Processing of Claims
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Source: BFI inspection assessment
For an explanation about how to read this radar chart see Strategic management.
4.1 HB and CTB are vital payments made to help people on low incomes. Claims should be dealt with quickly and accurately.
New claims - speed of processing
4.2 Regulation 76(3) of the Housing Benefit (General) Regulations 1987 states that every claim must be decided within 14 days of the relevant information having been received or as soon as is reasonably practicable thereafter. There is a similar provision in respect of CTB at regulation 88(3) of the Council Tax Benefit (General) Regulations 1992, which also requires first payment of any CTB to be made within 14 days of receipt of the claim or as soon as reasonably practicable thereafter.
4.3 In addition to the statutory requirements, the Best Value regime also requires local authorities to measure and report the average time for processing new claims and sets a target of 36 days. A target that should be reached by all local authorities by 2005/06.
4.4 Rhondda Cynon Taf was not at Standard for this element because only 78% of all new claims had been processed within 14 days against the standard of 90%. The average time for processing new claims from our sample was 37.6 days, this is only 1.6 days outside the target. Rhondda Cynon Taf did not produce an exception report for claims not reaching the processing targets mainly due to the deficiencies of the benefits IT system.
14-day performance
4.5 Rhondda Cynon Taf completed a self-assessment against this Standard and reported that in August 2002 it processed 75% of claims within 14 days. Our sample of 27 new claims decided between 1 April 2002 and 28 June 2002 confirmed this level of performance.
| Decided within 14 days | |||
|---|---|---|---|
| Type of case | Number of claims decided | Number | % |
Rent Rebate |
16 |
11 |
69 |
Rent Allowance |
11 |
10 |
91 |
Total |
27 |
21 |
78 |
Source: BFI analysis
4.6 Figure 4.2 shows that Rent Allowance claims exceeded the 90% required by the Standard but performance for all new claims fell short. Rhondda Cynon Taf attributed this to the cumulative effect of:
- delays during the unification of all benefits work within the Revenues and Benefits unit in September 2001
- the end of year close down of the benefits IT system for 5 working days in March 2002
- processing time lost while preparations took place for the introduction of the document image processing system
- inadequate procedures in place on the Scanning and Indexing section resulting in some documents being incorrectly indexed and not being immediately available to staff.
36-day performance
4.7 Rhondda Cynon Taf’s self-assessment revealed that its average time to complete the processing of claims was more than 36 working days, and averaged 50 days for the period October 2001 to June 2002, as shown in Figure 4.3.
| Month | Oct 2001 | Nov 2001 | Dec 2001 | Jan 2002 | Feb 2002 | March 2002 | April 2002 | May 2002 | Jun 2002 | Average for period |
|---|---|---|---|---|---|---|---|---|---|---|
Days |
56 |
53 |
48 |
57 |
44 |
63 |
44 |
40 |
46 |
50 |
Source: Rhondda Cynon Taf
Exception reporting
4.8 For a local authority to be at Standard for new claims – speed of processing, it needs to produce exception reports, on claims not meeting the 14-day and 36-day claims processing Standards, which identify the length and reasons for any delays.
4.9 A management report used to monitor and control new claims, lists all claims received and awaiting action but it did not:
- report specifically on claims not reaching the processing targets
- summarise performance at a high level, for example, it does not identify the reason for or length of delays in processing
- identify trends and patterns from the reasons for delays
- analyse peaks and troughs of workloads.
4.10 To demonstrate what can be achieved by using exception reporting, we created the table in Figure 4.4, based on analysis of our sample of 27 new claims.
| Work step | Average days | Range of days |
|---|---|---|
From date of receipt at designated office to date of first action |
9 |
0 – 31 |
From date of first action to all information or evidence available |
19 |
0 – 146 |
From date of all information or evidence available to date of decision |
10 |
0 – 33 |
Total days from claim received to decision |
38 |
7 – 165 |
Date of decision to date of first payment |
3 |
0 – 13 |
Total days from claim received to first payment |
41 |
8 – 172 |
Source: BFI analysis
4.11 Figure 4.4 shows that there were delays across the process, which undermined Rhondda Cynon Taf’s ability to reach Standard. For example, it took on average 9 days from receipt of the claim form to date of first action by the Benefits Assistant, and 10 days from when all information was available to the claim being decided.
4.12 Existing controls also fail to identify other areas of delay, for example, in obtaining information from claimants, where, in our sample, it took on average 19 days. In our sample of 27 new claims there were 18 cases where further information was required from the claimant before the claim could be decided. When we looked at these, we found 7 cases (39%) where repeated responses to written requests for information made by Benefits Assistants were ineffective. Rhondda Cynon Taf accepted that if this level of data shown in Figure 4.4 had been available to them, it would have considered, at an early stage, other methods of obtaining the information, for example through a visit to the claimant’s home or an office interview.
4.13 Figure 4.4 also shows that for the cases we sampled it took on average 3 days from date of decision to payment. A single cheque run was made weekly, on a Friday and while this does not affect performance, it is not good practice as it increases the period claimants have to wait to receive their HB entitlement. In the light of our findings Rhondda Cynon Taf introduced 2 payment runs a week in October 2002, which has resulted in a reduction in the number of telephone and personal enquiries made by claimants. This typifies the positive and responsive attitude of Rhondda Cynon Taf while we were on-site.
4.14 We were told that the current management report would be replaced later this year by more relevant data, available through the document image processing system. However, unless this system is able to accurately track the progress of a claim from date of receipt to decision, a full analysis will not be possible.
We recommend that Rhondda Cynon Taf: |
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Payments on account
4.15 Regulation 91(1) of the Housing Benefit (General) Regulations 1987 requires local authorities to make a payment on account, if:
- they are unable to decide a Rent Allowance claim within 14 days of receipt of the claim, and
- that inability has not arisen out of the claimant’s failure to provide the necessary information, which the local authority has requested whether on the claim form or otherwise.
4.16 Payments on account should only be made when necessary, and for as brief a period as possible, as they are not intended as a substitute for making a full decision and correct payment on a claim.
4.17 We found through our sampling of new and renewal claims and through workshops that the authority was not at Standard for this element.
4.18 We found that Rhondda Cynon Taf:
- made payments on account in appropriate cases
- monitored existing payments on account, however, this could be improved further.
4.19 To reach Standard Rhondda Cynon Taf needs to introduce procedures that ensure that appropriate payment on account cases are quickly identified, for example through daily prioritisation of Rent Allowance claims received by the benefits service.
4.20 Rhondda Cynon Taf told us that it only makes a payment on account when a referral has been made to the Rent Officer. To monitor payments on account, a benefits IT system report is produced weekly, which lists all cases where a Rent Officer referral is more than 25 days old.
4.21 In a sample of 11 new Rent Allowance cases we found 4 where a payment on account was appropriate and had been paid because all the required information had not been received within 14 days. In one of these 4 the payment on account had been in place for more than 4 weeks, so the controls were not wholly effective because of a lack of monitoring.
4.22 Rhondda Cynon Taf could exceed the Standard in this element by developing the benefits IT system reports further to:
- analyse reasons for payments on account
- identify trends and patterns
- make changes to working practices
- identify additional training for individuals and groups of staff
- measure levels of staff performance and implement personal development plans.
We recommend that Rhondda Cynon Taf: |
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Reported changes of circumstances
4.23 Sections 111A and 112(1A) of the Social Security Administration Act 1992 (as amended) created specific legal offences relating to social security benefits making it an offence to dishonestly or without reasonable excuse to fail to notify a change of circumstances prescribed in regulations under the Act.
4.24 Sections 111A(1A)–(1G) and section 112(1A)–(1F) created offences of dishonesty or knowingly failing to notify changes of circumstances affecting entitlement to benefit or other payment or advantage under the social security legislation which are not changes that are excluded by regulation from the changes that are required to be notified. These offences can be extended to landlords.
4.25 The Best Value regime requires local authorities to measure and report the average time for processing notifications of changes of circumstances.
4.26 Although not at Standard for this element Rhondda Cynon Taf:
- works in accordance with the relevant Housing Benefit (General) Regulations 1987
- uses parts of the HB and CTB claim forms to refer to the need to report changes of circumstances promptly to the authority, although the consequences of not reporting changes are not explained
- uses the benefits IT and document image processing systems to control future action on cases, for example, to identify when a social security benefit is due to terminate
- reminds claimants to report changes of circumstances through its decision notices and claim forms, and, in the case of decision notices, informs claimants of the consequences of not reporting changes of circumstances
- requires claimants to provide the same level of supporting evidence for changes of circumstances as for new and renewal claims.
4.27 To be at Standard Rhondda Cynon Taf needs to ensure it meets the Standard for processing reported changes of circumstances within 9 days and amend its claim form to state the consequences of not reporting changes of circumstance.
4.28 Figure 4.5 shows that 23 (58%) cases in our sample of 40 were processed within Standard. The remaining 17 (42%) of cases were outside Standard and a 7-day target set by Rhondda Cynon Taf as part of its Best Value Improvement Plan.
| Days | Number of claims | % |
|---|---|---|
0 – 9 |
23 |
58 |
10 – 14 |
6 |
15 |
15 – 21 |
6 |
15 |
Days |
Number of claims |
% |
22 – 34 |
1 |
2 |
More than 35 |
4 |
10 |
Total |
40 |
100 |
Source: BFI analysis
4.29 Rhondda Cynon Taf now plans to introduce improved control procedures, using reports produced by the document image processing system, to drive up performance levels.
4.30 Although missing the 9-day Standard, Rhondda Cynon Taf processes changes of circumstances in accordance with the relevant Housing Benefit (General) Regulations 1987. For example, when dealing with a change which results in an HB and CTB overpayment, the Benefits Assistant had in all cases taken steps to establish the earliest date of change and reassessed the case from that date rather than the date the reassessment had taken place.
4.31 Claimants are required to provide the same level of supporting evidence for changes of circumstances as for new and renewal claims, for example, we found correspondence sent to claimants requesting information to verify capital.
We recommend that Rhondda Cynon Taf: |
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Renewal claims
4.32 Regulation 72(14) of the Housing Benefit (General) Regulations 1987 and regulation 62(15) of the Council Tax Benefit (General) Regulations 1992 require local authorities to invite a claimant to make a claim for a further award of benefit when a benefit period:
- exceeding 16 weeks is due to end within the next 8 weeks and no claim has been received
- is brought to an early end because entitlement or receipt of IS or JSA(IB) has stopped.
4.33 The Best Value regime requires local authorities to measure and report the percentage of renewal claims processed on time.
4.34 We found that Rhondda Cynon Taf is at standard in this element apart from the use of exception reporting to monitor any delays.
8-week renewal target
4.35 Rhondda Cynon Taf invites further claims by sending out claim forms within 8 weeks of the expiry of the current benefit period. However, this was only achieved by extending benefit periods. The benefit periods were extended because:
- additional workload resulted from the transfer, in September 2001, of Rent Rebate cases from Community Housing Division to the Benefits service
- Rent Allowance cases were aligned with Rent Rebate cases, following the transfer of Rent Rebate cases from Community Housing Division.
4.36 All renewal claims were issued to claimants at 4 specific times during the year, 8 weeks before the end of the benefit period. Since November 2001 all renewal claims are reviewed taking account of the date of claim. This allows Rhondda Cynon Taf to:
- plan and make better use of resources by spreading the processing of renewal claims over the whole year
- tailor benefit periods to coincide with changes of circumstances and thereby improve the accuracy of the award of benefit.
Monitoring and control of renewal claims
4.37 Since 1 July 2002 Benefits Assistants have been able to log receipt of completed claim forms on the document image processing system.
4.38 A report is produced 4 weeks before the end of the benefit period by the benefits IT system, which identifies renewal claim forms that have not been returned. Benefits Assistants use this report to issue a reminder to the claimant, having checked the document image processing system to confirm a form has not been returned.
4.39 Where no claim form is received by the end of the benefit period, the Benefits Assistant terminates the claim and issues an appropriate decision notice to the claimant. We were told that claim details are referred to the Benefit Fraud team to follow up.
4.40 The reminder gives the claimant the opportunity to contact Rhondda Cynon Taf. Procedures could, however, be improved. For example:
- in Rent Allowance cases, where HB and CTB is paid direct to a private landlord or a Registered Social Landlord, a copy of the reminder should be sent to alert the landlord that the benefit period is about to expire and a renewal claim form is outstanding. This will encourage contact to be made with the tenant
- a check should be made on the benefits IT system to establish if there is a history of claimant failure to return forms, or to establish if the claimant has problems with reading or writing. In these cases a member of the Benefits service should make a visit to the claimant.
Supporting claimants
4.41 Rhondda Cynon Taf issues guidance on how to support claimants who are sick, aged, or unable to call at one of the authority's offices and require support when completing the HB and CTB claim form. Claimants can obtain help over the telephone or by a home visit. Rhondda Cynon Taf relies on the claimant contacting the Benefits service rather than anticipating where additional support is required, but it has identified the need to provide a more proactive service to vulnerable people. As part of the restructure of the Revenues unit, Rhondda Cynon Taf has expanded the role of visiting officers. These officers were undergoing training at the time of our inspection.
Extending benefit periods
4.42 Our sample of 20 renewal claims showed that benefit periods did not exceed 60 weeks in any case and there had not been a break in payment in any of the claims. This performance exceeds the Standard of 83% of claims to be decided upon before the expiry of the current claim.
Exception reporting
4.43 A report of outstanding renewal claims is produced by the benefits IT system and used to control claims. The report contains details of all outstanding claims but it does not identify what time is taken on the various stages of processing claims.
4.44 Figure 4.6 shows the average times taken at each processing step for our sample of 20 cases.
| Work step | Average days | Range days |
|---|---|---|
From date of receipt (at designated office) to date of first action |
3 |
0 – 39 |
From date of first action to all information or evidence available |
1 |
0 – 13 |
From date of all information or evidence available to date of decision |
18 |
2 – 63 |
From date of decision to date of first payment |
6 |
1 – 24 |
Total days from claim received to first payment |
28 |
7 – 78 |
Source: BFI analysis
4.45 Rhondda Cynon Taf accepted, in the light of the findings in Figure 4.6 that the management controls and exception reporting mechanisms were not sufficient to ensure that Standards were met. The authority agreed to review existing exception reports to see if they could be adapted to provide more focused information and stated that once sufficient information is stored on the document image processing system, it would be possible to produce management reports that better inform operational procedures.
We recommend that Rhondda Cynon Taf: |
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Verification policies and procedures
4.46 Local authorities must verify information supplied by claimants to decide entitlement to benefit. This is an essential part of securing the gateway to the HB and CTB systems. The Housing Benefit (General) Regulations 1987 require that:
...a person who makes a claim shall furnish such certificates, documents, information and evidence in connection with the claim…as may be reasonably required by the appropriate authority to decide that person’s entitlement to housing benefit...
4.47 There is a similar provision in the Council Tax Benefit (General) Regulations 1992.
4.48 Rhondda Cynon Taf has not implemented the Verification Framework and does not have a written policy or procedures for verification but it provides staff with a training aid. The training aid states that original documents must be provided for verification of identity, but in practice photocopies of supporting evidence are accepted from the claimant, even though the HB and CTB claim form advises claimants that original documents must be provided. This training aid covers all aspects of verification except for those required for non-dependants.
4.49 We found that, if a verification policy and procedures were in place, ensuring original documents only were accepted, Rhondda Cynon Taf would be at Standard in this element.
4.50 As well as the training aid Benefits Assistants:
- have received fraud awareness training from the Benefit Fraud team and apply this knowledge when scrutinising claims. For example, by comparing signatures on past and current claim forms
- have a good understanding of the importance of undertaking verification checks
- seek further information from the claimant until satisfied that they have a full picture of the claimant's circumstances.
4.51 Figure 4.7 shows the verification practices at Rhondda Cynon Taf.
Verification work area |
% of cases where verification was complete in our sample of 47 new and renewal claims |
BFI comments |
Identity and National Insurance Number for claimant and partner |
100 |
Training aid instructs staff to accept 2 sources of original evidence, for example:
|
Liability to pay rent and residency |
100 |
All supporting evidence in our sample was signed and date stamped original seen. |
Receipt of IS and JSA(IB) |
94 |
In our sample of 47 new and renewal claims 34 (72%) claims were linked to entitlement to IS or JSA(IB). All 19 new claims were verified to Verification Framework standards, but of the 15 renewal claims, there were 2 (13%) cases where entitlement to IS or JSA(IB) had not been verified. Sampling showed that entitlement is verified using:
|
Income and capital |
93 |
In our sample of 47 new and renewal claims:
Income was not verified in one (7%) renewal case and income had not been verified in one (7%) new case. |
Non-dependants’ circumstances |
100 |
Interviews with staff revealed that photocopies of supporting evidence are accepted from the claimant but original documents had been obtained for all cases in our sample. |
Source: BFI analysis
4.52 Figure 4.7 demonstrates strong, but incomplete, verification in the absence of written policies and procedures. To be sure that staff are adopting a totally consistent approach to verification, a written verification policy and procedures should be developed.
4.53 Despite this, a good level of evidence provided by claimants was held in the claim file or on the document image processing system. All evidence had been date stamped original seen. However, evidence received was not recorded by staff on the benefits IT system or on a locally produced control sheet, resulting in a failure to provide an audit trail of the action taken to verify a claim correctly.
4.54 Ultra-violet scanners are provided in all offices and are used to verify the authenticity of documents provided by the claimant.
Cross-checking of renewal claims
4.55 During our sampling exercise we found evidence to confirm that cross-checking had taken place and information had been followed up, for example there were letters to claimants requesting clarification as information provided to support the current claim did not match existing records. However, we found no evidence that the information gained from the cross-checking process had been documented on the benefits IT system or document image processing system.
Management checks
4.56 The Quality/Control section undertakes management checks to confirm that staff comply with existing instructions, but the checks do not ensure that only original documents have been accepted.
We recommend that Rhondda Cynon Taf: |
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Verification of identity
4.57 Since 6 September 1999, sections 1(1A) and 1(1B) of the Social Security Administration Act 1992 (as amended) requires HB and CTB claimants and any partner included in a claim to provide:
- a statement of their National Insurance Number and information or evidence establishing that the number has been allocated to them, or
- information or evidence enabling the National Insurance Number allocated to them to be ascertained.
4.58 If a person does not have a National Insurance Number, they should apply for one and provide all the necessary information or evidence to enable such a number to be allocated to them.
4.59 Rhondda Cynon Taf was at Standard for the verification of the National Insurance Number and identity element. Staff obtained sufficient evidence to verify National Insurance Numbers and identity for claimants and partners in all the cases we analysed and they understand the requirements of the relevant Housing Benefit (General) Regulations 1987.
Verification of liability to pay and residency
4.60 Section 130(1)(a) of the Social Security Contributions and Benefits Act 1992 provides that a person is entitled to HB if:
...he is liable to make payments in respect of a dwelling in Great Britain which he occupies as his home
4.61 Similarly, section 131(3) of the Social Security Contributions and Benefits Act 1992 provides for CTB:
The main condition for the purposes of subsection (1) above is that the person concerned –
(a) is for the day liable to pay Council Tax in respect of a dwelling of which he is resident.
4.62 These sub-sections mean that, before a local authority can award benefit, it has to be satisfied about both residency and liability to pay either rent or Council Tax. Rhondda Cynon Taf staff obtained sufficient documentation to verify liability to pay and residency, but they did not undertake visits to confirm residency at the time of our inspection.
4.63 However, the visiting officers will do this in the future, and the implementation of a full visiting programme will enable Rhondda Cynon Taf to reach Standard in this element.
Verification of receipt of IS/JSA(IB)
4.64 The Housing Benefit (General) Regulations 1987, Schedule 3, paragraph 10, Schedule 4, paragraph 4 and Schedule 5, paragraph 5, provide that when the claimant receives IS or JSA(IB) the local authority must disregard a claimant’s income, earnings and capital. There are similar provisions in the Council Tax Benefit (General) Regulations 1992. Before a local authority can assume the claimant has no income or capital, it must obtain confirmation from Jobcentre Plus that the claimant is in receipt of IS or JSA(IB). Rhondda Cynon Taf did not do this in all cases sampled and was therefore below Standard for this element (see Figure 4.7).
We recommend that Rhondda Cynon Taf: |
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Verification of income and capital
4.65 In cases when HB and CTB claimants are not in receipt of IS or JSA(IB), the local authority must verify the income and capital of the claimant and any partner.
4.66 Rhondda Cynon Taf would reach Standard in this element if all claims are verified to Verification Framework requirements and evidence of verification is recorded on the benefits IT system.
4.67 We found that income had not been verified in one of the 20 renewal cases. The claimant had declared on the HB and CTB claim form that Incapacity Benefit was in payment but this had not been verified. We found one new claim of 27 in our sample, where income had not been verified.
4.68 Rhondda Cynon Taf said that further enquiries would be made with the claimants to determine the correct position in these 2 cases.
4.69 Rhondda Cynon Taf used appropriate documents intelligently to verify income and capital in line with Verification Framework standards. Examples of good practice are:
- Benefits Assistants examine the inside cover of Retirement Pension order books to see if it is annotated with the letter ‘K’, which indicates that the claimant is in receipt of an occupational pension
- bank and building society statements are checked to establish that they match the amount declared by the claimant and to identify any unusual deposits or withdrawals
- the level of income and capital declared on the HB and CTB claim form is compared with previous applications to identify any discrepancies or omissions that need further investigation.
Verification of non-dependants’ circumstances
4.70 HB and CTB are reduced for
each non-dependant normally living with the claimant. It is in the claimant’s
interest to provide details of
non-dependants because the amount of any deduction depends upon the
circumstances of the non-dependant and, if they are in remunerative work, that
person’s gross income. If a claimant does not provide details of a
non-dependant’s income the highest relevant deduction must be applied. Rhondda
Cynon Taf was not at Standard in this element because there are no written
policies, procedures or guidance provided to staff.
Management checks
4.71 Effective management checks provide information about:
- the integrity and security of benefit processes
- the quality of work such as the evaluation of performance against legislative and other requirements
- training and development needs of staff
- weaknesses in processes.
4.72 The Audit Commission, in Countering Housing Benefit Fraud - a Management Handbook, recommends that local authorities quality check at least 10% of claims as a way to prevent errors entering the process at the beginning. The check should take place before a decision notice is sent to a person affected.
4.73 The number of checks undertaken exceeded 10% and Rhondda Cynon Taf ensured that:
- the benefit calculation was correct and lawful
- the claim form was complete, and supported by original documents in respect of the National Insurance Number and identity for both claimant and partner
- a valid Rent Officer decision exists
- a training aid has been produced which describes the accuracy checking process
- there is a dedicated Quality/Control team comprising 6 officers.
4.74 Rhondda Cynon Taf undertakes 2 separate accuracy checking processes. The first process, conducted by a Benefits Officer on the Quality/Control section, is primarily designed as an accuracy check and covers the 10% quality check recommended in the Standards. However, this check is carried out against new claims only. The second process, while primarily concerned with providing assurance of the quality of all correspondence produced from the benefits IT system, has developed into a further quality check. The Senior Benefits Assistant has responsibility for completing these checks, which include all claim types.
4.75 To be at Standard Rhondda Cynon Taf needs to build on these strengths by:
- confirming that the claim is supported by original documents
- targeting high risk cases, for example, the more complicated self-employed cases
- ensuring that cases requiring correction are returned to a supervisor before referral to the relevant Benefits Assistant
- introducing a control mechanism to ensure that cases referred to the Benefits Assistant have been corrected
- setting targets for the time to be taken for the Benefits Assistant to correct the claim
- analysing information gained
from management checks and use this to:
- train and develop staff
- evaluate and revise existing working practices
- compare performance levels against those detailed in various service level agreements with external stakeholders.
4.76 A description of the checking activity is detailed in Figure 4.8.
| Type of management check | Management check undertaken to Verification Framework standards | BFI comments |
|---|---|---|
The claim form is complete. |
Yes |
Checks undertaken by both Benefits Officer Quality/Control and Senior Benefits Assistant. |
All required original documents are available for verifying:
|
|
|
|
Yes |
Checks undertaken by Benefits Officer Quality/Control and Senior Benefits Assistant and original documents provided by claimants to support application. |
|
No |
Although checks are undertaken by both Benefits Officer Quality/Control and Senior Benefits Assistant the training aid states that photocopies are acceptable and it does not clarify under which circumstances photocopies can be accepted. |
|
No |
Although checks are undertaken by both Benefits Officer Quality/Control and Senior Benefits Assistant the training aid states that photocopies are acceptable and it does not clarify under which circumstances photocopies can be accepted. |
|
No |
Although checks are undertaken by Benefits Officer Quality/Control and Senior Benefits Assistant the training aid states that photocopies are acceptable and it does not clarify under which circumstances photocopies can be accepted. |
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No |
Although checks are undertaken by both Benefits Officer Quality/Control and Senior Benefits Assistant the training aid states that photocopies are acceptable and it does not clarify under which circumstances photocopies can be accepted. Earnings certificate used to confirm level of income. We make further comment in Customer services. |
|
No |
Although checks are undertaken by both Benefit officer Quality/Control and Senior Benefit assistant a training aid not available but test check validates that non-dependants income has been verified. |
Type of management check |
Management check undertaken to Verification Framework standards |
BFI comments |
|
Yes |
Checks undertaken by both Benefits Officer Quality/Control and Senior Benefits Assistant. |
That any decision to pay the landlord direct is based on application of the fit and proper person test. |
No |
Guidance not available to staff until training aid was developed during BFI visit. |
The decision on the benefit period has taken into account all known or anticipated changes of circumstances. |
Yes |
Check undertaken by both Benefits Officer Quality/Control and Senior Benefits Assistant. |
A risk criterion has been correctly applied. |
No |
Risk criterion not applied as Rhondda Cynon Taf has not implemented the Verification Framework. |
The calculation of benefit is correct, taking into account all known income, capital and rent liability. |
Yes |
Check undertaken by both Benefits Officer Quality/Control and Senior Benefits Assistant. |
Target checks for high risk cases. |
No |
Checks are undertaken regardless of risk. Opportunity not taken to use management checks to evaluate the effectiveness of training and to check the level of understanding of new instructions, for example, changes to current procedures. |
Monitor outcome to ensure continuous improvement. |
No |
Information not used to inform business needs. The Benefits Officer completes a quarterly summary of errors found, which is collated on a Quality Checking form. This is then passed to the Principal Benefits Officer who uses the information to discuss issues at a monthly meeting between the Principal Benefits Officer, the Senior Benefits Officers and Benefits Officers. |
Maintain audit trail of all management checks. |
No |
No audit trail is maintained for any of the checks undertaken by the Senior Benefits Assistant. The Senior Benefits Assistant does not complete a Quality Checking form, no summary is collated and the results of the checks are not cascaded at monthly meetings. |
Source: BFI analysis
4.77 Figure 4.8 shows the high level of checking undertaken by Rhondda Cynon Taf but also some duplication of effort and ineffective use of resources.
4.78 Rhondda Cynon Taf is now reviewing the checking regime to:
- ensure all cases are referred to a Benefits Officer to discuss the case with the Benefits Assistant
- re-focus the scope and volume of checks
- introduce a management control record to ensure that cases raised as an error are returned to the Benefits Officer (Quality/Control) after correction.
We recommend that Rhondda Cynon Taf: |
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Tailoring of benefit periods
4.79 Housing Benefit (General) Regulations 1987 and Council Tax Benefit (General) Regulations 1992 require that awards are to be for a fixed period, which, when originally decided, must not exceed 60 weeks. Paragraph (2) of each of those regulations requires that:
The benefit period shall be such number of benefit weeks, as the relevant authority shall decide having regard in particular to any relevant circumstances that the…relevant authority reasonably expects may affect entitlement in the future.
4.80 These legal requirements on benefit periods take priority over any generalised risk categorisation procedures followed. However, when they have been applied, the Verification Framework gives guidance on the length of benefit periods that should be allocated to claimants in different risk groups.
4.81 The legal requirements on benefit periods mean that, as well as taking risk groups into consideration, local authorities must also take account of potential or known changes of circumstances that could effect entitlement to benefit.
4.82 To be at Standard in this element the authority needs to:
- introduce procedures to ensure that benefit periods do not exceed 60 weeks
- tailor benefit periods to take account of claimants’ circumstances.
4.83 There were no controls in place within the benefits IT system to ensure that HB is automatically stopped at the 60 week point although a weekly benefits IT system report identifies cases where the benefit period exceeds 60 weeks. Rhondda Cynon Taf told us that 1% of the caseload exceeds 60 weeks and that it is aware of the implications for the level of subsidy received from the Department.
4.84 We did not find any benefit period exceeding 60 weeks in our sample and despite not having the Verification Framework, staff have a good understanding of the need to limit the period of the HB and CTB award to match the claimant's circumstances. The range of benefit periods set in our claims sample was between 12 and 56 weeks and we found only 2 new claims where the benefit period had not been limited to take into account anticipated changes. In one an annual increase in the claimant's private pension had not been anticipated, in the other an annual increase in the claimant's part-time earnings had not been anticipated.
4.85 Procedures are to be introduced to improve controls through the use of management reports available from the document image processing system.
We recommend that Rhondda Cynon Taf: |
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Risk assessing and checking claimants’ circumstances
4.86 Estimates in the second Housing Benefit Review: Main Stage Report, 1998 indicate that around 70% of fraud and error occurs as a result of claimants or landlords failing to report changes of circumstances. It is essential therefore that local authorities carry out checks on claimants’ circumstances. The frequency and type of check may be determined by a number of factors, such as:
- the risk associated with the type of claim
- whether or not HB is linked to IS or JSA(IB) entitlement
- the method used to pay benefit.
4.87 Rhondda Cynon Taf is not at Standard in this element because it:
- does not have a risk management process as outlined in the Verification Framework
- has no mechanism for identifying high-risk claims
- has no procedures to help minimise the risks associated with such claims. In particular, Rhondda Cynon Taf did not:
- analyse notifications of changes of circumstances received. For example, there was no analysis to see if useful data can be obtained regarding the types of claims that need checking during the period of entitlement
- analyse non-returned renewals to help establish whether certain claim types require shorter benefit periods
- record how many claims need further information from the claimant and why
- record the reasons for reassessment of claims
- use fraud intelligence on individuals and groups of claimants obtained by the Benefit Fraud team through its investigations and analysis of data on the fraud case management system.
We recommend that Rhondda Cynon Taf: |
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Requirement to refer to Rent Officer
4.88 The Housing Benefit (General) Regulations 1987 require a local authority to refer certain Rent Allowance claims to the Rent Officer for a determination to be made on the level of rent eligible for HB and to make this referral within 3 working days, or as soon as is practicable. The regulation also provides for an application to be made for a pre-tenancy determination.
4.89 Rhondda Cynon Taf has some strengths in this area, including:
- a current service level agreement with the Rent Service
- a management report to ensure that referrals are returned from the Rent Officer.
4.90 To reach Standard in this element Rhondda Cynon Taf should:
- replace its existing training aid with formal written procedures
- meet the legal deadlines set
for:
- referring cases to the Rent Officer
- making a decision on the claim following receipt of the Rent Officer decision
- ensure that the service level agreement with the Rent Service is monitored and includes timescales, which match those in regulations 12A(3) and 12A(4) of the Housing Benefit (General) Regulations.
4.91 In our sample of 47 new and renewal claims there were 4 claims where a referral to the Rent Officer was required and these had been appropriately made but they took too long to clear. We included a further sample of 7 new Rent Allowance cases and Figure 4.9 illustrates the average length of time taken to process all 11 cases.
| Process | Average days taken |
|---|---|
Time taken for Rhondda Cynon Taf to refer claim to the Rent Officer |
20 |
Time between referral to and decision by the Rent Officer |
16 |
Time taken between decision by the Rent Officer and receipt at Rhondda Cynon Taf |
2 |
Time taken for Rhondda Cynon Taf to process Rent Officer decision |
10 |
Total time taken |
48 |
Source: BFI analysis
4.92 Figure 4.9 shows there is a long delay in the identification of cases that need to be referred to the Rent Officer. Work is not sifted regularly to identify HB and CTB claims that need to be referred to the Rent Officer.
4.93 Referrals sent to the Rent Officer are recorded on the benefits IT system. A weekly report lists outstanding Rent Officer referrals, and any over 25 days old are noted before the report is issued to the Rent Officer.
4.94 A service level agreement between Rhondda Cynon Taf and the Rent Service was introduced in August 2002. Some targets in it did not comply with the timescales contained in regulations 12A (3) and 12A (4) of the Housing Benefit (General) Regulations 1987. For example, the service level agreement states:
in at least 98% of cases send referrals to the Rent Officer within 14 working days and the remaining 2% within a further 2 working days unless special arrangements are made with the appropriate Rent Officer Service Office.
4.95 Neither Rhondda Cynon Taf nor the Rent Officer monitor performance against the levels of service set out in the service level agreement.
4.96 The Rent Officer described the relationship with Rhondda Cynon Taf as "good" with commitment by both sides to resolve any difficulties. There are no arrangements in place to meet periodically, but particular problems are raised over the telephone or fax. The Rent Officer reports no difficulties contacting the Benefits service as a liaison officer has been appointed who can be contacted through a dedicated telephone number.
We recommend that Rhondda Cynon Taf: |
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