Interface with BFIS
Background
Powys deals with Newtown, Ebbw Vale and Swansea BFIS teams in the Mid and South Wales area. Most of the work done by the Powys fraud staff is in the north of the county, which is covered by Newtown BFIS. Ebbw Vale BFIS is the sector which covers most of south Powys and to a much lesser degree, Swansea BFIS sector covers an area of south-west Powys. This part of the inspection has not focused on Powys’s interface with Swansea BFIS.
The nature of benefit fraud investigations by LA and BFIS fraud staff inevitably means that there will be occasions when both could be investigating the same allegation of fraud. To prevent this, DSS introduced a national model SLA for LAs and BFIS to use. Its aim is to help and formalise the system of liaison and exchange of information used in counter fraud operations at local levels. LAs and BFIS teams can use the model SLA as a basis for setting their own local SLA terms.
Conclusions
Powys deals mainly with Newtown and Ebbw Vale BFIS teams. The fact that the 2 BFIS offices are approximately 70 miles apart means that effective communication between Powys and BFIS is crucial to combating benefit fraud.
Our inspection identified a number of strengths and good practices, including:
- a good, informal working relationship
- the willingness to work together if the opportunity arises
- sharing information when appropriate.
Personal contact between Newtown BFIS and Powys FIOs is frequent and this has helped to forge a good working relationship. Contact in the south of the county between Ebbw Vale and Powys fraud staff is much less frequent and the fact that no SLA exists between Ebbw Vale BFIS and Powys suggests that liaison and exchange of information are not as efficient as they could be.
We also identified a number of areas where there are opportunities to improve, including:
- encouraging exchange visits to help staff appreciate the need for effective liaison
- undertaking a form of cross-benefit training to improve understanding of each other’s role
- where an SLA is in place, monitoring its effectiveness and looking for improvements
- where an SLA is not in place, considering implementation of one
- ensuring the correct liaison forms are used and issued on time to avoid duplication of investigations
- exploring the opportunities for joint exercises.
Findings
We analysed the interface between the 2 main BFIS teams and Powys, using the requirements of the national model SLA as a baseline. Our findings are detailed in Figure E.16.
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Fig. E.16: Interface between BFIS teams and Powys |
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Requirements |
Newtown BFIS |
Ebbw Vale BFIS |
Powys |
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The SLA |
The SLA, in line with the national model, was signed in December 1998, formalising liaison for Radnorshire and Montgomeryshire. |
No SLA is in place with Brecknockshire. Powys approached Ebbw Vale BFIS in November 1998 to consider an SLA, but was told that it would not be appropriate at that time. Previously, Ebbw Vale had approached Powys about an SLA, but no decision was reached. No further contact has been made by either party. |
Brecknockshire FIO deals mostly with Ebbw Vale, but also works with:
Powys does not have an SLA with any of the above. An SLA was agreed with Newtown BFIS in November 1998 and has been in operation for part of Brecknockshire, Radnorshire and Montgomeryshire since December 1998. |
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Provide training for staff to deliver the standard of service as defined in the SLA |
No formal training has been delivered. Staff are familiar with the SLA and, since its introduction, have tried to meet the SLA standards. |
No SLA is in existence, so there is no formal document to follow. No informal training has been delivered. |
No formal training has been delivered. FIOs are aware of the SLA standards and try to work to them. |
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Actively monitor performance |
No formal monitoring arrangements in place. |
No SLA in place to monitor. |
No formal monitoring arrangements in place. |
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Agree methods of performance measurement |
No agreement has been made nor processes put in place to measure performance. |
No SLA in place to measure performance. |
No agreement has been made nor processes put in place to measure performance. |
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Fraud cases which involve HB/CTB and designated benefits |
‘Finders keepers’ arrangement applies. BFIS to notify Powys within 10 days that it will undertake investigation. The above system works well. Newtown issues the appropriate HBF forms on time. If BFIS is unable to investigate, it should refer the case to Powys within 5 days, offering Powys the investigation. We did not find any evidence of this type of case. |
No SLA in place to refer to. ‘Finders keepers’ arrangement applies, but the use of the appropriate HBF forms is not adopted. This has led to duplicate BFIS/LA investigations in the past. |
Radnorshire, Montgomeryshire and the small part of Brecknockshire that deals with Newtown BFIS apply the ‘finders keepers’ arrangement. Powys should notify BFIS within 10 days that it will undertake investigation. The above system works well and the appropriate SLA forms are issued on time. If Powys is unable to investigate, it should refer the case to BFIS within 5 days, offering BFIS the investigation. We did not find any evidence of this type of case. Even though Brecknockshire does not have an SLA with Ebbw Vale, the appropriate SLA forms are issued. We have some concern about the time taken to reply to SLA3 forms. |
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Investigation responsibility |
BFIS investigates claims if social security benefits only are in payment. Staff are aware of this and keep to this requirement. |
No SLA in place to refer to. |
All sites investigate claims if HB/CTB only is in payment, as in the Newtown BFIS SLA. Staff are aware of this and keep to this requirement. Brecknockshire does not have an SLA with Ebbw Vale to follow. |
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Claiming WBS |
WBS is recorded by whoever carries out the investigation and should include any HB/CTB in payment. BFIS staff are aware of the agreement and find that as the ‘finders keepers’ arrangement works well, there have been no problems in obtaining details from Powys to claim HB/CTB WBS. |
No SLA in place to refer to. |
WBS is recorded by whoever carries out the investigation and should include any HB/CTB in payment. Powys’s FIOs are aware of the agreement with Newtown and find that as the ‘finders keepers’ arrangement works well, there have been no problems in obtaining details from BFIS to claim the designated benefits. No SLA is in place between Ebbw Vale BFIS and Brecknockshire to refer to. |
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Exchange of information |
The SLA requires that liaison meetings take place at least every 12 months. A meeting was held in March 1999. Information is supplied to Powys by telephone and in writing, on a regular basis and within legal requirements. Staff have a good relationship with Powys and have no difficulties in exchanging information. |
No SLA in place to refer to. One informal meeting with the Brecknockshire FIO has taken place, but there are no plans for any more unless the need arises. Exchange of information within legal requirements is not problematic. |
The Newtown BFIS SLA requires that liaison meetings take place at least every 12 months. Information is supplied to BFIS by telephone and in writing, on a regular basis and within legal requirements. Staff have a good relationship with Newtown BFIS and have no difficulties in exchanging information. Brecknockshire and Ebbw Vale BFIS do not have an SLA, but exchange information on an informal basis and within legal requirements. |
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Liaison |
Formal liaison procedures have been included in the SLA. No nominated liaison officer has been appointed to monitor the SLA. Staff are aware of the provisions of the SLA, but as the working relationship with Powys is good, informal and regular liaison takes place between the staff. |
No SLA in place to refer to. There are informal arrangements between Ebbw Vale and Brecknockshire and staff work within these arrangements. |
Formal liaison procedures have been included in the SLA. No nominated liaison officer has been appointed to monitor the SLA. Staff are aware of the provisions of the SLA, but as the working relationship with Newtown BFIS is good, informal and regular liaison takes place between the staff. |
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Prosecution, administrative penalty, formal caution policy and case closure |
BFIS has set out its policy in the SLA, which states what action to take in cases of a more serious nature. |
No SLA to refer to, therefore no policies in place. |
Powys has set out its policy in the SLA with Newtown, which states what action to take in cases of a more serious nature. The SLA includes the opportunity for Powys to pass a prosecution to Newtown BFIS if it is unable to take the case forward. |
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Publicity |
Arrangements have been made for publicity of appropriate cases to be dealt with at both local and national levels. Any publicity of HB/CTB fraud is cleared with Powys first. |
No SLA in place to refer to. |
Arrangements have been made for publicity of appropriate cases to be dealt with at a local level with Newtown BFIS. Any publicity of designated benefit fraud is cleared with Newtown BFIS first. |
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Discuss and agree the potential for local joint fraud exercises |
No joint exercises have been undertaken with Powys. |
No joint exercises have been undertaken with Powys. |
No joint exercises have been undertaken with any BFIS office. |
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Provide regular and up-to-date lists of contact points |
Staff are in regular contact and details of any changes in the staffing situation are provided. |
Staff are in regular contact and details of any changes in the staffing situation are provided. |
Staff are in regular contact and details of any changes in the staffing situation are provided. |
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Exchange visits and cross-benefit training |
No formal exchange visits have been held, but contact with Powys is so frequent that an informal exchange has been ongoing for some time. No cross-benefit training has taken place. |
Apart from an impromptu visit to the Brecknockshire FIO in August 1997 no other visit has been made. No cross benefit training has taken place. |
No formal exchange visits have been held, but contact with Newtown BFIS staff is so frequent that an informal exchange has been ongoing for some time. No other exchange visits have taken place and no cross-benefit training has taken place with any BFIS office. |
Source: BFI interviews
Recommendations
We found that there are areas where improvements would provide a higher level of service and formalise liaison between BFIS and Powys. We have provided a recommended action plan for Powys and BFIS at Figure E.17.
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Fig. E.17: Powys/BFIS recommended interface action plan |
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Item |
Issue |
Corrective action |
Lead responsibility |
Priority |
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SLA |
The SLA in place with Newtown does not contain agreed methods of performance measurement, nor is it actively monitored. |
The SLA between BFIS and Powys should be monitored on an ongoing basis and improvements discussed and implemented as necessary. |
Powys/BFIS |
High |
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There is no SLA in place with Ebbw Vale BFIS. |
Consideration should be given to implementing an SLA which should:
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Powys/BFIS |
High |
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Exchange of information |
HBF and SLA forms are not always exchanged correctly and within appropriate timescales. |
The implementation of an SLA with Ebbw Vale should formalise the exchange of HBF and SLA forms. The ongoing situation should be monitored and reported on at liaison meetings. |
Powys/BFIS |
High |
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Discuss and agree the potential for joint fraud exercises |
No joint working exercises or joint prosecutions take place at present. |
Both parties to discuss the potential for joint exercises and joint prosecutions. We acknowledge that geographical barriers may prevent joint exercises in some areas. |
Powys/BA |
Medium |
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Exchange visits and cross-benefit training |
No exchange visits or cross-benefit training take place at present. |
We recommend that both parties discuss the potential for such exercises on an ongoing basis. |
Powys/BFIS |
Medium |
