Recommendations
Getting it right
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Getting it right – recommendations |
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We recommend that SHMBC: |
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· formally monitors and after 6 months evaluates its introduction of BFI‘s national model claim form. |
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· identifies any further local adjustments to the claim form that could maximise its opportunity to: - get the right information at the first time of asking - clear claims more quickly. |
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· reminds its staff that a minimum of 2 independent items of evidence are required to establish NINO and identity for all IS and JSA(IB) claims. |
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· through its management checking framework, takes steps to ensure that the NINO and identity of IS and JSA(IB) claimants are properly verified. |
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· reminds its staff and revises its management check of rent liability to ensure that: - tenancy agreements are current for the period of the benefit award - rent liability has been verified in all RA claims. |
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· introduces the use of the RAT as the primary source of verifying IS or JSA(IB). |
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· revises its procedural guidance and desk aids to direct staff to use the RAT for: - new claims when a DWP print out has not been received - all renewal claims. |
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· ensures that staff are fully aware of: - what constitutes a thorough scrutiny of the claim form and the evidence provided - the types of information and inconsistencies they should be looking out for. |
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· ensures that evidence of income is obtained in all cases and carefully scrutinised to: - ensure that the correct amounts have been taken into account - identify inconsistency or harmony with all the other aspects of a claim. |
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· ensures that in conjunction with the claim form, evidence of savings and income are scrutinised together to ensure that all validate the financial position declared by the claimant. |
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· ensures that evidence is obtained for all types of capital declared and that the evidence provided: - corresponds with the capital declared by the claimant on the claim form - conforms to VF standards and SHMBC guidance. |
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· ensures that all claim forms and all types of evidence gathered are carefully scrutinised together to ensure that the full extent of a claimant's or partner's capital has been properly declared and verified. |
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· ensures that the capital position declared on the previous claim is cross checked with that declared on renewal. |
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· introduces a systematic means of monitoring and evaluating the key performance standards outlined in its SLA with the RO. |
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· takes steps to identify and analyse the reasons for delay in referring cases to the RO. |
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· introduces controls to ensure that all appropriate cases are, wherever possible, referred to the RO within 3 working days of receiving a claim. |
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· ensures that quarterly liaison meetings with the TRS include the reporting of all the key areas of performance outlined in the SLA. |
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· introduces and takes steps to ensure that no less than 10% of awards are subject to management check. |
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· changes its case selection methodology so that checks are generated on a percentage basis rather than a fixed weekly number. |
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· Revises its guidance and retrains its accuracy checkers to ensure that it: - thoroughly tests the quality, accuracy and security of the claims it examines - systematically checks all evidence provided or still needed, the characteristics of the claim and any other sources available so that it can confirm the claim as genuine - improves performance in the key areas of weakness that we highlight in this report, in particular those surrounding the evidencing of income and capital - introduces independent validation of checks conducted by team leaders to ensure that the correct standard is being consistently applied. |
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· introduces management controls to ensure that: - on receipt, claims are scrutinised immediately and that additional information is requested promptly - the best and quickest route to obtain additional information is used, such as using RAT rather than a clerical enquiry to DWP - claimants are encouraged to respond promptly to requests for additional information for example, by outlining in the letter that 28 days is a time limit and that an immediate response is preferred - reminders are sent to claimants who fail to respond to requests for additional information before the 28 days time limit expires. |
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Keeping it right – recommendations |
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We recommend that SHMBC: |
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· increases the percentage of renewal claims processed before the end of the existing benefit period, by: - increasing its monitoring of outstanding invitations to renew and identifying the actions required to accelerate clearance - changing its system design so that reminders are issued 4 weeks before the end of the existing benefit award. |
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· introduces a formal monitoring and control system to identify claimants who fail to respond to the renewal claim reminder letter. |
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· establishes the reason for a failed renewal claim and obtains full details of when and why benefit was no longer required. |
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· visits all claimants who fail to respond to its correspondence to establish the reason for a renewal claim not being made. |
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· reviews its weekly work prioritisation process to ensure that changes of circumstances that have an impact on HB and CTB amounts are dealt with immediately. |
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· urgently revises its decision notices so that they advise claimants: - of their right to a written statement of the reasons for the decision - that any such request should be in writing and signed by the PA - of the address to which such requests should be sent - of the time limit for doing so. |
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· urgently revises its overpayment decision notices so that claimants are advised of the reason that the overpayment occurred. |
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· raises staff awareness of VF risk assessment and reminds them to thoroughly check the risk group allocated by the IT system in all claims processed. |
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· ensures through management checking that the risk groups allocated to claims comply with those outlined by VF. |
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· further develops its VF IT database and undertakes tests to ensure that the data it holds and the management information it provides is reliable. |
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· introduces a formal reporting mechanism to give managers and staff information about its VF visiting programme. |
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· uses intelligence from the VF visiting programme for risk assessment purposes by identifying the: - types of change that are identified at the VF visit - probable reasons for these changes not being anticipated at the time the claim was processed - types and risk categories of claims where a claimant’s circumstances were found to differ from those declared at the time of the claim - improvements needed in its evidence handling or case control mechanisms. |
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· introduces policy and puts systems in place to ensure that: - landlords whose probity is in doubt are systematically identified - through management instruction, guidance, training and checking, staff are formally and correctly applying the fit and proper person test to these landlords - a list is kept of landlords who are judged not to be fit and proper to receive direct payments. This should be maintained, available and referred to by all staff. In doing so, full account should be given to the provisions of the Data Protection Act. |
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· introduces a formal benefits IT system access policy and supporting procedural guidance. |
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· introduces a formal documentation process that provides an audit trail of all requests for access and de-registration of system users. |
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· introduces a periodic management check of system user access levels to provide assurance that they continue to be commensurate with the posts held by staff. |
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· introduces extended background checks for new recruits to its benefit administration and fraud investigation posts. In doing so: - the rights of the individual, defined in legislation including the Data Protection Act (DPA) and the Human Rights Act (HRA) should be considered - information collected should be securely stored and retained in a manner that prevents confidential information being disclosed in breach of the provisions of the DPA or HRA. |
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· takes into account the training needs identified in this report when formulating its 2002/03 training plan. |
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· promotes the use of RAT and: - ensures that the RAT is used to gain assurance that the correct HB and CTB system indicators have been set - agrees and introduces formal arrangements for notifying Jobcentre Plus of cases where indicators have not been set. |
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Putting it right – recommendations |
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We recommend that SHMBC: |
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· in addition to general fraud awareness sessions for staff, provides feedback to individual staff on the outcome of cases they have personally referred for investigation. |
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· introduces an anti-fraud publicity strategy that makes full use of available media. These should include the use of local press, radio, SHMBC's council tax bills and rent increase notices. The strategy should target different audiences: - claimants - the public - landlords - employees - all other benefit stakeholders. |
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· redesigns its fraud database to capture management information on the reasons for and numbers of: - incomplete referrals received from staff - referrals that could have been avoided by a more thorough examination of the claim and its supporting documents - referrals that were closed without investigation. |
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· systematically analyses the management information it gathers on the quality of referrals and uses it to educate staff, maximise investigative time and drive up the success rate of the referrals it receives. |
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· takes the strongest measures available to it to prosecute landlords found to be committing or colluding in HB fraud. |
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· uses intelligence gathered by its investigation team to identify landlords who are not fit and proper persons to receive direct payments. |
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· revises its procedures to ensure that a WBS is not recorded until the benefits section has confirmed a fraud overpayment. |
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· introduces an enhancement to its fraud database so that gone away cases are provided a specific code that prohibits the recording of a 100% WBS. |
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· re-examines non-residency (100%) WBS claims made during 2000/01 and 2001/02 to ensure their validity and correctness. |
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· introduces a management check that provides assurance that WBS: - claims continue to be valid at the end of the year - recorded and validated on file reconcile with amounts recorded on the fraud IT database. |
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· urgently introduces a formal plan detailing the preparatory work required to introduce LA cautions and administrative penalties and the timescale for their introduction. |
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· urgently introduces procedural guidance and management controls that ensure that all cases that meet the criteria outlined in its prosecution policy are progressed for LA caution or administrative penalty. |
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· introduces written procedures to support its prosecution policy that direct staff to: - undertake IUCs in all appropriate cases - record reasons for discounting prosecution in cases where the fraud overpayment is within the prosecution range - pass the file for formal authorisation of the decision not to prosecute. |
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· introduces a management check by the CRBO to provide assurance that all cases with the potential for sanctions are being properly considered. |
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· takes urgent steps to review staffing levels within the investigation team and recruits an adequate number of staff to support and achieve within SAFE. |
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· introduces formal risk-based assessment to its counter fraud operation. |
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· includes risk assessment as part of its review of its counter fraud resource. |
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· formally records and then systematically reports the outcomes of investigation quality checks to the CRBO. |
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· introduces a fraud hotline publicity strategy. |
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· makes full and regular use of its local media to maintain the spotlight on benefits fraud and its fraud hotline. |
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· systematically monitors fraud hotline usage and outcomes. |
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· actively pursues with BFIS areas for closer working and joint exercises and that these objectives are included in the SLA. |
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· includes a check of overpayment recoverability decisions within its management check of casework quality. |
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· introduces and systematically monitors management information that provides a breakdown of the overpayments that it identifies by classification, volume and amount. |
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· uses the management information it collects to monitor and analyse the reasons why overpayments occur, to identify and introduce operating procedures that eliminate or reduce their occurrence. |
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· updates its procedural guidance to provide more detail on and examples of the classification decision making process. |
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· provides overpayment classification refresher training to both its processing staff and its checking officers. |
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· reviews and revises its management checking approach to ensure that overpayment classification is considered in sufficient depth to provide assurance on the correctness of classification decisions. |
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· works with its IT supplier to introduce system enhancements that provide comprehensive and accurate information on the amount of debt recovered and accounts for the individual methods of recovery used. |
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· puts procedures in place to recover appropriate overpayments from future payments to landlords. |
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· introduces a recovery plan to identify all overpayments where recovery is not in progress and takes urgent action to pursue those debts by using all the powers available to it. |
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· introduces debt recovery targets through which to measure its performance in recovering old, new and overall benefits debt. |
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· reviews its management information so that it can systematically identify and monitor individual cases where recovery has either not commenced or broken down. |
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· undertakes a discrete analysis of all cases where an outstanding debt is over 12 months old to ensure that the appropriate action is taken to recover the debt. |
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· introduces a formal management check that provides assurance that recovery action is being pursued in a timely and appropriate manner. |
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Making sure the strategy works
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Making sure the strategy works – recommendations |
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We recommend that SHMBC: |
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· draws up detailed operational plans that: - identify and take account of the training and tools required by staff to deliver improvements - outline work standards and success criteria - build in key dates for the formal review of and reports on progress to plan. |
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· introduces a benefits specific internal security strategy taking full account of the internal safeguarding recommendations that we make in this report. |
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· introduces a set of operational measures that underpin its high level BVPIs to ensure that the: - quality, accuracy and security of all work undertaken across its Benefits Service is systematically monitored and reported - key components of its anti-fraud strategy and prosecution policy are delivered, especially administrative penalties and LA cautions - recovery of all benefits debt is effectively pursued. |
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· ensures that IA takes a key role in monitoring the Benefits Service’s progress and implementation of its BV action plan and BFI recommendations. |
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