Findings (continued)

Getting it right

Definition

2.26 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.

2.27 To secure the gateway to benefit, an organisation must:

· insist that claimants produce enough evidence to prove that they qualify for benefit before benefit is paid

· make sure information can be checked systematically, with a sound appreciation of where it is at risk of being wrong

· bring together all the available information where the claim is checked

· make sure it has continuing contact with claimants.

Backlog of work

2.28 Backlogs of work have been a feature of Lambeth’s benefit service for many years. There was a substantial backlog before the contracting out of the benefit service to Capita in November 1997.

2.29 When Capita took over the contract in 1997, it found that the backlog of work figure was hugely understated by 65,800 pieces of post. In total there were 106,000 pieces of post outstanding. Capita and Lambeth came to an agreement about the extra Lambeth would have to pay Capita to clear this backlog. We were told by Lambeth that Capita had made good progress in reducing the backlog but this had stalled when the conversion to Academy system took place in January 2000. At the time of our inspection, outstanding work stood at around 35,000 pieces of post. The backlog is the main symptom of the problems in the benefits service. At the time of our visit Lambeth was unable to confirm when it expected the backlog of work to be cleared. However, we consider that the problems with the service are more fundamental than this. We found:

· basic management techniques are not applied

· the monitoring of the contract is poor.

2.30 The Members have acknowledged the poor performance in the findings of their enquiry on the benefit service. It was reported:

Housing and Council Tax Benefits are vital payments made to help people on low incomes. The service has been provided by Capita Business Services since 1997.

The Council accepts that its performance in respect of HB and CTB claims is extremely poor and is taking drastic action to drive up performance.

2.31 In 1998 the LA commissioned an independent review of the services provided by Capita. An action plan for improving the service was produced following the Members’ review but the required improvements have not happened quickly enough. The continued poor performance led to an investigation by Lambeth’s SC, which reported its findings in March 2000. The SC found that the services still failed to meet statutory and contractual targets in a number of critical areas. It found:

· failure to meet the statutory 14-day deadline for processing claims

· failure to meet the 8-day contract target for processing claims

· poor customer care

· unacceptable levels of complaints

· missing files.

2.32 The SC reported that:

The quality of service is unacceptable. The committee recommends that a comprehensive action plan containing improvement targets in the failing areas must be produced. To ensure real improvements the committee also recommends that the action plan be closely monitored.

To help speed up change, the council has established a tough management team to work alongside Capita management, preparing the action plan with clear targets for rapid and sustainable improvement.

2.33 As a result of the committee’s findings a PB was created in March 2000. This group consists of:

· the leader of the council

· the Member with responsibility for HB and CTB

· the Chief Executive

· the Executive Director of Finance and Corporate Services

· the HCC

· the Operations Director for Capita

· the Service Manager for Capita

· a UNISON representative.

2.34 The PB decided to focus on:

· improving customer service

· reducing the backlog of 45,000 items outstanding up to March 2000

· reducing the number of complaints and appeals

· improving the filing system.

2.35 Some of these were "quick wins", designed to help the claimant if they had been successful. But it is arguable that claimants have not seen any change other than cosmetic. The PB has focused on the symptoms of the failing service, rather than the cause, such as lack of resourcing in the Primary Assessment Team (PAT) and Assessment Teams (ATs).

2.36 We were told that good progress had been made to reduce the backlog by Capita. Figure 2.9 shows the amount of outstanding work at Lambeth since November 1997.

Fig. 2.9: Backlog – timeline
Date	Overall backlog (pieces of post)	Notes
November 1997	106,000	When Capita took over the benefits contract on 1 December 1997 the backlog was believed to amount to 65,800 pieces of post. However, shortly after the contracting out of the benefit service it became apparent that it was some 40,000 higher. The Due Diligence Audit Review of the backlog undertaken at the end of November 1997 and issued in April 1998 confirmed the higher backlog figure. This led to Capita producing a detailed schedule for tackling the backlog and an estimate of charges payable by Lambeth in respect of it.
November 1999	23,000	Report produced by Capita shows that 2 years on from it taking over the contract, the backlog had reduced considerably.
March 2000	43,000	Following the conversion to Academy, the backlog had increased. Unlinked post received before February 2000, including new and renewal claims was ring-fenced and a backlog team set up to process it. The objective was to clear the ring-fenced backlog by the end of October 2000.
June 2000	35,500	In June letters were sent to all claimants apologising for the poor service and asking them not to visit the counter at OMH for a period of 10 weeks, to allow for resources to be directed into clearing the backlog. The ring-fenced backlog had reduced to around 30,000 but outstanding linking on PAT stood at over 2,000 and outstanding work on assessment teams at 3,500.
September 2000	35,100	At the end of September, when we were on-site, the backlog ring-fenced in March 2000 had been reduced to around 7,300. However a second backlog had accrued, largely as a consequence of the PAT being unable to link post to files. This new backlog, of around 15,800 pieces of post, covered post received between March and July 2000. Unlike the earlier backlog, however, it did not include any new or renewal claim forms. In addition, linked post and claims awaiting action by AT stood at around 12,000.

Source: BFI analysis

2.37 Figure 2.9 can only give a broad overview of the backlog situation at Lambeth as:

· measurement methods have not been consistent

· other sections that receive post have not been included in the totals

· a significant proportion of backlog post requires no action other than filing, usually because duplicate claims/correspondence have been received and actioned.

2.38 The initiatives implemented by Lambeth and Capita have had some positive impact. However, we found that the outstanding work in September 2000 was not significantly less than at the start of the PB.

2.39 We consider the main reasons for this are that:

· Lambeth has not allocated sufficient resources to deal with new incoming work effectively and efficiently, resulting in new backlogs accruing

· management information used to monitor performance is incomplete and inaccurate.

Monitoring performance

2.40 We consider that the PB has helped to oversee action taken by Lambeth to address the backlog of work. However, the PB has not been provided with the management information necessary to obtain a full picture of the problem and therefore keep things on track. We found that the statistics presented to the PB by Capita:

· had not been validated by Lambeth

· focused on the ring-fenced backlog and not on the total work outstanding, allowing a further backlog to accumulate

· did not include data on the quality of work, for example test checking and returns by determination officers. This is unfortunate because poor quality work can often result in additional work, including reassessment, being required at a later date

· were produced clerically, rather than by using Academy. This was unfortunate because:

– the quality, completeness and uniformity of the data has been called into question by independent consultants

– the amount of time spent on producing statistics this way diverted resources away from the main task of clearing work

· failed, amongst other things, to:

– highlight the significance of some of the work outstanding, such as changes of circumstances correspondence requiring the reassessment of cases, in some cases to prevent an overpayment of benefit

– inform on the assessment work being undertaken by specialist sections, such as the liaison teams

– report on the number of calls to the call centre and that a significant percentage of these were repeat calls where action had not been taken after the initial call to resolve the problem

– inform on the number of duplicate claims being set up.

2.41 In addition we also found that Lambeth:

· had not communicated its policy to all staff

· had not ensured that all staff were set individual targets

· did not undertake management checks of work

· managers and team leaders were not providing the support and required direction for staff.

2.42 We consider this to be poor management by Lambeth and Capita.

Teams dealing with assessment work

2.43 To deal with the backlog of work we found that there were a number of teams, in addition to the PAT and ATs, responsible for dealing with assessment work. Figure 2.10 provides details.

Fig. 2.10: Other teams involved in assessment work
Team	Description
The ring-fenced backlog team	Set up in March 2000 to deal with all unlinked and unactioned post received before 29 February 2000
Synergy Project Team	Set up to support the caller section and process any cases that needed urgent attention as a consequence of a claimant visiting the counter. The team was not fully occupied on this work and had also been assisting in the clearance of the ring-fenced backlog.
Complaints and LGO Section	Set up to deal with complaints and LGO cases. Where complaints or LGO investigations require claims to be reassessed the staff on this section will carry out this work.
Review and Review Board Section	Responsible for dealing with reviews and review boards. However, in addition to dealing with review requests a significant level of cases are amended by the team, due to errors found in the original assessment rather than being referred back to the AT.
Court liaison teams (2 Public and one Private)	Responsible for dealing with queries on benefit entitlement from LA Housing and landlords. In addition these sections had to represent the LA on cases that went to court to explain the status of a defendant’s benefit claim. It is estimated that over 50% of the cases liaison staff deal with require assessment or reassessment and we found that cases are reassessed by the team rather than referring them back to the AT.
Mendip team	Set up to deal with claims and other assessment work to ease the pressure on staff at OMH. Files for this team are sent by courier to and from their offices in Somerset. Original plans for the team to deal primarily with new claims had to be revised when it was realised that it had no access to the LA’s creditors system which was necessary to decide on the method of payment on private claims. The team now deals with up to 600 cases a week – a mixture of claims and old post including rent increase and RO determination notifications.
Red Bag Scheme	Set up by the PB to assess all RR new and renewal claims received at the NHOs. It is not known for how long the team will be in existence, but it is expected to continue until February 2001.

Source: BFI analysis

2.44 Many of teams outlined above were set up as a result of initiatives created by the PB, and their expected life span is uncertain.

Ring-fenced backlog team

2.45 When the ring-fenced backlog team was set up in March 2000 all 45,000 items of outstanding post were sorted and all items for the same claimant were linked together and filed in individual folders for each claimant. When this had been done we were told that there were 30,500 folders.

2.46 The backlog team’s objective was to clear the outstanding work by the end of October 2000. However, we found that the team was not meeting this target and had transferred some of its work to other sections, including the AT.
Figure 2.11 shows details of the backlog folders passed to other sections for actioning during the period July to September 2000.

Fig. 2.11: Ring-fenced backlog folders passed to other sections for actioning – July to September 2000
Month	Synergy	Complaints and LGO section	AT
July 2000	370	600	0
August 2000	435	450	600
September 2000	200	0	1,000
Total	1,005	1,050	1,600

Source: BFI analysis

2.47 At the end of September 2000 there were still 7,295 folders to be actioned. We examined the folders in the backlog and found that:

· 63 new claims were at least 6 months old

· 115 renewal claims were at least 6 months old

· there were 33 cases where benefit had ceased where the notification of the change was over 6 months old and at least 14 of these required an overpayment to be calculated.

2.48 Moreover, a Capita manager told us that it had been agreed that the backlog team would also take responsibility for the 15,800 pieces of post that had accumulated between March and July 2000 for the PAT. However, it was not in the position to start linking and clearing this additional new work because it had yet to clear the original ring-fenced backlog.

We recommend that Lambeth ensures that Capita:

· draws up a clear action plan, with achievable targets for clearance of the backlog

· nominates an officer responsible for managing the backlog and new work

· reviews the resources required for the PAT and ATs

· provides accurate management information on the amount of work outstanding

· implements a performance management system including a comprehensive checking regime.

In addition, to satisfy itself that the backlog of work is being cleared, Lambeth must:

· validate the information provided by Capita

· closely monitor Capita’s progress towards the clearance of the backlog.

File management

2.49 Lambeth has recognised that the current filing system affects the provision of good customer service. Lambeth believes that the current problems experienced with the filing system have been created by a failure to manage the system effectively which has led to problems of overcrowding and misfiling.

2.50 In addition we found the following:

· duplicate claim forms were sent by claimants because they thought the previous ones had been lost

· duplicate files were set up where the original file had been lost

· there is no central record of duplicate claims or files so there is no knowledge of how many there are in the system

· no records of those cases where duplicate and original claims had subsequently been amalgamated

· documentation about changes of circumstances, for example rent increases for HA cases, are processed without reference to a case file. This increases the risk that other relevant information contained in the file, for example unactioned post, is not taken into account at the time of assessment.

2.51 Despite repeated attempts to resolve the problems associated with the system, there have not been any major improvements. We discussed this with Lambeth and Capita and were informed that a new trackable filing system has been ordered and will be fully operational by May 2001. The new system will be held in a secure area and will include a facility to track a file as it moves from section to section.

To help Lambeth better secure the benefits service a more efficient and controlled filing and case control system must be provided. We recommend that Lambeth ensures that Capita fully implements the proposals for the revised filing system.

2.52 Implementing this recommendation will ensure that Lambeth improves the:

· accessibility, retrieval, checking and control of benefit claim files

· efficiency of the service by reducing time spent searching and locating benefit records.

Public enquiry reception

2.53 In its publication Countering HB Fraud the Audit Commission (AC) suggests customer care is particularly important in benefit administration and is one of the major contact points between LAs and many of the vulnerable and less well-off people in their areas. It is therefore essential that authorities have an easily accessible public enquiry reception if claimants are to be encouraged to visit the authority’s offices so that they can:

· make enquiries about their benefit claims

· provide evidence in support of their claims

· report changes of circumstances that may affect their benefit entitlement.

2.54 There is a dedicated team dealing with all types of HB and CTB enquiries at OMH. However, we found that there is no provision for the team to receive additional resources to cover for planned or unplanned absences or provide additional help during peak times.

2.55 The public enquiry reception is open from 09.00 to 16.30 Monday to Friday and 09.00 to 13.00 on Saturdays. We consider Saturday opening to be good practice and an example of Lambeth responding to the wishes of its customers.

2.56 In June 2000 Lambeth introduced a ticketing system (Adaptacom) to measure customer waiting times, volumes and transaction times. Before this Lambeth recorded information on a locally developed spreadsheet.

2.57 We found that the office opens at 08:00 to allow claimants to wait inside the public enquiry reception rather than outside. But enquiries will not be dealt with until 09:00. We observed that there were long queues before 08:00 and a significant number of callers were often waiting in the public enquiry reception before 09:00. The public enquiry reception is closed early if the customer service team decides the number waiting will not be dealt with before the end of the working day.

2.58 We found that a ticket from the ticketing system is not issued to those callers arriving at OMH before 09.00. Lambeth does not measure the waiting time, volumes or transaction times of those arriving at OMH before 09.00.

2.59 A ticket is only issued to those callers who wish to query their entitlement or make an enquiry about the progress of their claim. Those wishing to hand in documents or have documents copied are not issued with a ticket and are required to queue at booths used for copying documents. Lambeth does not measure the waiting time, volumes or transaction times of those wishing to hand in documents or have documents copied.

2.60 We analysed the statistical data provided by Lambeth on the number of callers visiting OMH to enquire about HB and CTB claims for the period 1 June 2000 to 30 September 2000. The results of our analysis are shown in Figure 2.12.

Fig. 2.12: Callers to OMH – June to September 2000
	June	July	August	September
Number of callers	1,156	1,424	1,560	1,924
Average waiting time	72 mins	68 mins	87 mins	101 mins
Average time spent with each caller	30 mins	29 mins	31 mins	27 mins
Total time	102 mins	97 mins	118 mins	128 mins

Source: BFI analysis of Lambeth data

2.61 Figure 2.12 shows that there has been an increase in the number of callers and an increase in the average waiting time since June 2000.

2.62 We analysed the data provided by Lambeth and established the shortest and longest periods claimants had waited to be seen at OMH. The results are shown in Figure 2.13.

Fig. 2.13: Range of waiting times – June to September 2000
	June	July	August	September
Shortest	1 min	1 min	1 min	1 min
Longest	392 mins	234 mins	374 mins	472 mins

Source: BFI analysis of Lambeth data

2.63 As Lambeth does not identify and record the type or reason for the caller it was not possible for us to analyse the reason for the increase in the number of callers or the time taken to deal with the enquiries. However, we believe that the backlog of work has had a significant impact on the number of callers to OMH and the time taken to deal with the enquiry.

We recommend that, to improve the quality of service provided to those who visit OMH, Lambeth ensures that Capita:

· ensures there is an adequate number of reception staff to assist the public

· measures the time taken for all public callers to be dealt with at OMH and uses the information to improve service delivery

· identifies, records and analyses the reasons callers that visit OMH.

2.64 Implementing this recommendation will help reduce the time taken to deal with enquiries and provide important information on which management decisions can be made about service delivery.

Call centre

2.65 Capita, with Lambeth’s agreement, uses Capita’s call centre in Coventry to handle incoming calls from the public. The calls are charged at local rates for Lambeth residents. Although the call centre is responsible for taking calls from a number of Capita sites, a dedicated team is responsible for taking calls from Lambeth claimants and residents.

2.66 The role of the call centre is to:

· provide quick and easy access for claimants

· ensure the optimum level of staff are available to answer telephone queries

· filter calls so that assessment staff only need to be involved in more complex issues that cannot be concluded by a call centre agent

· allow assessment staff to concentrate on assessing claims

· refer outstanding claim queries to assessors at OMH, identifying the priority of the query.

2.67 To help the call centre team, PAT is expected to record all correspondence received on the computer system. We were told that the backlog of work means that not all correspondence has been recorded, and so it is not possible to rely on the information recorded on the Academy system. As a result the call centre staff cannot with any certainty tell callers whether their documentation has been received. This has a significant effect on the number of repeat calls made to the call centre.

2.68 The call centre staff record the number of repeat calls. Figure 2.14 shows the number of calls and frequency of the caller for July 2000.

Fig. 2.14: Callers to the telephone call centre – July 2000
Frequency	Number	%
Once	1,149	52
2 times	152	7
3-4 times	476	21.5
More than 5 times	430	19.5
Total	2,207	100

Source: BFI analysis

2.69 There is no formal process to inform the call centre staff the state of the work outstanding at Lambeth. Nor is a formal script provided for the call centre team to use when answering calls about the backlog, for example, how to tell claimants how long they may have to wait for their claim to be processed. In the absence of a script, the call centre team advises callers to make further contact in 2 weeks. This increases the number of calls made to the call centre.

2.70 The call centre collects data on the reasons for the calls. Figure 2.15 shows the main reasons given to the call centre.

Fig. 2.15: Reasons for calls to the call centre
Query	% of calls
Enquiry to establish the progress of claim	40
Request for further information	20
Reason for cancellation* when all information has been provided	12
Reason for conflicting correspondence	8
Other	20
Total	100

Source: BFI analysis

* terminology used in Lambeth referring to claims where benefit has stopped.

 

2.71 Call centre staff use the notes facility on the computer system to record information obtained from claimants over the telephone. This includes requests from claimants to return calls and provide information on the progress of their claim.

2.72 The call centre team told us that Lambeth did not return calls due to the volume of other work. This results in further calls to the caller centre by dissatisfied callers, which in turn adds to the backlog of work at OMH.

2.73 There are 2 escalation procedures for call centre staff to use when claimants have requested further information about their claim. Either reports are produced using Academy or the e-mail facility between the sites is used. However, we found that these procedures were not being used due to the volume of other work at Lambeth. There are no controls in place to ensure that call back requests are actioned. Overall this means that Lambeth is providing a very poor service to claimants.

2.74 We found there are no procedures for the call centre team to obtain information from the caller to pass on to CAFT. When appropriate to do so, the call centre team tells claimants wishing to report allegations of fraud to contact Lambeth’s fraud hotline. Team members can record the information on the notes facility of the computer system for a particular claim. However, this procedure provides no assurance that the caller will contact the hotline or that assessment staff or CAFT will act on the information recorded on the system. This means that opportunities to investigate allegations of fraud are either lost or not taken forward.

2.75 There are no procedures for the call centre team to receive feedback in respect of those cases identified as possible fraud. There is no statistical data held on the success of the notes made to the CAFT by the call centre team.

We recommend that, to improve the quality of service provided to those who contact the call centre, Lambeth ensures that Capita:

· ensures that all correspondence received is recorded on the IT system

· introduces procedures so that the call centre team is aware of the state of work in Lambeth and develops scripts for the call centre team to use when dealing with callers

· benefit processors return calls to callers who have requested an update on the progress of the claim.

In addition, we recommend that, to improve the reporting of fraud, Lambeth ensures that Capita:

· introduces formal arrangements for the call centre team to record allegations of suspected fraud and make necessary referrals to CAFT

· ensures procedures are in place to provide feedback to the call centre team on the outcome of fraud referrals.

2.76 When implemented, these recommendations will:

· improve the service to the claimants by reducing the number of calls and excessive number of repeat enquiries

· help to reduce the amount of work created by the backlog

· provide important information on which management decisions can be made about service delivery

· improve the flow of information between the call centre team and CAFT about allegations of fraud

· encourage the call centre team to obtain relevant and quality information from callers about allegations of fraud.

Post opening

2.77 Secure post opening arrangements are an important factor in helping secure the gateway to HB and CTB. In Lambeth benefits post is delivered direct to OMH by the Royal Mail and is opened on site each day.

2.78 We observed post opening at OMH on 3 October 2000. We found a number of weaknesses in the security of the processes:

· staff not involved in the post opening process have free access to the post opening room

· the post opening area is not free of other papers and documents

· there is no adequate segregation of post opening duties

· there is only occasional supervision of the post opening process

· the post room contained personal belongings

· staff were allowed to enter the post opening area after the procedure had commenced

· not all post is opened on receipt

· post passed to an addressee is not opened in front of a member of the post opening team

· valuables sheet is not countersigned

· 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 XXX

· XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X

· XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX

2.79 Appendix B provides a full comparison of Lambeth’s post opening procedures against the BFI Good Practice Guide.

We recommend that Lambeth reviews and introduces revised post opening procedures immediately. In particular, Lambeth should ensure that Capita addresses the identified weaknesses as detailed above and in Appendix B.

2.80 The benefits for Lambeth of doing this are:

· management will have an assurance that the systems for receiving and handling mail and valuables are secure

· the risk of internal fraud and theft will be minimised

· the security to the gateway, helping to prevent fraudulent claims getting into the system at the point of entry will be improved.

Claim form

2.81 A good claim form for both new and renewal claims plays a vital part in:

· ensuring administrative efficiency

· securing gateways into the benefit system

· providing a better quality service to claimants.

2.82 Lambeth uses 4 forms for new HB and CTB claims for:

· people in temporary accommodation

· private sector tenants and owner occupiers

· council tenants

· HA tenants.

2.83 Along with these forms, Lambeth uses a short renewal form for those claimants who are in receipt of IS/JSA(IB). Use of shortened renewal forms is bad practice because it is likely that information needed to assess initial claims is just as important for a renewal claim. The law does not recognise a difference between new and renewal claims so a renewal assessment needs as much information and evidence as a new claim.

2.84 Having a range of forms can mean that claimants are sometimes asked to complete an inappropriate form. We found 4 such cases in our renewal claims sample. In one case, an RA claimant completed and returned a short claim form for LA tenants and was, as a result, not given the space to state if their rent had increased. In another case, a short claim form was accepted from the claimant and benefit paid even though IS/JSA(IB) was no longer in payment.

We recommend that Lambeth stops using the shortened renewal claim form immediately as it increases the risk of fraud and error entering the system.

2.85 The BFI Good Practice Guide outlines the attributes of an effective claim form. In addition, the VF specifies the minimum amount of information to be collected on the claim form, together with the minimum verification that is required to support that information. We checked to see if the form met the requirements of the April 2000 version of the VF. Appendix C gives the results of our analysis.

We recommend that Lambeth introduces a single claim form for all types of HB and CTB claims, including renewal claims, thereby ensuring that all relevant information is captured accurately efficiently and as well as fully meeting the requirements of the VF.

2.86 Having one claim form will:

· eliminate confusion for benefit processors and claimants as to which form should be used

· improve customer service and administrative efficiency by capturing full and accurate data the first time, reducing the need of claimants and staff to ask for further information or clarification of details.

Verification

2.87 To secure the gateway to the benefit system it is important that LAs make sure that claimants supply verifiable information and evidence before payment is made. LAs should also ensure that the evidence required is authentic, has not been tampered with and can be verified as relating to the claimant. This reduces the risk of fraud and error.

2.88 Lambeth has not demonstrated its commitment to ensuring the gateway is secure by adopting the VF, which represents the minimum standard that LAs should use to help secure HB and CTB. We discussed this with Lambeth and were told that it had not budgeted to pay for a service that included VF when it had awarded the contract to Capita. In addition to this Lambeth considered it inappropriate to implement VF as it had a substantial backlog of work.

2.89 To test the verification processes adopted by Lambeth we sampled 61 new and 59 renewal claims processed and paid between April and June 2000. We compared Lambeth’s performance with the standards of the VF. Lambeth fell significantly short of the VF requirements in a number of areas. We discuss our comparison between Lambeth’s procedures and the standards in the VF on each main area of verification below.

2.90 The 2 main teams responsible for processing HB and CTB are the PAT and ATs.

2.91 The PAT is responsible for delivering to the assessment team cases that can be assessed without further intervention. The assessment team staff are then supposed to input the results into the Academy system. However, we found this has not worked because:

· the technical ability of the staff in the PAT is not good enough

· there are not enough staff in the PAT to deal with all the work that comes in each day, as shown by the backlog of work

· the quality of the cases that go to the AT is not high enough for the assessors to action them without further intervention.

Obtaining sufficient information to process claims

2.92 Regulation 73 of the Housing Benefit (General) Regulations 1987 (HB Regulations) puts the onus on the claimant to provide all the information that an LA requires to determine entitlement to benefit. There is a similar provision in the Council Tax Benefit (General) Regulations 1992 (CTB regulations). It is vital, therefore, that the LA ensures that claimants complete claim forms correctly and that any information that has not been provided is obtained from the claimant.

2.93 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX
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XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X
XXXX XXXX X

 

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX X
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XXXX XXXX XX	XXX	XXX	XXX
XXXX XXXX XXXX	XXX	XXX	XXX
XXXX X	XXX	XXX	XXX

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2.94 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX
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 XXXX XXXX X
XXXX XXXX

Quality of requests for further information

2.95 To test the quality of the information sent to claimants we sampled items of outgoing correspondence on 3 October 2000. We selected 10 items at random from the public and private assessment teams.

2.96 We found that the public and private assessment team carries out work that should have been done by PAT. Figure 2.17 shows the number of requests for further information sent by the private and public assessment teams.

Fig. 2.17: Requests for further information sent by the private and public assessment teams
Requests for further information	Public	Private	Total
Items sampled	10	10	20
Number not dealt with by PAT	1	6	7
% not dealt with by PAT	10	60	35

Source: BFI analysis

2.97 We also found that enclosures had not been sent to the recipient. In total there were 14 cases where a claim form, business reply envelope and a checklist informing the claimant what proof was required to support their claim should have been provided. Our sample showed that in 6 (43%), cases only the claim form had been provided. This is confusing for the recipient and may lead to further enquiries from them either by telephone or in person at OMH.

Controlling requests for further information

2.98 We found that there were weaknesses in the methods used by Lambeth to control requests for further information from claimants or landlords. In particular we found that:

· requests for further information are returned to the main filing run, once the request has been made

· reminders to claimants or landlords are not sent so no further action is taken on the claim unless the claimant or landlord contacts the LA

· the PAT is not recording the receipt of documents on the Academy system

· staff do not use the Academy system or clerical methods to monitor and control outstanding requests for further information from claimants or landlords.

2.99 Because of these failures, Lambeth does not know how many claims are awaiting action, and is providing a very poor service to claimants and landlords.

We recommend that Lambeth ensures that Capita puts in place procedures to control requests for further information and takes the necessary action to record the receipt of all information on the Academy system.

Quality of evidence

2.100 We found that Lambeth’s verification procedures do not require claimants to provide original documents in support of their claim. This was by our sampling exercises and in interviews. We found evidence that photocopies of supporting documentation are accepted and are stamped by PAT as "original seen". This raises questions about the strength of the procedures adopted by Lambeth to verify the authenticity of documents and, therefore, the quality of evidence provided in support of claims.

2.101 We were unable to identify those claims where the copy held on the claim file had been provided by the claimant or taken from original documents by a member of staff. Our findings on verification therefore represent the maximum number of cases where original documents may have been seen.

2.102 We found that staff at the public enquiry point use UV scanners to test the authenticity of original documents provided by claimants. The PAT does not make use of scanners.

2.103 In our sample of new and renewal claims we found that Lambeth does not ensure that staff:

· routinely sign each document to endorse that it has been checked and verified in line with Lambeth’s VF procedures

· working as part of the PAT check the validity of original documents before they are copied and stamped for VF purposes.

2.104 Figure 2.18 shows the results of our sample of new and renewal claims.

Fig. 2.18: Original documents not stamped as original seen
	New claims	Renewal claims	Total
Number in BFI sample	61	59	120
Original documents not stamped	21	13	34
% of sample	34	22	28

Source: BFI analysis

2.105 The results from Figure 2.18 show that Lambeth does not ensure that original documents are obtained and used as part of its verification processes.

Verification of new claims

2.106 To make sure benefit is paid correctly it is important that when claims are received the verification of information and evidence gathered is comprehensive. To assess Lambeth’s standards of verification we sampled 61 new claims determined between April and June 2000. We used the VF as a benchmark and the results of our sampling are shown in Figure 2.19.

Fig. 2.19: Verifying evidence on new claims
Evidence	Appropriate cases	Number verified	Number not verified	% verified
Identity and National Insurance number (NINO) for claimant	61	44	17	72
Identity and NINO for partner	6	5	1	83
Rent liability	61	59	2	97
Residency	61	0	61	0
IS/JSA(IB)	48	37	11	77
Income	13	9	4	66
Capital	8	2	6	25

Source: BFI analysis

2.107 Our sampling showed that Lambeth’s verification of information for new claims is very poor. We have commented on the performance against each type of evidence provided later in this section.

Verification of renewal claims

2.108 To ensure that benefit continues to be paid correctly it is important that when a renewal claim is received the verification of information and evidence is as comprehensive as that for new claims. To assess Lambeth’s verification we sampled 59 renewal claims processed between April and June 2000. Our sample highlighted that the verification processes adopted by Lambeth for renewal claims does not provide any assurance as to the accuracy of awards and the integrity of the benefit system. Quite simply, an unacceptable number of claims are put into payment without rigorous verification. We used the VF as a benchmark and the results of our sampling are shown in Figure 2.20.

 

Fig. 2.20: Verifying evidence on renewal claims
Evidence	Appropriate cases	Number verified	Number not verified	% verified
Identity and NINO for claimant	59	41	18	69
Identity and NINO for partner	12	6	6	50
Rent liability	59	54	5	92
Residency	59	0	59	0
IS/JSA(IB)	24	19	5	79
Income	35	31	4	89
Capital	18	12	6	67

Source: BFI analysis

 

Verification of identity and NINO

2.109 Of the 120 claims sampled, verification of identity was sought and received for 85 (71%) of claims.

2.110 Subsections 1(1A) and (1B) of the Social Security Administration Act (SSAA) 1992 (inserted by section 19 of the Social Security (Fraud) Act 1997) provide that no person whose entitlement to any benefit depends on his making a claim shall be entitled to that benefit unless subsection (1B) is satisfied in relation to the person making the claim and to any person in respect of whom he is claiming benefit. Subsection (1B) is satisfied in relation to a person if:

· the claim is accompanied by:

– a statement of the person’s NINO and information or evidence establishing that the number has been allocated to that person or

– information or evidence enabling the NINO that has been allocated to the person to be ascertained or

· the person makes an application for a NINO to be allocated to him which is accompanied by information or evidence enabling such a number to be allocated.

2.111 This legislation took effect for HB and CTB claims from 6 September 1999. BFI previously visited Lambeth in December 1999 and found that the LA had acted unlawfully by failing to fully introduce the requirements of subsections 1(1A) and (1B) from 6 September 1999.

2.112 At the time BFI was told that implementation had been delayed mostly because of the introduction of the new Academy system and that the procedures would be introduced from 4 January 2000.

2.113 As a result of our visit in December Lambeth carried out an exercise to ensure that those claims determined between 6 September 1999 and 4 January 2000 complied with the legislation.

2.114 To assess Lambeth’s compliance with this legislation we tested the 61 new claims all processed in the period April to June 2000. We found poor compliance with the legislation, which requires 100% compliance. Our finding is that benefit was illegally paid in 17 of the 61 claims tested. The results of our sampling are shown in Figure 2.21.

Fig. 2.21: New claims – compliance with subsections 1(1A) and (1B) of the SSAA 1992
	Number	%
Compliant	44	72
Non-compliant	17	28
Total	61	100

Source: BFI analysis

2.115 We were told that Lambeth had not applied section 1(1A) of the SSAA 1992 to renewal claims and had chosen to phase in the requirement for claimants to provide and verify their NINOs. However, Capita told us that it was applying subsection 1(1A) and there had been no instruction not to apply the requirement to renewal claims.

2.116 We found the temporary accommodation and hostel team has not received training on NINO verification. The results from our sampling are similar to that of new claims in that all NINOs are not being verified on the renewal claims. This shows that benefit was being paid illegally in 18 of the 59 renewal claims tested. The results of our sampling are shown in Figure 2.22.

Fig. 2.22: Renewal claims – compliance with subsections 1(1A) and (1B) of the SSAA 1992
	Number	%
Compliant	41	69.5
Non-compliant	18	30.5
Total	59	100

Source: BFI analysis

2.117 To illustrate Lambeth’s non-compliance with legislation, we include case studies in Figures 2.23 and 2.24, from 2 cases in our sample.

Fig. 2.23: Non-compliance with subsections 1(1A) and (1B) of the SSAA 1992 – case study 1

Lambeth had not obtained a NINO from evidence supplied by the claimant on a new claim. Lambeth had accepted that the claimant’s landlord (HA) had established that the NINO belonged to the claimant. This is unlawful because Lambeth had not established the allocation of the NINO as required by subsection 1(1B).

Source: BFI analysis

Fig. 2.24: Non-compliance with subsections 1(1A) and (1B) of the SSAA 1992 – case study 2

Lambeth was unable to obtain a NINO from evidence supplied by the claimant on a new claim. In this case Lambeth had not contacted BA, using the specific form (DCI1 LA), requesting a NINO trace, or an allocation of a NINO to the claimant.

Source: BFI analysis

 

Verification of rent liability

2.118 Lambeth’s performance in verifying rent liability was better than in other areas of verification, but was still poor. Our sampling showed that in 59 out of 61 new claims and 54 out of 59 renewal claims, liability to pay rent had been confirmed. In RA claims we found that original tenancy agreements and letters from landlords or landlord agents had been obtained.

Verification of residency

2.119 Verification of residency was particularly poor. We found that CAFT was carrying out a high number of residency checks but the outcomes were only reported back to the AT when residency is not confirmed, and as a result, Lambeth is missing an opportunity to share this information.

We recommend that CAFT refers to the benefits section details of all cases where residency has been verified.

2.120 At the time of our inspection there were 4 dedicated Visiting Officers (VOs) based in CAFT. In 1999/2000 37,798 proactive visits were conducted.

2.121 Lambeth uses a bespoke case management system for HB and CTB fraud called FACTS. Every Monday, details of all new RA cases are downloaded from Academy into the FACTS database. New cases are split by postcode between the 4 VOs. However, although the VOs were aware that BA also visits some new claims, they do not liaise with BA to confirm which claimants have already been visited.

2.122 XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXX There had been problems in the past when CAFT had requested cancellation prematurely in some RR cases. These had led to complaints, some of which got into the press. For example there was an elderly and disabled claimant who was unable to answer the door in time, and a blind claimant who was unaware that a letter had been left.

2.123 We were told that the HD insisted on the right to approve the stopping of benefit payments and insisted on a much higher standard of proof of non-residency before authorising action. We were shown evidence where CAFT had made up to 15 ineffective visits to council properties over a period of 9 months, but where the HD had refused to approve the stopping of the benefit payments. CAFT’s response was to stop visits to council properties, and concentrate on RA cases.

2.124 We are very concerned that the HD has been allowed to veto work of the HB section. It is at the least inappropriate that a landlord is allowed to have this level of power.

We recommend that:

· Lambeth reports the outcome of all visits to the AT

· CAFT liaises with BA to develop a joint visiting programme and ensure information on visits is exchanged

· Lambeth subjects RR cases to the same scrutiny as RA cases

· the HD are prevented from influencing the work of the HB section.

Verification of income

2.125 Verification of income on new and renewal claims was poor. Our sampling showed that income is not consistently verified. In IS and JSA(IB) cases, we found that Lambeth does not make full use of the RAT to establish whether the claimant is in receipt of a DSS benefit.

Verification of IS/JSA(IB)

2.126 Claimants who have a low income and do not have the resources to pay their rent without help may face hardship if there are delays in paying HB and CTB. In common with other LAs Lambeth has a high proportion (60%) of claimants who were in receipt of IS/JSA(IB).

2.127 Verification of IS/JSA(IB) was poor. This is surprising as Capita has 2 RATs and a RAT enables an LA to confirm receipt of IS and JSA(IB) without having to make enquiries to BA. Written requests from Capita to BA for information on form NHB5 should only therefore be made in exceptional circumstances.

2.128 Full and proper use of a RAT speeds up the verification process and significantly reduces the number of NHB5s and telephone enquiries between an authority and BA.

2.129 We found that Lambeth made poor use of the RAT. In particular, we found that:

· in our sample of renewal claims 4 cases where the RAT had not been used to confirm receipt of IS or JSA(IB)

· one case where 3 RAT enquiries had been made where only one was necessary

· Lambeth places the onus on the claimant to provide proof that they are in receipt of the qualifying benefit.

2.130 We also found that:

· BA at Balham was receiving an average of 30 NHB5s and 50 telephone enquiries a week from Lambeth, seeking confirmation of benefit status

· ES staff have recently been instructed not to issue handwritten letters to claimants seeking proof of receipt of JSA(IB), but to refer all such enquiries to BA.

Verification of capital

2.131 Our analysis of the new and renewal sample claims indicated that Lambeth needs to do more to verify capital on standard HB and CTB claims.

2.132 In 7 (14%) of the 48 claims in our sample that were not linked to IS or JSA(IB) entitlement, we found that capital had not been verified. In a further 9 cases (19%) we found indications that a claimant might have undeclared capital. We found one case where the claimant was being paid earnings direct into their bank account, but had not declared a bank or building society account and Lambeth had done nothing to pursue this with the claimant. The claim had been assessed on the basis that no capital was held. To illustrate Lambeth’s poor performance in verifying capital, we include case studies in
Figures 2.25, 2.26 and 2.27, from 3 cases in our sample.

Fig. 2.25: Verification of capital – case study 1

Lambeth received a new claim from a claimant who had declared that he had no capital. However, evidence provided in support of the claim indicated that other benefits were being paid to the claimant’s bank account. Lambeth took no action to query this matter with the claimant. This is bad practice because Lambeth had not queried the level of any capital held in the bank account of the claimant.

Source: BFI analysis

Fig. 2.26: Verification of capital – case study 2

Lambeth received a renewal claim form from a claimant who had previously declared savings and also had an occupational pension paid into his bank account. Lambeth did not verify the level of savings held by the claimant at the time the renewal claim was made. In this case Lambeth had not established the level of capital held by the claimant.

Source: BFI analysis

Fig. 2.27: Verification of capital – case study 3

Lambeth received a new claim from a claimant who requested that payment be made direct into her bank account. However claimant did not provide evidence of the level of capital held in her bank account. She did however provide evidence of another account and Lambeth accepted a mini-statement as evidence for this account. This is bad practice because Lambeth had not verified the amount of capital for all accounts declared by the claimant and had accepted a mini-statement as evidence of capital.

Source: BFI analysis

Cross-checks

2.133 Many frauds are found when claimants provide inconsistent information to support their claims. Cross-checking information held about a claimant with previous claims and other LA records and pursuing discrepancies helps to identify inconsistencies and so reduce fraud and error.

2.134 Lambeth told us that as part of the verification process staff cross-check information on claims with previous HB claims and other records. These checks include comparing claimant signatures on claim forms. Additionally, council tax liability is confirmed.

2.135 Our sample of new and renewal claims showed that there were 33 claims where insufficient attention was given to cross-checking information provided by the claimant in support of their claim. Figure 2.28 shows the number of cross-checks that were not carried out, and Lambeth agreed that the discrepancy should have been pursued.

Fig. 2.28: New and renewal claims – cross-checking information
	Number	%
Claims sampled	120	-
Discrepancy not pursued	33	27

Source: BFI analysis

2.136 In addition to Lambeth not following up possible undeclared capital, our sampling showed other examples of inconsistencies not being pursued, for example:

· in 2 cases, HB claims in respect of other persons were filed without any attempt to establish their status in the household and the impact on HB already in payment

· in 2 cases, date of arrival or departure and forwarding addresses were not sought in respect of people who were said to have arrived in or departed from the claimant’s household

· in one case, indications that the claimant was receiving an occupational pension were not followed up

· in one case, a discrepancy with council tax records was not resolved

· in one case, there was no attempt made to establish the status of a fraud investigation or that of an outstanding review before a renewal claim was assessed and paid.

We recommend that Lambeth improves its verification procedures, and reduces the opportunity for fraud and error to occur, by:

· revising its verification procedures to reflect more closely the principles of the VF

· accepting only original documents to substantiate all elements of the claim

· ensuring all relevant information is gathered before a claim is assessed and paid

· paying greater attention to the quality of information gathered

· applying a consistent approach to verifying all elements of a claim

· making greater use of the RAT to check IS/JSA(IB) entitlement

· introducing formal procedures to check residency at the outset of a claim, particularly in RA claims and those involving temporary accommodation outside the Borough

· making sure staff pay greater attention to cross-checking all information provided by the claimant in support of their claim.

Capita management checks

2.137 The 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 standard, identify training needs and help guard against internal fraud.

2.138 We found the number of management checks and the quality of these checks to be poor. We established that:

· Capita senior management does not collect and monitor data on the number and outcomes of checks carried out by team leaders. They were unable to tell us how many checks had been completed the last 3 years

· team leaders complete checks on less than 10% of claims.

2.139 We were told that the need to concentrate checks on trainee staff, pressure of work and the absence of staff responsible for carrying out checks all played a part in checking levels falling below 10%. We also found that there is no structured or documented system in place for the management check of overpayment cases.

2.140 We consider the quality of checks poor because:

· management checking is not transparent. There are no records of checks made held on files or on the benefit system

· we were told by team leaders that checks were often focused on one or 2, rather than all, aspects of a claim and that it was left to them to decide on the scope of a check

· some team leaders were said to give advanced warning of checking or asked assessors to select their own cases for checking, allowing bias, and possibly collusion, to enter into the checking process

· managers do not carry out any "dipstick" checks on the checks carried out by their team leaders.

2.141 We also found that full use is not made of the information checks can provide, for example:

· outcome of checks are not reported up the management chain. An important indicator of work quality is, therefore, missing from the picture

· results of checks are not collated to help inform training needs or to help develop procedures or improve guidance

· assessors "post" their work on Academy before any checks are carried out. Consequently if a check reveals an error, it may be too late to prevent the issue of an incorrect notification letter or benefit payment.

2.142 BFI’s Good Practice Guide outlines the importance of management checks and lists the risks associated with failing to carry out such checks.

We recommend that Lambeth ensures that Capita increases the coverage of checks and ensure the checking level does not fall below 10%. Also, it must introduce procedures to ensure checks are recorded and reported and used to determine instances of poor performance and training needs.

Determinations

2.143 Officers directly employed by the LA can only make legal determinations. While contractors are permitted to carry out preparatory tasks, such as gathering evidence and making recommendations or provisional assessments, they cannot make determinations that are legally valid. We found that procedures at Lambeth failed to ensure that determinations were made at the appropriate time in the benefit process, if at all, resulting in:

· invalid determinations being made by Capita

· a high risk of internal and external fraud and error.

2.144 In addition we found that the work done by the determination officers were not thorough enough to identify Capita’s failure to obtain sufficient evidence or to assess claims correctly.

2.145 Claims included in our sampling showed serious weaknesses in the arrangements for passing assessed claims for determination. In particular, we found that Lambeth:

· had no way of controlling cases to ensure that all assessed cases were subsequently determined

· allowed Capita to "post" claims on the Academy system before they had been determined. In some cases this resulted in payments and determination notices being issued before the claim had been determined. These are illegal payments

· failed to control claims rejected by the determination officer to ensure that:

– such cases were suspended until Capita had made the required corrections and returned them for determination

– rejected cases were returned for determination

· failed to reconcile the number of claims assessed with those determined

· failed to ensure that the determination officer who determined the case signed off all determination certificates.

2.146 Figure 2.29 shows that in 44% of the new claims we sampled, benefit was paid before determination. This is a serious concern.

 

Fig. 2.29: New claims paid before determination
Type	Number sampled	Number paid before determination	% paid before determination
Rent rebate	34	8	23.5
Rent allowance	27	19	70
Total	61	27	44

Source: BFI analysis

2.147 In addition, 3 of the renewal cases we sampled had been reassessed during the benefit year to take account of changes such as rent increases, but these assessments had not been determined. In one of these cases, the assessment had been made without the benefit file, making it difficult to know whether all relevant information was taken into account when the case was assessed.

2.148 The problems with the determination arrangements at Lambeth are highlighted by the following case studies in Figures 2.30 and 2.31, selected from the claims we sampled.

Fig. 2.30: Determinations – case study 1

A new claim was received on 1 October 1999 and assessed by Capita on 27 January 2000. The case involved a single female landlady and a male sole tenant who claimed HB. Rent liability was not verified and, despite the possibility of there not being a commercial tenancy, no further action was taken to establish that a rent liability existed. The determination team rejected the claim on 27 January, yet before the case was amended 6 payments were issued between 27 January and 3 April amounting to £1,815.40. The claim was finally determined on 17 April 2000. Rent liability was, however, never verified and there was no consideration given to the possibility that the landlady and tenant might be living together as husband and wife.

Source: BFI analysis

Fig. 2.31: Determinations – case study 2

A renewal claim was received on 4 April 2000. This was a difficult case with issues around tenancy, rent liability and income that needed to be resolved. The initial assessment work carried out on 3 May was rejected by the determination team, as was the second attempt. The determination team finally cleared the third assessment of 9 May on 15 of May. By this time the claimant had been issued with 3 determination notices within the space of a week, which we can only assume must have been very confusing. Moreover, we consider that although the case had now been determined and paid, questions relevant to benefit entitlement remained unanswered including: how the occupational pension was paid and when it increased, whether the claimant had any savings and whether the tenancy was contrived.

Source: BFI analysis

2.149 In cases where Capita requests additional information or evidence and the claimant fails to provide this within 4 weeks, Capita assumes, at the end of this period, that claimants do not wish to pursue their claims. These cases are then abandoned, without referral to the determination officers. This means that Lambeth is not being given the opportunity to decide whether the information or evidence requested by Capita had been "reasonably required" under HB regulation 73. It also means that there is no assurance that determination decisions are sound and training needs for determination officers may not be identified.

2.150 We found that determination officers, primarily due to pressures of work, are unable to carry out full checks on all of the cases they receive. On the evidence available to us Lambeth were not fully determining claims as required by the regulations. For example on a renewal claim received from a council tenant, they would usually only check:

· the applicant’s signature

· the date the claim was received

· proof of income and capital.

2.151 Consequently, determinations on matters such as non-dependants, input of details, notices of determination and benefit period will not normally be undertaken on such cases.

2.152 If determination officers wish to carry out a full determination over and above those recommended that is a matter for them. There is no further guidance or target set in this respect, even though it was a legal requirement.

2.153 Determination officers told us that time constraints meant that if a major error in an assessment is found the case is returned for correction without any further errors being looked for. This is done on the basis that assessment staff should check all other aspects of the case when correcting errors identified at the determination stage.

2.154 We were told that when an error has been identified and the case is returned, problems can occur when the same case is re-submitted and it is found to contain other errors. This slows down the clearance of cases and can put strain on the relationship between Lambeth determination and Capita assessment staff. In our sample of new and renewal claims we found a total of 7 claims that had been rejected at the determination stage.

2.155 Senior determination officers are supposed to do a 10% check on determinations made. This has never been done due to pressure of work

2.156 Although the senior determination officers discuss individual cases with their staff, for example those cases where there is disagreement between a determination officer and Capita assessment staff, they do not keep a record of these to help inform training needs or the need to review procedures or guidance.

2.157 We consider the situation, coupled with the failure to determine all HB and CTB, to be very serious. Payments are being made illegally.

We recommend that, to comply with the legislation and reduce the opportunity for fraud and error to occur, Lambeth must immediately draw up and implement procedures with Capita to ensure that:

· all assessed cases are received by the determination team, including those that have been returned for correction and abandoned cases

· system action to pay benefit and issue notifications is suspended until a determination has been made

· the number of assessments made are reconciled with determinations made

· determination officers make a full determination

· senior determination officers carry out a 10% check of determination made to monitor the quality and improve consistency of determinations made

· information collected on rejected assessments is put to full use to help improve the quality of assessment work and to clarify the roles and responsibilities of assessment and determination staff

· staffing levels are appropriate to provide for the above.

2.158 Implementing this recommendation will:

· ensure that Lambeth complies with legal requirements

· improve the accuracy and integrity of the award of benefit

· reduce the number of incorrect payments and notifications sent to claimants.

Speed of processing

2.159 Regulation 76(3) of the HB Regulations states that claims must be determined within 14 days of the relevant information having been received or as soon as is reasonably practicable thereafter. There is a similar provision in the CTB Regulations.

2.160 Figure 2.32 shows Lambeth’s 14-day performance in determining new claims since 1997/98.

Fig. 2.32: % of new claims determined within 14 days of receipt of all information
	1997/98	1998/99	1999/2000
RR claims	29.33	33.81	35.25
RA claims	29.05	39.31	48.30

Source: Lambeth

2.161 We analysed our sample of new claims to identify those determined within 14 days of receipt of all information. We found that Lambeth’s overall performance has not improved during the 2000/01 financial year and remains poor. The results are shown in Figure 2.33.

Fig. 2.33: New claims sample – claims determined within 14 days of receipt of all information
Time taken to determine	Number	%	Average time (days)
Within 14 days	21	34	7
15 – 28 days	14	23	21
Over 28 days	26	43	128

Source: BFI analysis

2.162 Figure 2.34 shows that 77% of the new claims in our sample took over 28 days from date of receipt to determination. This shows that there is considerable scope for Lambeth to improve the speed with which it processes new claims.

Fig. 2.34: Time taken from claim receipt to determination date
Time taken	Number	%	Average time (days)
Within 14 days	5	8.2	9.2
15 – 28 days	9	14.8	24.88
Over 28 days	47	77	129.48
Total	61	100	104

Source: BFI analysis

2.163 We further analysed our sample of new claims to identify the time taken between the main steps of assessing a claim. We found significant delays throughout the process. The results and the average and minimum and maximum number of days taken are shown in Figure 2.35.

Fig. 2.35: New claims processing
Work step	Average days	Range days
Date of receipt to date of first action	36	0 – 224
Date of all information to date of assessment	45	0 – 256
Date of receipt to date of assessment	87	0 – 256

Source: BFI analysis

We recommend that Lambeth urgently reviews its processes to improve processing times as this delay in assessing claims causes hardship to claimants. To do this it should:

· ensure that all claims are looked at promptly on receipt, so that further evidence can be requested immediately

· make effective use of management information to monitor whether claims are assessed within timescales

· ensure staff are aware of priorities and necessary deadlines

· use management checks to ensure processes are being kept to

· consider whether current resources are adequate.

Payments on account

2.164 Regulation 91(1) of the HB Regulations requires LAs to make a payment on account (POA) where they are unable to determine a RA claim within 14 days, and the inability to do so has not arisen out of the claimant’s failure to provide the necessary information to determine the claim.

2.165 As Lambeth has had a significant backlog for some time, we looked at our sample of new and renewal claims to see whether POAs were being made when required. The results are shown in Figure 2.36.

Fig. 2.36: Analysis of POA performance in sample cases
	Number	%
Number of RA cases where POA made	20	-
Number of cases where a POA should have been, but was not made	7	35
Number of POAs made	13	65

Source: BFI analysis

2.166 In our sample, all the cases had been delayed due to the backlog and Lambeth failed in its statutory duty to make a POA in 7 claims. There is no monitoring to ensure that claims with all necessary supporting information are passed for provisional assessment on day 15.

2.167 One consequence of this failure is that tenants can accrue rent arrears through no fault of their own. This has been commented upon by the LGO and we return to the issue later in this report.

We recommend that Lambeth should ensure that Capita puts in place procedures, supported by documentary guidance, to refer all cases for POA determinations if a full determination has not been made by day 15. Lambeth should also ensure that Capita implements the necessary monitoring arrangements to make sure POAs do not continue beyond a maximum period of 13 weeks.

Performance monitoring

2.168 It is essential that all benefit officers delivering the service understand what is required of them. This requires management to set well-defined performance standards and monitor achievement against these. These should include standards for processing benefit claims and cover compliance with legislation and processes.

2.169 We were told that all Capita managers are on performance-related pay, so there are real incentives for service targets to be achieved. It is surprising, therefore, that there are no formal productivity targets, performance standards or monitoring of staff output. We discussed this with Capita who informed us that staff would normally be expected to action 20 cases per day, but because of the problems faced by the LA it was "pleased" if 15 or 10 cases were actioned.

2.170 Lambeth and Capita have not agreed and set clearly defined performance standards for staff. In addition there are no procedures to check the accuracy or validity of the statistical data provided by staff.

2.171 The absence of well-defined, measurable targets and monitoring procedures means no assurance can be given on the accuracy or validity of the performance data of the benefits section. The current procedures provide no incentive for staff to process benefit claims accurately or quickly and hinder the effective administration of HB and CTB.

We recommend that Lambeth urgently reviews its current performance monitoring arrangements with Capita to clearly define the standards of performance required by processing staff. To do this it should:

· set well-defined performance standards that include standards for processing benefit claims and cover compliance with legislation and processes

· monitor achievement against the performance standards

· devise and implement procedures to check the validity of the statistical data provided by staff.

Working with BA

2.172 Lambeth’s ability to administer HB and CTB claims effectively and efficiently depends on good working relationships with BA. This is because 60% of its HB/CTB claims are linked to IS/JSA(IB) entitlements. And in many of the remaining claims other benefits administered by BA are in payment.

2.173 An effective partnership between an authority and BA can provide mutual benefits:

· through savings on administrative costs and benefit expenditure

· by reducing the amount of fraud and error.

SLA

2.174 To set the framework for closer working at operational level, it is essential that organisations develop and agree relevant SLAs, which reflect local issues on benefit administration and counter fraud activity.

2.175 The SLAs should reinforce the government’s strategy on countering fraud set out in A New Contract for Welfare: SAFEGUARDING SOCIAL SECURITY.

2.176 There is a current signed SLA for 2000/01 between Lambeth and the Parkside Group of BA. This is co-ordinated by the liaison officer at Belfast Benefit Centre. The signatories are the Benefits Policy Manager for Lambeth and the Manager of the Belfast Benefit Centre and the Income Support manager on behalf of the SW Thames District of the BA.

2.177 An annual certificate of performance should be signed by Lambeth, to confirm that performance meets service requirements. However, we found that the certificate of performance for 1999/2000 had been signed in March 2000 by the Capita Operations Manager and not by Lambeth.

2.178 We found that there was no monitoring of BA performance by Lambeth. The certificate of performance for 1999/2000 does not include any information relating to actual performance against the targets contained in the SLA. The absence of any formal monitoring means that neither BA nor Lambeth has any firm data on which to measure the level of compliance, and therefore no assurance that the standards set out in the document are actually being met.

Liaison

2.179 Lambeth interfaces mainly with the Parkside Group of BA. Parkside administers benefits in 3 geographical Districts:

· Palace District which covers Kensington, Chelsea and Peckham, administered at Makerfield Benefit Centre

· South Circular District which covers Brixton and Lewisham, administered at Belfast Benefit Centre

· South West Thames District, which covers Balham, Streatham and Wandsworth, administered at Balham District Office.

2.180 General control of all liaison arrangements is undertaken on a Group basis. Due to the geographical distances involved, liaison meetings are held over 2 days at Wigan in March, June, September and December. Liaison meetings are held at Wigan, as Belfast attendees are unwilling to travel to London. These meetings are co-ordinated by Makerfield Benefit Centre. Representatives from the 3 BA Districts, CAFT, Capita and Lambeth attend, as well as representatives from the other 12 LAs that interface with the Group.

2.181 We interviewed officers at only Balham BA because:

· it is the only BA office located within Lambeth

· Lambeth only holds BA liaison meetings with the Parkside Group

· the Group processes large proportions of claims.

2.182 We found that there are no arrangements for local liaison meetings between Lambeth and Balham BA. The Manager of the Balham BA wrote to the Lambeth Chief Executive on 13 July 2000, expressing concerns about the lack of local liaison between the 2 organisations, inefficiencies in the exchange of information and the lack of SLA monitoring. We were told that a reminder letter was sent to the Chief Executive on 20 September 2000 and that at the time of our on-site inspection, no reply had been received to these letters.

We recommend that, to improve liaison at local level, Lambeth holds regular meetings with Balham BA, to discuss operational issues, the exchange of information and monitoring of the SLA.

We recommend that, to ensure that performance standards are met, Lambeth:

· monitors the performance standards of the SLA on a regular basis

· discusses the standard of performance with BA at regular local liaison meetings

· takes responsibility for signing the annual certificate of performance.

Validation of NINOs

2.183 Subsections 1(1A) and (1B) of the SSAA 1992 require all HB and CTB claimants and their partners to supply a valid NINO. Where a claimant or partner does not possess a NINO, the LA must forward an application on the claimant’s behalf to BA using a form DCI1. Balham BA has a dedicated validation team to deal with such enquiries. We were informed that, at the time of our inspection, Balham received 12 such applications a week.

2.184 Balham BA staff commented to us that there had been numerous problems in the processing of the DCI1 applications received from Lambeth. For example:

· 25% of cases are rejected due to poor completion of the DCI1

· 25% of cases are rejected because the claimant already has a NINO.

We recommend that, to improve the quality, consistency and security of the DCI1 process, Lambeth ensures that:

· 100% management checks are completed on all DCI1 forms

· all rejected applications are reported to Capita

· discusses the standard of DCI1 completion at regular local liaison meetings with BA.

Working with ES

2.185 It is important that LAs work closely with ES, because claimants who are also in receipt of contribution-based Jobseeker’s Allowance and JSA(IB) are required to attend an ES Jobcentre every fortnight to confirm their entitlement to JSA. A partnership approach will:

· reduce the risk of fraud and error by ensuring that changes of circumstances notified to ES are promptly referred to the LA when HB and CTB are in payment

· save administration costs and benefit expenditure by ensuring that unnecessary enquiries and overpayments are avoided.

2.186 There are 5 ES Jobcentres in Lambeth. We found that Lambeth does not work closely with ES for the following reasons:

· there is no SLA

· there is no nominated liaison officer in ES or Lambeth

· there are no staff exchanges or meetings.

2.187 We found that ES staff had recently been instructed not to issue handwritten letters to claimants seeking proof of receipt of JSA(IB), but to refer all such enquiries to BA. This was because ES staff were not their internal procedures.

2.188 ES staff said in interviews that they would welcome closer liaison with Lambeth, including having an SLA covering performance monitoring.

We recommend that, to improve communication with ES, Lambeth ensures that it :

· implements an SLA based on the national model and agrees with ES methods of monitoring performance against the standards contained in the agreement

· appoints a nominated liaison officer

· holds regular local liaison meetings with ES to discuss performance

· arranges for cross training and staff exchanges.

Working with the Rent Officer

2.189 The RO is required to make determinations on rent levels in accordance with the Rent Officers (Housing Benefit Functions) Order 1997. The RO fulfils an important role in setting the maximum HB payable in many cases, thereby controlling expenditure on high rents or properties that are under-occupied.

2.190 Following DSS’s scrutiny of Lambeth’s subsidy claims, DSS questioned Lambeth’s compliance with the requirements of the Rent Officers (Additional Functions) (Amendment) Order 1997 which is now revoked by the Rent Officers (Housing Benefit Functions) Order 1997. Lambeth accepted it had failed to act in accordance with the law for the financial years 1994/95 to 1997/98 and DSS is seeking recovery of subsidy paid in respect of cases which Lambeth failed to refer to the RO. The subsidy being recovered amounts to £20.5 million. It is therefore of concern that Lambeth has failed to introduce the required management and control measures to ensure compliance with the law. Lambeth does not ensure compliance with this provision.

2.191 The RO told us that its relationship with Lambeth is poor. There is no SLA between Lambeth and the Rent Service. Lambeth does not measure the performance of the RO and does not record the time taken for the RO to respond to enquiries.

2.192 If an LA does not request a valid RO determination where appropriate, it is failing to comply with HB regulation 12A(1). The contract with Lambeth states the contractor shall send appropriate cases to the RO. Our sample of new claims showed that referrals were made in all but one of the claims. Figure 2.37 provides details.

Fig. 2.37: Analysis of RO referrals sent in sample of new claims
	Number	%
Referral sent	13	93
Referral not sent	1	7
Total	14	100

Source: BFI analysis

2.193 To assess the quality of referrals sent by Lambeth, we analysed the referrals returned from the RO and received at OMH on 20 September 2000. In total there were 93 referrals received, including 20, which had been rejected by the RO. We analysed the reasons for the rejections and the details of our findings are shown in Figure 2.38.

 

Fig. 2.38: Reasons for RO rejections
Reason	Number	%
Decision made within last 12 months	7	35
All relevant information not provided	12	60
Duplicate referral	1	5
Total	20	100

Source: BFI analysis

2.194 We found that the information provided by Lambeth is of poor quality and there is no control over the referrals made. This results in inappropriate referrals being sent. Dealing with such work is resource-intensive for the RO and Lambeth.

2.195 HB regulations 12A(3) and 12A(4) require authorities to make the referral within 3 working days of the claim or change of circumstances giving rise to it, or as soon as practicable thereafter.

2.196 To measure the time taken for Lambeth and the RO to complete the referral and determination process, we further analysed the referrals returned from the RO and received at OMH on 20 September 2000. We found that there are delays throughout the whole RO referral process. Benefit processors input data to the Academy system and RO referrals are produced overnight and are printed at the West Malling Capita site. Internal courier then returns the referrals to OMH via the Bromley Capita site. The referrals are then sent by second class Royal Mail to the RO. The results of our analysis are shown in Figure 2.39.

Fig. 2.39: Analysis of delays in RO determination process
Process	Average days taken
Time between date of dispatch from OMH to receipt at RO	146
Time at RO	6
Time between date of dispatch from RO to receipt at OMH	16
Overall time taken	168

Source: BFI analysis

2.197 Analysis of our sample of new claims, which was confirmed during interviews with staff, shows that there is no control over the RO referral process. We established from our sample of new claims that in 6 out of 13 cases (46%) where a referral was made, a reply had not been received from the RO and Lambeth were not taking any further action to obtain RO determinations.

2.198 Of the renewal cases sampled 3 showed there were delays in either requesting or actioning RO determinations as follows:

· an HB application was made on 20 April 1999, but the RO did not receive a referral until 28 July 1999 – over 3 months later. We were told that this delay was due to the backlog of assessment work

· an RO decision received in May 2000 had not been linked to the claimant’s file. This meant that indicative rent levels were still being used to determine HB entitlement. In fact, the indicative rent levels had been used on this case continuously since 1997

· an RO decision received in February 2000 was not actioned until July 2000 when a renewal claim was assessed.

2.199 To establish the number of claims where an RO referral had not been returned we obtained from Capita a management report from the Academy system of all the claims since April 2000 where benefit had been paid on an indicative rent for more than one month. We analysed the data on the list and the results are shown in Figure 2.40.

Fig. 2.40: Analysis of management report
Time taken	Number of claims shown as outstanding
Total over 1 month	1,175
Between 1 month and 2 months	499
Between 3 and 5 months	408
Over 5 months	268

Source: Lambeth

2.200 We discussed our findings with the RO who expressed concern at the number of referrals shown as outstanding on Lambeth’s system. We cross-checked the 10 oldest cases and found that the RO had no record of a referral having been received in 6 cases. According to the RO records, all the remaining 4 cases had been processed and returned to OMH within 3 days of receipt.

2.201 Our testing therefore questions the accuracy of Lambeth’s list showing 1,175 referrals outstanding. We discussed this with Capita and we were told that referrals that have been determined and returned by the RO are held centrally and controlled by the PAT. On receipt of a determination the PAT is responsible for recording its receipt on the Academy system and then referring the matter to the private team to re-assess the claim. Because of the amount of work outstanding at Lambeth it was not possible for us to reconcile the list of the outstanding referrals to identify how many had been sent and returned. Our findings, however, indicate that in many cases the referral has been returned by the RO and Capita had not taken the appropriate action to re-determine the claim.

2.202 It is clear form our sampling and from what is in the contract that Lambeth has no involvement in the RO referral process. It is not for the contractor to pass referrals to the RO, it is a matter for the LA.

We recommend that Lambeth changes its arrangements for creating and sending RO referrals so as to ensure each referral is made by them and not by the contractor.

Pre-tenancy determinations

2.203 Claimants can find out the maximum rent HB will be based upon by asking for a Pre-Tenancy Determination (PTD). Whenever an LA receives a request for a PTD, it must refer the details to the RO within 2 working days of the date of receipt the request for the PTD. When the RO receives a PTD referral, a determination is made in the same way as for other cases referred. The RO notifies the result to the LA and the claimant within 5 working days.

2.204 We discussed the PTD arrangements with the RO. We were told that the procedure has fallen into disuse and very few, if any, referrals are made from Lambeth. We found no evidence in our sample of new claims that the claimant had requested a PTD. The RO told us that, to avoid delays, landlords contact the RO direct and request that a decision is made without involving Lambeth. The RO informs the landlords that the correct procedure involving Lambeth must be followed.

We recommend that, to ensure compliance with its statutory responsibilities, Lambeth monitors its performance in dealing with the RO.

We recommend that, to strengthen its working relationship with the RO, Lambeth:

· develops and signs an SLA with the Rent Service, based on the nationally agreed document

· introduces a mechanism for measuring performance against the targets contained in the SLA

· implements procedures that ensure RO referrals are issued on time on all appropriate cases and that replies from the RO are monitored and actioned as soon as possible after receipt

· introduces procedures for dealing with PTDs

· introduces formal arrangements to meet regularly with the RO so that effective communication takes place.

We recommend that, to improve the efficiency of the administration of work involving the RO, Lambeth:

· ensures data is input to the Academy system

· reviews its arrangements for the despatch of referrals to the RO

· publicises PTDs

· carries out compliance checks to confirm the correct working practices are being followed.

 

Getting it right – recommendations

· We recommend that Lambeth ensures that Capita: · draws up a clear action plan, with achievable targets for clearance of the backlog · nominates an officer responsible for managing the backlog and new work · reviews the resources required for the PAT and ATs · provides accurate management information on the amount of work outstanding · implements a performance management system including a comprehensive checking regime. In addition, to satisfy itself that the backlog of work is being cleared, Lambeth must: · validate the information provided by Capita · closely monitor Capita’s progress towards the clearance of the backlog. (Paragraph 2.48)

· To help Lambeth better secure the benefits service a more efficient and controlled filing and case control system must be provided. We recommend that Lambeth ensures that Capita fully implements the proposals for the revised filing system. (Paragraph 2.51)

· We recommend that, to improve the quality of service provided to those who visit OMH, Lambeth ensures that Capita: · ensures there is an adequate number of reception staff to assist the public · measures the time taken for all public callers to be dealt with at OMH and uses the information to improve service delivery · identifies, records and analyses the reasons callers that visit OMH. (Paragraph 2.63)

· We recommend that, to improve the quality of service provided to those who contact the call centre, Lambeth ensures that Capita: · ensures that all correspondence received is recorded on the IT system · introduces procedures so that the call centre team is aware of the state of work in Lambeth and develops scripts for the call centre team to use when dealing with callers · benefit processors return calls to callers who have requested an update on the progress of the claim. (Paragraph 2.75)

· We recommend that, to improve the reporting of fraud, Lambeth ensures that Capita: · introduces formal arrangements for the call centre team to record allegations of suspected fraud and make necessary referrals to CAFT · ensures procedures are in place to provide feedback to the call centre team on the outcome of fraud referrals. (Paragraph 2.75)

· We recommend that Lambeth reviews and introduces revised post opening procedures immediately. In particular, Lambeth should ensure that Capita addresses the identified weaknesses as detailed above and in Appendix B. (Paragraph 2.79)

· We recommend that Lambeth stops using the shortened renewal claim form immediately as it increases the risk of fraud and error entering the system. (Paragraph 2.84)

· We recommend that Lambeth introduces a single claim form for all types of HB and CTB claims, including renewal claims, thereby ensuring that all relevant information is captured accurately efficiently and as well as fully meeting the requirements of the VF. (Paragraph 2.85)

· We recommend that Lambeth ensures that Capita puts in place procedures to control requests for further information and takes the necessary action to record the receipt of all information on the Academy system. (Paragraph 2.99)

· We recommend that CAFT refers to the benefits section details of all cases where residency has been verified. (Paragraph 2.119)

· We recommend that: · Lambeth reports the outcome of all visits to the AT · CAFT liaises with BA to develop a joint visiting programme and ensure information on visits is exchanged · Lambeth subjects RR cases to the same scrutiny as RA cases · The HD are prevented from influencing the work of the HB section. (Paragraph 2.124)

· We recommend that Lambeth ensures that Capita improves its verification procedures, and reduces the opportunity for fraud and error to occur, by: · revising its verification procedures to reflect more closely the principles of the VF · accepting only original documents to substantiate all elements of the claim · ensuring all relevant information is gathered before a claim is assessed and paid · paying greater attention to the quality of information gathered · applying a consistent approach to verifying all elements of a claim · making greater use of the RAT to check IS/JSA(IB) entitlement · introducing formal procedures to check residency at the outset of a claim, particularly in RA claims and those involving temporary accommodation outside the Borough · making sure staff pay greater attention to cross-checking all information provided by the claimant in support of their claim. (Paragraph 2.136)

· We recommend that Lambeth ensures that Capita increases the coverage of checks and ensure the checking level does not fall below 10%. Also, it must introduce procedures to ensure checks are recorded and reported and used to determine instances of poor performance and training needs. (Paragraph 2.142)

· We recommend that, to comply with the legislation and reduce the opportunity for fraud and error to occur, Lambeth must immediately draw up and implement procedures with Capita to ensure that: · all assessed cases are received by the determination team, including those that have been returned for correction and abandoned cases · system action to pay benefit and issue notifications is suspended until a determination has been made · the number of assessments made are reconciled with determinations made · determination officers cover the full range of issues when checking assessments · senior determination officers carry out a 10% check of determination made to monitor the quality and improve consistency of determinations made · information collected on rejected assessments is put to full use to help improve the quality of assessment work and to clarify the roles and responsibilities of assessment and determination staff · staffing levels are appropriate to provide for the above. (Paragraph 2.157)

· We recommend that Lambeth ensures that Capita urgently reviews its processes to improve processing times as this delay in assessing claims causes hardship to claimants. To do this it should: · ensure that all claims are looked at promptly on receipt, so that further evidence can be requested immediately · make effective use of management information systems to monitor whether claims are assessed within timescales · ensure staff are aware of priorities and necessary deadlines · use management checks to ensure processes are being kept to · consider whether current resources are adequate. (Paragraph 2.163)

· We recommend that Lambeth should ensure that Capita puts in place procedures, supported by documentary guidance, to refer all cases for POA determinations if a full determination has not been made by day 15. Lambeth should also ensure that Capita implements the necessary monitoring arrangements to make sure POAs do not continue beyond a maximum period of 13 weeks. (Paragraph 2.167)

· We recommend that Lambeth urgently reviews its current performance monitoring arrangements with Capita to clearly define the standards of performance required by processing staff. To do this it should: · set well-defined performance standards that include standards for processing benefit claims and cover compliance with legislation and processes · monitor achievement against the performance standards · devise and implement procedures to check the validity of the statistical data provided by staff. (Paragraph 2.171)

·We recommend that, to improve liaison at local level, Lambeth holds regular meetings with Balham BA, to discuss operational issues, the exchange of information and monitoring of the SLA. (Paragraph 2.182)

· We recommend that, to ensure that performance standards are met, Lambeth: · monitors the performance standards of the SLA on a regular basis · discusses the standard of performance with BA at regular local liaison meetings · takes responsibility for signing the annual certificate of performance. (Paragraph 2.182)

· We recommend that, to improve the quality, consistency and security of the DCI1 process, Lambeth ensures that: · 100% management checks are completed on all DCI1 forms · all rejected applications are reported to Capita · discusses the standard of DCI1 completion at regular local liaison meetings with BA. (Paragraph 2.184)

· We recommend that, to improve communication with ES, Lambeth ensures that it: · implements an SLA based on the national model and agrees with ES methods of monitoring performance against the standards contained in the agreement · appoints a nominated liaison officer · holds regular local liaison meetings with ES to discuss performance · arranges for cross training and staff exchanges. (Paragraph 2.188)

· We recommend that Lambeth changes its arrangements for creating and sending RO referrals so as to ensure each referral is made by them and not by the contractor. (Paragraph 2.202)

· We recommend that, to ensure compliance with its statutory responsibilities, Lambeth monitors its performance in dealing with the RO. (Paragraph 2.204)

· We recommend that, to strengthen its working relationship with the RO, Lambeth: · develops and signs an SLA with the Rent Service, based on the nationally agreed document · introduces a mechanism for measuring performance against the targets contained in the SLA · implements procedures that ensure RO referrals are issued on time on all appropriate cases and that replies from the RO are monitored and actioned as soon as possible after receipt · introduces procedures for dealing with PTDs · introduces formal arrangements to meet regularly with the RO so that effective communication takes place. (Paragraph 2.204)

· We recommend that, to improve the efficiency of the administration of work involving the RO, Lambeth: · ensures data is input to the Academy system · reviews its arrangements for the despatch of referrals to the RO · publicises PTDs · carries out compliance checks to confirm the correct working practices are being followed. (Paragraph 2.204)

 

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