Right benefit: how to effectively maximise performance against the indicator

This section includes good practice on:

• Introduction
• Encouraging and educating customers to report changes of circumstances
• Improving accessibility and responsiveness
• Working with others to maximise the reporting of changes of circumstances
• Maximising the use of available data and intelligence
• Data-matches
• Interventions
• Managing the process

Introduction

The key activities which minimise incorrectness in the benefit caseload are:

• encouraging customers to report changes of circumstance on time
• managing the caseload by finding and actioning unreported changes of circumstances
• managing work processes to reduce the opportunity for official local authority (LA) error

It is important that customers are aware of their responsibility to report changes in their circumstances on time to minimise error arising in ongoing claims. Encouraging and educating customers to report changes themselves reduces the requirements for intervention at a later stage and can avoid the costly business of recovering any resulting overpayment. Therefore it is essential to educate customers so that they understand the need to report relevant changes in their circumstances to promote a culture of self-reporting of changes. All means available should be explored to promote the need to report changes.

Where customers fail to report changes, interventions are a means of identifying them by proactively reviewing claims most likely to have had an unreported change. These are normally selected through some form of risk assessment, or in response to a predicted change that has been diary-dated but not reported by the customer.

There are a number of reasons why customers do not report changes in their circumstances. These include:

• ignorance of the rules
• confusion about what to report (especially when customers are claiming other social security benefits and tax credits)
• confusion about who to report changes to
• difficulties with language or physical access
• intent to defraud

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Encouraging and educating customers to report changes of circumstances

Good practice includes:

• taking every opportunity to remind customers to report changes
• exploring and using a variety of methods to publicise the requirement to report changes, such as:
  • leaflets with decision letters and Council Tax bills
  • include a fact sheet to insert inside each claim form which advises customers how to fill in the form and what information to provide
  • posters in LA reception areas and other suitable locations, such as:
    • libraries
    • leisure centres
    • Registered Social Landlords’ offices
    • Citizens Advice (CAB) offices
    • Age Concern offices
    • pensioners’ clubs
    • neighbourhood centres
    • doctors’ surgeries
    • community centres
    • the staff lounges of larger employers, for example, supermarkets or any other employer where it is known employees receive low pay or there are high numbers of staff who work part-time
  • publicity in the local press
  • issuing leaflets:
    • with local papers
    • with rent statements
    • with all correspondence to customers
    • at every visit
    • each time a customer calls at the LA’s offices
• advertising a free phone number on local radio, TV and the local press to encourage customers to report changes
• providing details of successful prosecutions in the local press
• providing details of customers responsibilities to report change of circumstances in council newsletters/magazines
• developing change of circumstance leaflets and forms to be enclosed with any communications with customers
• issuing change of circumstance forms with annual Housing Benefit and Council Tax Benefit (HB/CTB) award letters
• using a unique identifier code on change of circumstance forms to identify targeted mailshot exercise. This also enables LAs to prioritise some returns over others
• providing a change of circumstances form with the HB/CTB claim form
• producing material in a range of appropriate languages for the area
• undertaking targeted mailshots
• collaborating with other LA departments and third parties such as housing associations and local landlords to reinforce the message
• offering a range of locations and/or extended opening hours to facilitate the reporting of changes of circumstances
• conducting specific road shows to improve HB/CTB take-up, taking every opportunity to remind customers about the need to report changes of circumstances
• using diary dates to alert them to predictable changes of circumstances
• contacting customers following 14 days after the diary date to offer advice and assistance with reporting the change of circumstances
• ensuring the reporting of changes of circumstances is prominent when sending out any type of benefit letter
• identifying and eliminating barriers to reporting changes
• accepting changes reported electronically or by telephone
• providing clear advice and guidance on the claim form
• sending texts to customers after the change has taken place. Sending the text message to remind a customer prior to the change will not educate them to self-report. You should ask the customer from the outset if they would like to be contacted by text message for any reason
• providing a range of products, for example, mouse mats, bookmarks, etc, to serve as a reminder to staff

Improving accessibility and responsiveness

Good practice includes:

• advertising a freepost address to report changes
• accepting the reporting of changes by phone and e-mail
• providing an on-line change of circumstances form
• providing a change of circumstances form with the HB/CTB claim form
• undertaking out of hours visits
• conducting targeted outbound telephone call exercises
• providing pre-paid business reply envelopes
• extending office opening hours
• providing a changes of circumstances tear-off portion on notification letters
• using plain English in notification letters asking customers to report changes that may reduce or increase their benefit entitlement
• ensuring Visiting Officers leave changes of circumstances form with customers
• providing customers with a changes of circumstances form when they attend the LA’s offices
• working closely with the Pension, Disability and Carers Service (PDCS) and Jobcentre Plus to ensure changes reported to it are forwarded to the LA
• reviewing access to services for vulnerable customer groups, including:
  • the elderly
  • disabled
  • customers with language or literacy difficulties

Several LAs have reported some success with new procedures for taking changes of circumstance over the phone. While the customer is on the phone reporting the change, the LA makes an appointment for an officer to call out within the next few days to collect the necessary evidence to support the change.

Working with others to maximise the reporting of changes of circumstances

Good practice includes:

• working with key stakeholders and partners, including Registered Social Landlords (RSL), registered providers (RP) in England, welfare groups, CAB, Age Concern, private landlords etc. to encourage customers to report changes of circumstances
• providing relevant and appropriate training for LA staff, key stakeholders and partners on reporting changes and the consequences of changes that are not reported
• ensuring LA staff, key stakeholders and partners issue changes of circumstances forms
• providing scripts for those who have direct contact with customers to ensure:
  • staff proactively ask customers about known future changes, when they will take place and set diary dates to deal with them
  • customers are continually reminded of the need to report changes of circumstances

Maximising the use of available data and intelligence

Good practice includes:

• setting diary dates for foreseeable changes for example, Housing Benefit Matching Service (HBMS) scans with possible future changes
• conducting regular data sweeps to identify those cases without diary dates/case controls
• scrutinising returned cheques to identify any potential impact on the customer’s claim, for example, they may have vacated their home
• reviewing self-employed cases every three months
• considering customers with shortfalls in their rent and considering visiting those customers within six months to find out how they pay the shortfall
• visiting customers within six months of making a claim
• issuing targeted postal reviews on a weekly basis
• reviewing child maintenance payments to identify any changes in levels of income
• subjecting all privately rented cases to a Land Registry check to see who owns the property and therefore mitigating the risk of tenancy fraud
• establishing when wage/occupational pension increases occur for any large local employer
• targeting known occupational pension increases
• identifying significant birthdays, for example, Tax Credit changes for babies one year old and non-dependants reaching 25 years old
• identifying customers who have vacated their properties
• requesting wage slips in targeted reviews even when there is no change of circumstance reported
• maximising the use of National Fraud Initiative (NFI) results
• considering those fraud referrals received from assessment and customer service staff, including partners/third parties that do not result in an investigation.

Data-matches

Referrals from the Housing Benefit Database Matching Service (HBDMS) are a useful resource for identifying unreported changes of circumstance and LA error, including data input mistakes and unactioned work. The following good practice can equally be applied to internal data-matching, and to the results of the National Fraud Initiative.

Good practice includes:

• having a named officer responsible for co-ordinating the work
• prioritising the clearance of data-matches to ensure that those likely to result in the highest overpayment are dealt with first. These are matches associated with non-declaration, or under-declaration, of:
  • capital
  • earnings
  • Job Seekers Allowance (JSA)
  • Income Support (IS), Employment and Support Allowance (income related) (ESA(IR))
  • Tax Credits
  • Incapacity Benefit (IB) / Employment and Support Allowance (contributory) (ESA (C))
  • State Pension
• identifying early in the sift process those cases that require fraud action. LAs should consider whether it is best use of resources to have data-matches sifted initially by their assessment or their fraud teams
• clearing those referrals where it can be determined that the:
  • change has already been notified
  • change has already been actioned
  • data-match is the result of data input error
  • address has been mismatched and it is clear that the address registered for HB/CTB is correct
  • customer has died
  • customer is entitled to benefit despite temporary absence
  • change means that the customer's income remains below the applicable amount
• maintaining a record of progress on data-matches to make control of cases easier
• carrying out management checks to ensure the work is being completed accurately and fully with the correct codes
• carrying out management checks on the use of HBDMS negative return codes to identify training needs, trends or problems/issues
• requesting lists of outstanding cases from HBDMS to keep track of outstanding work, and ensuring final results on these cases are submitted to HBDMS

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Interventions

Inevitably there will be some changes that are not reported by customers, and not identified through data-matching. Although the Department for Work Pensions (DWP) no longer set targets for interventions, recent research indicates that they are an effective means of sweeping up many of the remaining incorrect claims in the caseload.

Ensure that adequate administrative support is in place to prioritise work and identify the appropriate intervention method based on the level of risk.

Good practice includes:

• ensuring that interventions are selected on the basis of risk using the risk-scored review list provided by HBDMS and/or local risk criteria
• basing the local risk criteria on analysis of existing data including fraud referrals and non-fraud overpayments. LA intervention strategies must comply with the requirements of the Human Rights Act and equalities legislation. Some factors which may be considered for inclusion within a local risk analysis to determine the LA’s interventions criteria are:
  • repeated non-declaration of changes in circumstances
  • frequent house moves
  • short-term fixed income cases
  • seasonal earners
  • wide variation in income
  • self employment
  • hostel dwellers
  • previous fraud referrals which were not subject to an investigation
  • previous fraud investigations
• conducting specific checks/ad-hoc data scans to review:
  • if single persons discounts are still applicable
  • if there are discrepancies  between the Benefits IT system and existing data held by the LA, for example information held on the Electoral Roll
  • customers whose reported capital is close to the threshold
  • customers who report they have capital of £12K and/or stocks and shares
  • customers who are self-employed and whose earnings/circumstances might fluctuate
  • customers who are in receipt of
    • occupational pensions
    • contributory-based JSA
    • statutory sick pay
    • Tax Credits
    • IB/ESA(C)
  • customers who report unchanged levels of capital and earnings
  • customers who are a single parent but not receiving maintenance payments or reporting child care costs
  • registered births and deaths
  • the uprating of other welfare benefits, for example, Pension Credit, IB/ESA(C) or Disability Living Allowance
  • the occurrence of minimum wage increases
  • any financial discrepancies in right to buy applications and the source of their money
  • the existence of non-dependants by cross-checking parking permits
  • students who potentially may have changes of income, for example, university students in June
  • the financial status of non-dependants in receipt of IS
• using partial reviews to concentrate on one aspect of the claim which is most likely to have changes
• making best use of resources by effectively targeting activities at the claims most likely to yield unreported changes of circumstance
• having an interventions strategy that enables staff to identify the most appropriate method of intervention in relation to the risk associated with the claim. Each of the intervention methods – visit, postal review or telephone – may be more appropriate in some cases than in others
• reviewing new claims after two weeks and 13 weeks
• visiting all addresses where post has been returned

LAs may find the following based on LAs’ experiences helpful.

Visiting

Visiting is an effective method of intervention. Visiting can also help to establish residency.

Good practice includes:

• in high risk cases consider whether an accompanied visit is appropriate
• notifying visits allow customers time to obtain the supporting evidence required. However, un-notified visits in certain cases may achieve greater results
• visiting schedules help the visiting officer to manage time more effectively and can include reserve visits to be carried out if time permits
• visiting cards provide reminders of a missed visit and give a contact point to rearrange the visit
• contacting the next appointment customer on completion of the previous visit if the LA keeps a record of customers’ phone numbers
• considering the most appropriate officers to undertake visits. Where benefit assessors carry out intervention visits, they can update claims as required immediately following the visit. This will minimise the number of follow-up requests for information and evidence, as a visiting officer who is inexperienced in assessing claims may bring back inadequate or insufficient evidence for the claim to be reassessed
• visiting officers should be trained in:
  • assessment work enabling them to answer HB/CTB-related enquiries
  • verifying the authenticity of documents
  • risks likely to affect claims verification
  • fraud awareness
• ensure visiting officers are fully aware of the LA's anti-fraud strategy and know when a case is likely to fall within the prosecution policy. Officers will have appropriate guidance for dealing with such cases to avoid the intervention activity prejudicing any subsequent sanctions activity.

Telephone reviews

Telephone reviewing can be used for low risk cases, and in situations requiring a speedy resolution. Customers may want assurance before disclosing their telephone numbers, but many LAs now ask for this information at the initial claim stage. Vulnerable customers can be notified by letter of the intention to review their case by telephone.

Good practice includes:

• making greater use of telephone reviews to capture and action as many changes as possible to remove postal delays
• telephoning customers with predictive changes, such as an increase in IB/ESA(C) or occupational pensions from the date of the predicted change/s to report their change of circumstance in advance
• using the phone to request further information or evidence gives officers an opportunity to explain their requirements, and ensure the customer understands what to provide
• clearing up simple enquiries by phone will reduce processing times by eliminating time taken to send letters and await further information

Postal reviews

Good practice includes:

• reviewing by post may require telephone follow-up, or even a visit, if replies are not received. LAs must ensure that the time allowed for replies does not conflict with the regulations on provision of information, suspension and termination
• targeting postal reviews at an appropriate time of year, for example following the annual increase in a local employer’s occupational pensions, can be effective for lower-risk cases
• ensuring that suspension or termination of claims is only used where reasonable. LAs should not suspend or terminate claims for benefit unless it is likely that there is no further entitlement to benefit
• using a postal review to effectively check information contained in data-match referrals and the risk-scored review list

Managing the process

Some incorrectness in the caseload is caused by weaknesses in administrative procedures, mistakes made by staff, and failure to action work or notified changes.

Good practice includes:

• having a strategy which clearly links to the Fraud Strategy
• setting up a dedicated Change Events team
• monitoring and analysing performance on at least a monthly basis
• breaking down performance into proactive and non proactive work so that it is clear which type of work is generating the most reductions
• carrying out management checks that clearly identify:
  • the date
  • the nature of check
  • the identity of the manager
  • any required remedial action
  • confirmation the remedial action has been taken
• analysing the results of management checks to identify weaknesses in policies or procedures  
• using information from management checks to identify additional training required
• ensuring benefits staff receive appropriate training which is reviewed regularly to refresh their skills
• setting local targets for measuring improvement
• ensuring employees are aware of the need to maintain their declarations of interest and to notify their manager if they are required to assess or review the claims of family members, friends and acquaintance
• ensuring only authorised employees have access to fraud files.

DWP have produced two e-learning packages on error awareness: the Guide for Assessors and the Manager’s Toolkit.

The Right Benefit toolkit contains a range of communication and evaluation products and aims to help LAs plan; implement; analyse; and evaluate results of any activities undertaken to improve the levels of correct benefit within caseloads. A link to the toolkit is shown below:  http://www.dwp.gov.uk/housingbenefit/security/rightbenefittoolkit.asp