Appendix A: Methodology
In this appendix we summarise the method used during BFI’s inspection at SHMBC.
Section 139A(1) Social Security Administration Act 1992 sets out the legislative framework for BFI’s function:
The Secretary of State may authorise persons to consider and report to him on the administration by authorities of housing benefit and council tax benefit.
To undertake this, BFI analyses processes to identify both best practices and areas where an LA could work more effectively and efficiently. The 2 main areas that are considered during the inspection are:
- benefit administration
- counter fraud work.
The inspection process is divided into 3 stages:
- set-up
- inspection
- reporting.
Set-up
BFI met with SHMBC to outline proposals for the inspection, following an invitation from the LA. This meeting included a presentation from SHMBC about its organisation, and from BFI about the inspection process. At this stage, provisional dates were agreed for the capture of data using a questionnaire, for the on-site inspection, inspection dates, the presentation of emerging findings and the drafting and clearance of the report.
Inspection
The inspection process began with an analysis of the data provided by SHMBC and that collected centrally by DWP. A pen picture was developed identifying the perceived strengths and weaknesses of SHMBC in both benefit administration and counter fraud aspects of its work. This pen picture allowed BFI to identify where it needed to concentrate its efforts, in terms of interviewing, data analysis and sampling when carrying out the fieldwork in SHMBC.
The inspection covered areas essential to administer benefits effectively and securely, grouped under the 4 main headings of the government’s strategy for safeguarding social security:
- getting it right
- keeping it right
- putting it right
- making sure the strategy works.
We examine performance in a number of areas. The extent of our examination in each area varies between LAs as it reflects our findings. The following paragraphs explain what areas we could examine under each of the 4 main headings.
Getting it right
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 high 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.
To consider how well an LA deals with claims from the start, the areas we could examine are:
- raising awareness of the HB and CTB scheme
- the claim form used by the LA
- verification of claims
- POAs
- post opening
- dealing with vulnerable groups
- liaison with the RS
- liaison with BA and ES.
Keeping it right
There are 4 crucial elements:
- designing operational procedures that make it as hard as possible for fraud and error to happen, but which are easy to understand and simple to use
- focusing resources where the system is weakest, to target regular checks designed to keep payments right
- keeping contact with the claimant through the period of the claim
- learning lessons from experience and using all available information from all possible sources to spot inconsistencies.
To consider how well an LA deals with claims once in payment, the areas we could examine are:
- decision notices
- benefit periods
- checking claimants’ circumstances
- revisions and appeals
- dealing with landlords
- internal security and controls
- training and guidance
- liaison with BA.
Putting it right
The greater emphasis on securing the gateway to benefit lets fraud investigators concentrate on people who intend to steal. This means:
- ensuring that fraud investigators are well trained
- providing high quality referrals to investigators
- passing on experience and information to other investigators quickly
- publicising the efforts of investigators
- providing investigators with sufficient resources
- sharing information with other agencies as allowed by the law
- recording overpayments and making every effort to recover them
- applying varied and effective sanctions.
To consider how well an LA deals with identifying claims that are wrong and putting claims right after it establishes that the claim is incorrect, the areas we could examine are:
- counter fraud policies and strategies
- fraud referrals
- counter fraud initiatives such as re-directing post and data-matching
- appointing authorised individuals
- managing investigations
- training of fraud investigators
- quality of fraud investigations
- prosecutions and other sanctions
- overpayments
- liaison with third parties.
Making sure the strategy works
Key points are that:
- activity must aim to reduce fraud and error
- the results of counter fraud efforts must be measurable
- organisations must be sure that rules and procedures are followed correctly
- countering fraud is everyone’s business and all organisations must co-operate
- the public understands that cheating the benefit system is a crime.
To consider how well an LA is making sure the strategy works, the areas of performance we could examine are:
- elected Members’ monitoring of the security and effectiveness of the delivery system
- using BVPIs and other performance indicators
- monitoring the speed of processing
- backlog of work
- taking assurance from audit
- monitoring SLAs.
Inspection method
The main elements were:
- a walkthrough of the benefit administration and counter fraud systems with SHMBC officers
- interviewing SHMBC staff, and local BA and ES staff
- seeking expert advice where necessary
- observing SHMBC’s working practices
- inspecting individual benefit claims and claims for WBS and cross checking information in these claims across BA and the LA
- analysing referrals to the fraud team
- examining documents relating to reviews, overpayments and IA work.
Reporting
Initial findings were presented to SHMBC’s benefits management in the course of the inspection. A further presentation of emerging findings taking into account feedback from the initial presentation and also further findings from the continuing analysis was given to the Chief Executive at the end of the on-site phase of the inspection.
The inspection report was drafted around the 4 areas outlined above and findings from fieldwork used to draw conclusions and make recommendations in each of the 4 areas of benefit administration and counter fraud activity.
Draft factual reports were sent to the Chief Executive for comment. Discussions were held with SHMBC about the draft, and written comments were received and fully considered before the report was finalised.