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Instigating repeat claim review process and selecting cases for review visits 4.139 Leicester operates an automated system of rolling reviews, which is an integral part of the benefits software. Leicester's standard benefit period is 52 weeks, although this could be longer if the renewal date comes due in April. This is because the system is off-line due to Council Tax annual billing procedures and up rating to the benefit system. All claims are renewed within the maximum 60 week benefit period because the system automatically stops payment at the end of the 60 week period. 4.140 We question Leicester's use of a shorter repeat claim form for all claimants whose claims are due for renewal, but it does still require claimants to answer questions. Claimants receiving standard HB are also expected to provide up-to-date evidence of household circumstances, income and capital. We provide an analysis of repeat claims at Appendix J. 4.141 Leicester has the same processing time target for repeat claims as it does for processing new claims (10 working days). Management information data provided by Leicester and other LAs to DSS appear to show that Leicester's performance in processing repeat claims is below the reported GB average for the 14 calendar days clearance targets. The data for the stats 124 form is obtained from Leicester's AS400 computer system.
Source: HBMIS stats 124
Source: HBMIS stats 124 4.142 The tables show that Leicester's performance declined between 1994/95 and 1996/97. However, as previously stated, Leicester has expressed doubts about the validity of the national data provided. 4.143 We also analysed the repeat claims received by the teams in May 1998. Once again regard should be given to 2 bank holidays in this month. On average 31.26% of renewal claims took more than 10 working days to process. As many claimants use renewal claims as a means of telling the LA of changes in their circumstances, we find that the delay in processing these claims may have resulted in unnecessary overpayments of benefits.
Source: Leicester City Council Selecting cases for review visits 4.144 The fraud investigation unit carries out targeted review visits 10 weeks before the renewal date. Cases are selected on an estimate of cost effectiveness, such as if enough benefit is in payment to justify carrying out a targeted review visit. Liaison with ES over applications for extended payments 4.145 The inspection team undertook an analysis of claims for extended payments. The results of the sample indicate that Leicester, ES and BA are making payments in accordance with HB regulations. We found that some staff are unclear about the claimant's right to appeal against these decisions and the compensation scheme. Leicester itself does not publicise the extended payment scheme. 4.146 We conclude that Leicester's processes for the handling of repeat claims and extended payment claims are generally robust. Fraud management 4.147 Under section 151 of the Local Government Finance Act 1972, it is the statutory duty of all LAs to make arrangements for the proper administration of their financial affairs. Under the Social Security Administration Act 1992 LAs have responsibility for the administration of the HB and CTB schemes and part of this responsibility includes the deterrence, prevention, detection and investigation of benefit fraud. 4.148 Leicester City Council has a strong anti-fraud culture at both strategic and operational level. This is reflected in the policies and procedures that the authority has implemented and by the increased resources that have been dedicated to the fraud investigation section. Managing investigations 4.149 The fraud investigation unit is a business unit in the internal audit division of the Town Clerk’s and Corporate Resources department. The unit is responsible for investigating cases referred from other departments of the council as well as those referred by the HB section. Work is also carried out in the fraud investigation unit under the Challenge Fund initiative. The head of internal audit has responsibility for the fraud investigation unit and reports to the audit sub-committee about their achievement against WBS targets. 4.150 The fraud investigation unit consists of 14 staff, including managers. Of these, 4 are on fixed term contacts. Reactive referrals 4.151 It is the responsibility of the permanent investigation officers to investigate reactive referrals from all departments of the authority. The majority of referrals come from housing (including HB) with increases in referrals from social services and education. Proactive referrals 4.152 The fixed term contract staff are employed to investigate Challenge Fund proactive referrals. These staff have been employed since the introduction of Challenge funding in the financial year 1996/97. At present there is a clerk, 4 investigating officers and a senior investigation officer who manages the team. 4.153 The Audit Commission report Countering Housing Benefit Fraud advises that
4.154 During discussions with Leicester concerning the employment of fixed term contract staff, we were told that the reason that the Challenge Fund staff are employed on fixed term contracts is because of the uncertainty that surrounds the WBS subsidy scheme. Leicester feels that it would be irresponsible to commit to permanent employment of staff in such circumstances. We suggested that as Leicester had to do anti fraud work anyway, it could second benefits assessment staff to do fraud work, utilising their skills and using the fixed term staff elsewhere. We were told that this would contravene the authority’s equal opportunities policies. However, we feel that Leicester could change this policy in such a way as to not inhibit effective working practices. Recruitment 4.155 Sound recruitment procedures form the first line of defence against internal fraud. Recruitment exercises are the responsibility of the manager, with the Departmental personnel sections carrying out the necessary verification of qualifications and references. Fraud awareness programmes 4.156 The principal investigation officer provides fraud awareness training for the HB section. In addition to this training, which was in place before our inspection, a proposal for job exchange and job shadowing between Leicester and BA fraud investigation staff is also being considered. 4.157 There is an aide-memoire for both fraud investigation and HB staff for handling anonymous telephone calls. XXXXXXXXXXXXXXXXXXXXXX
4.158 We would like to see the aide memoire expanded to help benefit processing staff identify potential fraud from application forms and general correspondence as well as telephone calls. Leicester say that all staff have been issued with the DSS handbook Fraud in Focus which it feels fulfils the role of an aide memoire. Staff training 4.159 Leicester has provided fraud training for their investigation staff using either training provided by DSS or the Local Authority Investigations Officers Group (LAIOG). Leicester state that is very difficult to find good training at a reasonable price. Leicester are currently looking into developments in NVQs and degrees in investigation as ways of making the career path more professional. 4.160 Training provided is varied and uses approaches such as
4.161 A detailed analysis of the training is given at Appendix L. Training new entrants 4.162 The principal investigations officer provides training for all new entrants to the HB section. This half day induction session includes training on the principles of confidentiality and general fraud awareness training. 4.163 The principal investigations officer has also recently provided refresher fraud awareness training for HB assessing staff. 4.164 The principal investigations officer is currently producing written guidance on fraud awareness for new recruits for the Town Clerk’s and Corporate Resources department. It is anticipated that this guidance will be adopted by all departments in due course. Code of conduct guide 4.165 Leicester has a corporate code of conduct for its employees, which is not specific to fraud investigation officers. The code of conduct is issued to all staff. The staff in the fraud investigation unit have access to copies of the LA benefit fraud investigators’ manual to get advice on the professional conduct of investigations. There is also a code of conduct for investigators for dealing with financial irregularities which has been in operation for several years. The Continual Business Improvement (CBI) manual, described below, also includes guidance on protocols for staff making visits to customers. Continual Business Improvement (CBI) manual 4.166 The fraud investigation unit has a detailed quality procedure manual that is updated as and when necessary. There is also guidance on the protocols for making visits to customers. The manual includes detailed guidance on performing various tasks that fraud investigation officers are required to carry out. Each individual task has standards and targets set. Quality control checks 4.167 The Audit Commission report Countering Housing Benefit Fraud states that managers should monitor overall performance and achievements of different parts of the investigation unit and of individual officers within the investigation unit. 4.168 Leicester feel that individual targets are not practical as this would have an adverse effect on the current flexibility of officers to take on urgent cases. We accept that flexibility is essential in fraud investigation, but believe that individual targets are a very effective means of monitoring an individual’s work as well as focusing the work of the section overall. 4.169 Managers in the fraud investigation unit carry out very basic monitoring of the workload of the unit, in that only an individual officer's allocation of work and current case file holdings are monitored. A pilot exercise is currently being run which monitors the quality of the investigation carried out. Each investigation officer has their work checked by a "buddy" before it goes forward to the manager for checking and closure. The buddy is another member of the team who has the same level of responsibility within the unit. Each month the principal investigations officer also monitors the number of referrals received and the total outstanding work.
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