain an audit trail of all reports received from IT and Control section listing activity on DIP and calculations on the benefit administration system

· select cases to be checked proportionate to the claims activity on the benefit administration system report

· delegate checking activity to assistant group managers

· ensure that all cases are checked within 7 days

· report weekly to the Revenues and Benefits manager on numbers checked against numbers selected.

If it does this RBK will have greater assurance that its management checking regime is being operated as designed.

Checking process

2.184 RBK had developed guidance which instructed the assistant group manager to check all aspects of the claim relating to that particular decision. A checking sheet had also been developed which supported this guidance and listed a range of 95 attributes, some of which had to be considered, depending on the work type being checked. In addition there was an explanation for each attribute as to what and how it should be checked.

2.185 The assistant group managers told us that whilst they used this as a checking list, contrary to the guidance, they did not complete a sheet for every case, as it had proved to be time consuming. Instead they completed a schedule known as the 10% checking sheet, on which they listed the following:

· benefit officer who had actioned the case

· work type being checked, for example new claim

· whether the calculation was correct or incorrect

· whether or not correct procedures had been followed

· comments

· whether referred back to benefit officer or not.

2.186 Each sheet, which could list up to 28 checks, was then signed by the checking officer to certify that the cases had been checked in accordance with the procedures.

2.187 The group manager does not check the checking records or any of the cases that have been checked to establish that the check had been done to the required standard and at the right time. RBK therefore had only limited management assurance that all aspects of the claim had been properly checked and that there was a consistent approach across the 3 sections.

2.188 More importantly however RBK has to consider if the extent of its check is too broad and whether it would be beneficial to target its resources on problem areas it has identified along with weaknesses identified in this report. This is particularly relevant in the area of verification when the 100% check on VF cases ceases.

We recommend that RBK revises its approach to management checks and:

· issues comprehensive guidance to assistant group managers as to what has to be checked

· amends the checking list and ensures completion for all cases checked.

If it does this RBK will ensure consistency of approach across its management checking regime and importantly identify issues or areas that would benefit from more specific targeting of checks.

2.189 Additionally for assurance RBK should ensure that the check carried out fully complied with guidance.

We recommend that the group manager re-perform the checks on a small percentage of the cases already checked by their assistant.

Outcome

2.190 Feedback was given to individual officers only if an error had been identified and the case required amendment. In that instance the officer was required to do the necessary amendments and notify the checking officer when they had been done.

2.191 When the checks were completed for each week the assistant group manager analysed the outcomes and documented the number and percentage of calculation errors and procedural errors.

2.192 There was no formal analysis or summary of the types of errors that had occurred. However group managers and their assistants told us that they would be aware of any trends and either notify all staff by e-mail or discuss them at the team meetings.

2.193 They cited 2 examples of trends that had been identified through management checking:

· staff were applying a change of circumstances without due regard to the changes in regulations effective from July 2001. This resulted in additional guidance being issued

· the standard of language used in general communication with the public was found to be inconsistent. As a result most staff have attended a Plain English training course.

2.194 Details of the checks undertaken were confined to individual teams, figures were not collated for RBK as a whole nor were they reported to the Revenues and Benefits manager.

We recommend that:

· assistant group managers analyse the completed checking lists to identify the types of errors found and their frequency

· RBK extends its summary report to include this information

· group managers use the summary report and collate figures for all groups. The findings for the individual groups and benefits as a whole should form part of a weekly management report to be discussed at the benefits management team meetings and fed back to benefit staff.

If it does this RBK will be able to learn more from error trends, and if the outcome of the summary analysis is reported to the Revenues and Benefits manager, his knowledge of performance in the benefits area will be greatly improved.

2.195 The only accuracy figures reported to RBK management were those identified from the DWP Stats 128. For the quarter ended December 2001, the period from which our sample was selected, RBK checked a total of 117 cases, of which 112 were correctly calculated. This equates to 96% accuracy. The local RBK target in this area is 97% but its BV target is 90%.

2.196 We applied RBK’s checking criteria to the cases in our sample of 60 cases. In particular we identified cases where:

· the claim form had not been fully completed

· an element of the claim had not been fully evidenced in line with RBK’s verification guidance

· the accuracy of the award was either fully or partially incorrect.

2.197 We found that a total of 17 new claims and 6 renewal claims had failings in one or more of the 4 areas. Of these 23 cases 3 could be immediately categorised as financial errors. When we compare this to our total sample of 60 cases, this would equate to an accuracy level of 95% which is broadly in line with RBK’s reported figure. However, the 20 procedural errors were, in the main, a result of insufficient verification and as such required further enquiries. The outcome of these further enquiries may well result in an increased number of financial errors and therefore a reduced accuracy level.

Dealing with vulnerable people, including the homeless

2.198 We reported earlier that RBK visit elderly and infirm people or others who need help with their claim. In this section, we report on how RBK deal with the homeless.

2.199 Under the Housing Act 1996 Part VII, LAs are responsible for providing accommodation for certain people who become homeless. Handling claims from homeless people effectively and efficiently needs close working relationships between housing staff and benefits staff.

2.200 The vast majority of homeless people accommodated by RBK are in receipt of HB. RBK provide accommodation for homeless people in 3 ways. These are:

· bed and breakfast through private landlords (B and B)

· council owned hostels

· private leasing scheme (PLS), operated by the private leasing section in RBK.

Bed and Breakfast

2.201 When a person becomes homeless, RBK, through its homeless unit usually provide bed and breakfast accommodation in the first instance, while the homeless claim is investigated. This accommodation is temporary, and HB covers charges, excluding services and breakfast. RBK told us that this charge is currently £207.64 per week, with the claimant responsible for service and breakfast charges.

2.202 The unit monitors occupancy in these cases by requiring the claimant to sign a form daily confirming residency. These forms are controlled by the B and B owner, and passed to the Homeless Unit weekly. A member of staff within the unit checks the signatures on the forms.

2.203 There will always be a risk that the business interests of some landlords may be confused with residency and rent liability. RBK have recognised this and their daily check of signatures will go some way to help manage the risk. Additionally the Homeless Unit undertook a programme of residency checks of all properties in the year ending 2001/02. They were unable to provide BFI with a list of visits and outcomes but did tell us that they came across few cases of non-residency. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX X.

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX X.

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX 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.

Council owned hostels

2.204 If rooms are available in one of 3 RBK owned hostels, the homeless person or family may be accommodated there. Resident wardens who control room occupancy also manage the hostels.

2.205 Accommodation charges are paid by HB in appropriate cases. We were told that charges ranged from £24.40 to £74.39 per week. The homeless person is personally responsible for any additional service charges.

Private Sector Leasing

2.206 RBK operate a private sector leasing scheme to accommodate homeless persons. This facility is run by a team of 7 officers, including 2 temporary agency staff, and is managed by a part-time, temporary unit manager.

2.207 RBK advertises for privately owned properties, and then takes on the role of landlord. If the property is acceptable to RBK, a 12 month contract is agreed with the owner. This contract guarantees payment of a negotiated weekly rent for 12 months, whether the property is occupied or not.

2.208 There are some risks for RBK in administering this scheme. This is particularly so if vacated properties are not be re-occupied quickly. Additionally costs may be incurred when making good any damage to properties. On the positive side the risk of rent arrears is low given, we are told by RBK, that over 90% of tenants are in receipt of HB.

2.209 Vacated properties are notified to the benefits section as appropriate on a weekly basis via the rent account computer system, and processed by a nominated officer in the benefits section. This is good practice.

2.210 Weekly costs are negotiated between RBK and the owner of the property, and are based on a range of acceptable charges. RBK’s Community Services Directorate Accountancy team in turn calculates the annual rent to be charged to the tenant on a weekly basis.

2.211 RBK told us that the level of rent set is consistently charged to tenants, regardless of their benefits status. So that a recipient of HB and a non-recipient of HB would have to pay the same rent for a given property. Records provided by RBK showed that weekly rents ranged from £135.14 for a studio to £358.34 for a 4 bedroom house.

2.212 DA told us that they follow the AC grant instructions when auditing this aspect of the claim. In the year 2000/01 they tested 9 cases and confirmed that all were properly categorised in accordance with the threshold levels.

2.213 Although all PLS properties were visited by the LA during 2001/02 and tenants interviewed to confirm residency RBK told us that this was a one-off exercise. They were unable to provide BFI with a list of visits and outcomes but did tell us that they came across few cases of non-residency. XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX .

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX XXXX XXXX XXXX XXXX XXXX .

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX.

Speed of processing

2.214 Regulation 76(3) of the HB Regulations prescribes that all claims shall be determined within 14 days of the relevant evidence and information having been received or as soon as is reasonably practicable thereafter. There is an identical provision at regulation 66(3) of the CTB Regulations.

2.215 Figure 2.20 shows RBK’s reported performance in new and renewal claims over the past 3 years.

Fig. 2.20: Percentage of new and renewal claims processed within 14 days
	1998/99	1999/2000	2000/01
HB	78	75	68
CTB	78	77	71

Source: DWP Analytical Services Division (ASD)

2.216 RBK’s claims clearance performance dipped in 2000/01. However this coincides with the period when benefit administration was taken back in-house. RBK told us that during the first six months of that year its 14 day performance slipped considerably due to the backlog of protracted and complex cases it had to clear during that period. RBK’s management information shows that performance improved considerably in the second half of the year.

2.217 RBK’s internal target for 2001/02 was to decide 90% of all claims within 14 days of all information becoming available. We looked at RBK reported figures for the quarter to December 2001, for new and renewal claims, and compared them to the findings from our sample which covered the same period. We detail our findings in Figure 2.21.

Fig. 2.21: Percentage of all claims processed within 14 days of all information becoming available
	RBK reported figure %	BFI sample %
New claims	84	80
Renewal claims	93	90
Total	86	85

Source: RBK MIS and BFI analysis

2.218 Our findings for both new and renewal claims were broadly in line with that reported by RBK and confirmed that its performance in the quarter had improved since last year and was approaching its internal target of 90%.

2.219 RBK’s claims clearance targets, both 14 day and BV, were detailed in the Revenues and Benefits Team Plan for 2001/02. However staff we spoke to were unclear as to what targets RBK had set. Some were only aware of the 14 day DWP target. Others, whilst aware of both targets, were unclear as to which RBK were working to. All reported that RBK’s performance data against targets was displayed on the staff notice board but was not fed back to them directly nor discussed at team meetings.

2.220 In addition, to aid the clearance targets, each benefit officer was set an individual daily target for activity clearance. This target was set each year at the performance appraisal interview and took into account the officer’s experience. This target specified quantity but did not include any quality element at all for the current appraisal year. RBK told us that it had planned to extend individual target to include quality for the year 2002/03, but had not yet done so.

Allocation of work

2.221 RBK controls and allocates all outstanding work using the information on the DIP system. Every piece of work, regardless of type, has a clearance target of 5 days. Assistant group managers, in discussion with the group managers, allocated work on a daily basis to the benefit officers. When allocating work they had to take into account the competing priorities of customer service duties, the number of staff available and their respective experience.

2.222 The BV target for new claims focuses on the average days taken by an LA to clear a claim from receipt of the claim to the date of decision. We examined both new and renewal claims to calculate the average days that RBK took at key stages of the claim process. Figure 2.22 outlines our findings.

Fig. 2.22: New and renewal claims clearance times – stage analysis
	Stages	New		Renewal
		Average days	Range	Average days	Range
1	Date of receipt (at designated office) to date of first action	9	0 – 35	6	0 – 21
2	Date of first action to all information/evidence available	36	0 – 134	15	0 – 37

 

	Stages	New		Renewal
3	Date of all information/evidence available to date of decision	8	0 – 25	7	0 – 32
Overall	Total days (from claim received to date of decision)	48	0 – 177	12	1 – 58

Source: BFI analysis

2.223 For 2001/02, RBK reported that it took an average of 52 days from the day a new claim form was received to the day the claim was decided. Our examination of new claims for the quarter ended December 2001 confirmed improvement towards the end of the year. During this period the average time taken by RBK to process a claim was 48 days, there is however scope for further improvement.

2.224 Whilst the average number of days taken to action cases at stages one and 3 exceeded RBK’s internal target of 5 days, 92% of them were however looked at within 14 days at stage one and 85% them looked at within 14 days at stage 3. This indicated that RBK’s allocation process worked effectively to control claims at both stages one and 3 and had contributed to its improved performance in 14 day clearance. This will provide a solid platform for RBK to improve on its end to end clearance target.

2.225 Significantly the biggest delays occurred at stage 2 (date of first action to date all information available) when RBK were collecting further information or evidence. At this stage clearance time can be influenced by claimant delay but can be controlled by RBK by the issue of:

· clear and comprehensive requests for all further information after initial scrutiny of the case

· timely reminders for requests for information or evidence.

2.226 We have commented earlier in this section that from our sample we found that RBK had to request further information in 87% of new claims and 27% of renewal claims. RBK’s new claim form should help it get more reliable information at the first time of asking.

2.227 In cases where a request for further information is unavoidable, RBK needs to do more to educate and encourage claimants to respond promptly. RBK was aware of this problem in getting prompt replies and to address it, it was advising claimants that they had to provide the information within 3 weeks, although in practice it was allowing 4 weeks for them to reply.

2.228 RBK also needed to ensure that all additional information was sought after initial scrutiny of the claim. The use of the summary sheet should go some way to ensure that all elements of the claim that require verification are considered at the initial stage. Additionally, because RBK could not route work back to the officer who originally worked on it, the summary sheet should also provide an audit trail and a status report for an officer picking the claim up for the first time, thus saving time.

2.229 From our sample of cases we found that on average it took RBK 36 days from the initial request to the date all information was available in the case of new claims and 15 days in the case of renewals. In Figure 2.23 we outline our findings regarding the extent of the delays at this stage.

Fig. 2.23: Delays from initial request for further information to date all information available
Number of days	New claims	Renewal claims
0 – 28 days	10	5
29 – 56 days	12	2
57 – 84 days	2	-
85 days and over	2	-

Source: BFI analysis

2.230 We examined all new claims where the delay at stage 2 was over 28 days. We found from the total of 16 cases, that RBK could have reduced the delay in 9 of them.

2.231 We found 5 cases where there was delay in obtaining information from DWP and landlords. Figure 2.24 provides details.

Fig. 2.24: New claims processing – delays in obtaining all information
Case summary	Overall number of days to obtain all information	BFI comment
RBK requested confirmation of IS entitlement from a claimant with mental health problems.	59	RBK should have used the RAT to obtain this evidence.
RBK made a RAT enquiry on 30/07/01 to confirm IS. It was advised that access was denied and to refer to Jobcentre Plus. It did not do so but made 3 further attempts to get the required information from the RAT, at each attempt the message was the same, that access was denied. RBK requested confirmation on 31/08/01 from the claimant. However this was not supplied and the claim was initially treated as defective.	134	RBK should have, as advised, referred to DWP. The process it had in place was to telephone DWP and then have the reply confirmed by fax.
Case summary	Overall number of days to obtain all information	BFI comment
Claimant supplied the evidence on 16/10/01 and RBK then required an acceptance form to be completed by the landlord before HB could be paid directly to them. This was completed and returned on 15/11/01.		The delay in requesting information from the landlord extended the overall delay in this case by 31 days.
RBK received 2 NHB 3s showing conflicting information. RAT enquiries were made but both showed that the IS claim was defective. In the meantime RBK requested proof of income from the claimant, but the evidence provided, letter from Jobcentre Plus, only showed that a claim to IS had been made but had not been decided. Eventually on 14/11/01 RBK telephoned Jobcentre Plus and obtained confirmation of the IS award, which had been decided on 12/11/01. The fax confirmation was received on 26/11/01.	42	Whilst RBK had no control over the majority of the delay in this case, we consider that it should have had controls in place to ensure that the fax was received within the quantifiable target of 5 days as contained in the SLA.
All information and evidence had been collected from the claimant. RBK then issued an acceptance form to the landlord, delaying the case by a further 23 days.	59	RBK should consider the requirement for landlord’s acceptance form on initial scrutiny of the claim.
All information and evidence had been collected from the claimant. RBK then issued an acceptance form to the landlord, delaying the case by a further 14 days.	51	RBK should consider the requirement for landlord’s acceptance form on initial scrutiny of the claim.

Source: BFI analysis

2.232 Our findings show that RBK need to get information from third parties such as landlords or DWP more quickly.

We recommend that RBK reminds staff of the need to consider obtaining information from landlords during the initial scrutiny of the claim and to make better use of the Jobcentre Plus RAT in obtaining verification more promptly.

2.233 We found a further 3 claims where RBK had not requested all of the information following the initial scrutiny of the claim. We were told that RBK had found the same itself when it had examined cases that had been delayed.

We recommend that RBK reminds staff of the requirement to consider the entire claim at the initial scrutiny stage and request all information at that time.

If it does this its speed of processing should improve, as will its performance against BVPI 78a.

2.234 In the final case of the nine where the delay could have been avoided, RBK requested evidence of income and capital from the claimant on 09/10/01. It issued a duplicate request on 21/11/01, some 6 weeks later, and finally obtained the required evidence on 3/12/01. In this case it took the claimant 55 days to provide the required information. HB regulation 72(6) – (8) specifies that an authority has no duty to determine claims if a claimant takes longer than 4 weeks to provide information. It is however good practice to send reminders but RBK has to consider the reasonableness in the delay to providing requested information or evidence.

2.235 RBK needed to identify and address the reasons for slow responses to requests for further information. On scrutiny of the further request letter that RBK issued we found that it could be improved and more easily understood by the claimant if it included a list of evidence that it would accept for example as proof of NINO.

2.236 The initial request letter for additional information or evidence did make it clear to claimants that if they did not provide the requested information within the time allowed their claim would be considered as closed. RBK should consider failed responses more quickly to ensure unreasonable delays are not incurred in those cases where the claim should be closed.

Payments On Account

2.237 Regulation 91(1) of the HB Regulations requires LAs to make a payment on account (POA) if they cannot determine an RA claim within 14 days, and the impracticality has not arisen out of the claimant’s failure to provide the necessary information to determine the claim.

2.238 We found that staff were aware of the legal requirements to make payments on account. We found only 3 cases in our sample where a payment on account was appropriate. In all 3 cases RBK were awaiting an RO determination and a POA had been correctly made in all cases.

2.239 In 2 of these cases RBK should have made a referral to TRS earlier and had they done so the need for POAs and the subsequent rework involved would not have arisen.

2.240 RBK do not monitor POAs to control the length of time they remain in payment. From our sample we measured the length of time from the date the POAs were made until the date RBK made a full decision, we found the following:

· in 2 cases RBK made a full decision within 3 weeks

· in one case RBK made a full decision within 6 weeks.

We recommend that RBK introduces a management report which identifies POAs that have been in payment for longer than a specified period of time, say more than 4 weeks and:

· takes the appropriate corrective action

· identifies trends and, if required, amends procedural guidance and considers training requirements.

If it does this it will have more knowledge and control of the POA process.

Liaison with DWP

2.241 RBK’s ability to administer HB and CTB claims effectively and efficiently depends on good working relationships with the DWP.

2.242 This is because many of its HB/CTB claims are linked to IS/JSA(IB) entitlements. In the quarter from October to December 2001, 972 (60%) of the total number of new HB claims (1,609) were from claimants who were receiving IS or JSA (IB).

2.243 Other benefits administered by DWP are in payment in many of the remaining claims.

Service Level Agreement

2.244 There is a national model SLA agreed between DWP, the Local Authorities Associations (LAAs) and Jobcentre Plus. Jobcentre Plus requires its local offices to sign an SLA with associated LAs and the LAAs state that the LAs ought to do so. This SLA must be kept relevant and up-to-date. For it to work effectively, relevant staff from both organisations must be both aware of, and required to act on its contents.

2.245 As a minimum standard we would expect an LA to have a signed, agreed and monitored SLA in place with Jobcentre Plus. Standards of performance should be contained in the SLA, and the testing of these standards should be carried out regularly during the lifetime of the SLA. Additionally we would expect an authority to have a RAT and to have adopted Electronic Transfer of Data (ETD). It also should ensure that it tells Jobcentre Plus of changes of circumstances as set out in the current SLA and required by regulations.

2.246 There is a current SLA between RBK and the local Jobcentre Plus office. This agreement is reviewed annually, and is modified to take local issues into account. Meetings between the 2 organisations are held quarterly. From the paper work provided we were able to confirm that an agenda is sent out in advance of meetings and that minutes are subsequently circulated showing action points cleared as well as those new actions required as a result of the meeting. There are nominated liaison officers and in RBK this role is included in the job description of one of the assistant group managers.

2.247 Monitoring of performance is an essential feature of the SLA, and is carried out during a planned monitoring week in each quarter to cover:

· date stamping of NHB1s – both IS and JSA cases

· adherence to the agreed 48 hour timescale for passing NHB1s to RBK

· quality of ETD information sent through the RAT.

2.248 The SLA performance certificate for 2001/02 had been signed off by both operations.

2.249 To help transfer data between Jobcentre Plus and RBK an electronic link is used. An RAT provides on-line access to the Jobcentre Plus Income Support Computer System and Jobseeker’s Allowance Payment System. The RAT link is designed to:

· give the LA direct access to BA information about IS and JSA(IB)

· improve accuracy of HB and CTB

· bring efficiency savings.

2.250 This electronic link also allows BA to provide IS and JSA(IB) data electronically using ETD.

2.251 As reported earlier RBK could make better use of the RAT when verifying claims.

2.252 It is important that changes of circumstances are passed on to RBK as soon as they are reported to Jobcentre Plus where entitlement to HB and CTB depends on continued IS and JSA(IB) payments. The processes in place should ensure that any changes are passed to RBK electronically.

2.253 To test the effectiveness of this process we assessed the extent to which the cases in our sample of 30 new claims had the correct system indicators set to facilitate this electronic exchange of information. We found that in 15% of the cases they had not been set. If this figure was applied across all of the 972 new claims received in that quarter it could mean that as many as 145 of them had no electronic means of exchanging information. As such this represents a big risk to keeping payments correct, although the onus is still on the claimant to report changes of circumstances.

We recommend that RBK, at the time of its next intervention, checks by using the RAT, that the correct system indicators are set for all HB and CTB claimants who are receiving IS or JSA(IB).

In addition it should remind Jobcentre Plus of its responsibilities in this respect.

If it does this it will have more assurance that the electronic interface is working as designed and is effectively helping to keep payments right.

2.254 Additionally we looked at the processes in place within Jobcentre Plus for the notification of claimant changes of circumstance to RBK for clerical claims, and we found that these clerical processes were sound. There were no cases in our sampling and we therefore did not test this further.

2.255 We visited the Jobcentre in Kingston and interviewed the Jobcentre Plus liaison officer. This officer is responsible for:

· processing JSA claims

· receiving and passing HB and CTB claims to RBK

· controlling the RBK and Jobcentre Plus performance monitoring process within the Jobcentre Plus office.

2.256 Historically there was no SLA between RBK and the Employment Service, however, from April 2002 Employment Service attended all previous RBK and Benefits Agency (Jobcentre Plus from April 2002) liaison meetings. Although organisational structures have changed, those involved in liaison have continued in their roles and this will serve RBK well as they develop its relationship with Jobcentre Plus.

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