02 Types of Customer Compliance Referrals

Support for the Very Long-Term Unemployed – pilot guidance for Customer Compliance Officers

Purpose

1.This guidance is for customer compliance officers in the four trailblazer Districts. It will assist Customer pilot officers when dealing with Long-Term unemployed referrals.

2.This guidance supplements the existing customer compliance guidance and must not be used in isolation.

Types of Customer Compliance referrals

High risk referrals

3.In addition to submitting an FRF to report an allegation of fraud, the Customer Compliance team should follow procedures in the Customer Compliance RiskCases guidance and input the FRF to route locally identified high risk referrals through FRAIMS as identified on the RiskPriority List.

4.High risk referrals are recorded on FRAIMS as follows:

• Risk A - (New Claims) Pre-payment LTAHAW/CP;
• Risk B - (Current Claims) Post-Payment LTAHAW/CP;
• Risk C -Recently Separated;
• Risk D -Previously Self-Employed;
• Risk E -WFI Sanction Cases:
• Risk F - R Case Scans;
• Risk G - Ad Hoc Scans authorised by Operational Delivery Support (ODS)
• Risk H – Community Care Grants (CCG)

CCG referrals

5.Referrals will be received by email to the Customer Compliance generic inbox from Social Fund Decision Makers (SFDMs) for pre award CCG application interventions. These referrals have a high risk of error and must be visited before a decision on the application can be made. Only in exceptional circumstances such as a PV marking can these cases be dealt with by office interview. These referrals must not be overloaded.

6.Applications will be referred for a pre award visit when the Decision Maker has decided to make an award and the value of the application is around £500 or over and one of the following national risk criteria apply:

• the customer states three or more main household items have broken down simultaneously or
• the customer is requesting replacement ofall major household items due to wear and tear or
• the customer alleges they have moved into unfurnished property and have nothing and yet the move took place some time ago.

7.Referrals will be received on a proforma directly from the SFDM. The CCO should complete the FRF. These referrals must be dealt with urgently to minimise the impact on CCG clearance times.

FIS referrals

8.Referrals may be received via the Fraud Investigation Service (FIS), prior to interview where information gathering/investigation finds that there is insufficient information/evidence to support a sanction.

Disability Living Allowance (DLA) and Attendance Allowance (AA) referrals

9.Referrals where DLA or AA only is in payment will not be downgraded from FIS to Customer Compliance but returned directly by FIS to PDCS, even when a criminal investigation has not taken place.

10.DLA or AA referrals where a Jobcentre plus benefit is also in payment, such as Income Support or Jobseekers Allowance may be downgraded by FIS but the Customer Compliance Officer will only deal with the Jobcentre plus element. (See sections 06 on Interviews and 07 on Post Interview Action if new and substantial information comes to light during the interview that could affect DLA or AA.

Carers Allowance referrals

11.Where a Carer’s Allowance (CA) case has been downgraded from FIS, the CCO must check that the case has been associated to the FRM PDCS FSU Inbox on FRAIMS, see FRAIMS guidance - Cases with a PDCS interest – Actions by Customer Compliance case owner.

12.If the case has not already been associated, the CCO must take action to associate the FRM PDCS FSU Inbox themselves. Ensure that the activity description field contains details of the CA in payment and the name and contact details of the CCO. This ensures the CCO receives a copy of the latest claim pack and case specific questions to support the CCO interview.

13.Where the case has been routed directly to Customer Compliance via FRAIMS and the case has a PDCS benefit interest, i.e. the offence may have an affect on any PDCS benefits in payment, the CCO must associate the case to the FRM PDCS FSU Inbox on FRAIMS, see paragraph 10.

Child/children not in the household referrals

14.If Department for Work and Pensions (DWP) benefits are in payment because a child/children is/are in the household and a referral is received alleging that the child/children is/are no longer living in the household, takeaction as outlined in FRAIMS guidance - ChildDependency Exception Routing.

15.If no DWP benefits are in payment for the child/children, action must still be taken to ascertain whether the claimant is required tosign on.

Abroad Fraud referrals

16.Via FRAIMS, all FRFs with ‘Abroad Fraud’ selected will route to the Abroad Fraud ‘in box’ in Edinburgh. Those cases that are unlikely to result in a sanction will be handed off to Customer Compliance.

Long Term Unemployed referrals

17.Following an Ongoing Customer Management (OCM) interview with someone who is long term unemployed, the case may be referred by a PersonalAdvisor (PA) for a customer compliance intervention. These must be entered on FRAIMS under ‘OCM’. The contact details of the PA will be shown in the free text box of the FRF.

Training for Work Allowance referrals

18.Occasionally FIS may downgrade cases in circumstances where the

customer is claiming a Training for Work Allowance. These cases should be accepted by Customer Compliance and appropriate action taken, even though the Training for Work Allowance is paid under the Employment and Training Act and is not classed as a benefit.

19.The allowance is based on the customer’s rate of JSA (IB) the day before they began training (less 10p) plus the training premium. The customer is still paid 10p of JSA (IB) in order for passported benefits to be claimed. Please see Section 8 – Claiming an MVA for details of how to claim an MVA in these cases.

Pension Service referrals

20.Currently FRAIMS is unable to distinguish Pension Service referrals from all other referrals. These types of cases should only be routed to Customer Compliance from FIS if the case is unlikely to result in a sanction. They should not be sent to Customer Compliance at the outset.

21.Customer Compliance teams may receive a small number of Performance Measurement referrals- High Suspicion Tracking (HST) cases for Pension customers. These referrals must be actioned and not handed off to PDCS, see paragraphs 15 to 21 for further information. They are identified by the source type Performance Measurement Referral.

22.In all other cases, if the case scores insufficiently and is received by Customer Compliance it should be passed to the relevant Pension Centre to take action. The following action should be taken:

Step / Action
1 / Print the FRF
2 / Close the case on FRAIMS
3 / Return the case to the relevant Pension Centre

GMS referrals

23.Via FRAIMS from the Database and Matching Service (DMS) via Generalised Matching Service (GMS), as per the national GMSRules list.

GMS custodial referrals

24.GMS Referrals are received for customers who have received a custodial sentence. The Compliance Support Officer (CCSO) must immediately sort the cases received into cases paid by direct payment or by cheque payment.

Action to take when customer has been or is due to be released from prison

25.If the prisoner has been released from prison or is due to be released within 4 weeks, the referral must not be closed without interview. If appropriate, BF the case to the release date and arrange for the interview to take place, taking into consideration that the customer has been in prison.

26.Take the following action for customers paid by Direct Payment:

Step / Action
1 / if the customer is in receipt of Jobseekers Allowance (JSA), confirm if evidence of signing has been input after sentencing took place which suggests an active impersonation fraud;
2 / confirm ongoing imprisonment and once received, record on FRAIMS as per “New Case Received – Case Owner Actions’ instructions in the FRAIMS guidance. If appropriate, complete a FRF with the offence type of “ID fraud”.
3 / for all other benefits, confirm ongoing imprisonment
4 / Refer the case to the Benefit Delivery Centre (BDC) via e-mail, for termination and overpayment action. Send hard copies of documents to the BDC and record the activity on FRAIMS as per ‘Benefit Decision, FIS and Customer Compliance’ instructions in the FRAIMS Guidance.
5 / notify the Pension, Disability and Carers Service of the custodial sentence if the customer is also in receipt of Pension Credit.

27.Take the following action for customers paid by cheque payment:

Step / Action
1 / if the customer is in receipt of JSA, confirm if evidence of signing has been input after sentencing took place which suggests an active impersonation fraud;
2 / confirm ongoing imprisonment and once received, record on FRAIMS as per “New Cases Received –Case Owner Actions” instructions in the FRAIMS guidance. If appropriate, completea PPQ with the offence type of “ID fraud”.
3 / if the customer is in receipt of JSA and only advance evidence payment has been made, refer the case to the BDC, via e-mail, for termination and overpayment action. Send hard copies of documents to the BDC and record the activity on FRAIMS as per ‘Benefit Decision, Suspension and Reinstatement’ instructions in the FRAIMS guidance.
4 / for all other benefits consider if the number of cheques issued since imprisonment suggests the active collusion of a third party to maintain the claim. Contact FIS (O) for advice; and
5 / notify the Pension, Disability and Carers Service of the custodial sentence if the customer is also in receipt of Pension Credit.

Follow up action

28.To prevent further payments being made, follow up action must be taken on all GMS Custodial cases. Take the following action:

Step / Action
1 / track the progress of termination action on each case. The BDC should close cases on the same day as receiving the e-mail notification from the CCSO;
2 / claim the appropriate outcomes and close the case as per ‘Closing a Fraud/Customer Compliance Case’ instructions in the FRAIMS guidance.

Performance Measurement - High Suspicion Tracking Referrals

29.Performance Measurement Referrals High Suspicion Tracking (HST) cases now go through FRAIMS and are routed according to the information contained within the FRF. Appropriate referrals are sent directly to the Customer Compliance Inbox.

30.If HST referrals contain sufficient information to pursue a sanction they are automatically routed to FIS by FRAIMS. If, prior to interview, it becomes clear that a sanction is not the likely outcome, the referral is then routed by FIS to Customer Compliance for action. Once received by Customer Compliance they must be actioned as a matter of priority.

31.Customer Compliance Managers must allocate HST referrals timeously via ‘My Team’s Incidents’ on FRAIMS. They should:

Step / Action
1 / select ‘My Team’s Incidents’ in Incident List view;
2 / select ‘Query’ button – a yellow bar will appear across the screen;
3 / click on the yellow bar under the heading ‘Source Type’ – using the drop-down arrow select ‘Performance Measurement referral’.

32.By selecting the ’Go’ button will produce a list of Performance Management referrals allocated to that team. Scroll along the columns until ‘Incident Owner’ header is located. Any Performance Measurement referral not allocated to an individual owner will display the team inbox number.

33.To allocate an ‘unallocated’ case to a CCO, select the hyperlink on the ‘Case Name’ – this should move the user to the ‘Cases’ screen for that individual case. Normal allocation action can be taken. To go back to a list, use the browser back arrow.

34.On receipt, the CCO must give priority to Performance Management referrals allocated. Users should:

Step / Action
1 / select ‘My Incidents’ to locate a Performance Measurement referral;
2 / select ‘Query’ button – a yellow bar will appear across the screen;
3 / click on the yellow bar under the heading ‘Source Type’ – using the drop-down arrow select ‘Performance Measurement referral’.

35.Selecting the ‘Go’ button will produce a list of Performance Management referrals allocated to that individual user.

36.When the CCO identifies the case via FRAIMS they must associate the PM Single Point Of Contact (SPOC) to the Case, see FRAIMS guidance – FIS or Customer Compliance action when a PM Case is received. This ensures the PM SPOC is able to view and track PM Cases and Outcomes on FRAIMS.

37.Referrals should be treated in the same way as any other Customer Compliance case.

38.In cases where the PM team need to contact the CCO, this is facilitated via the FIS Single Point of Contact (SPOC) based at Nottingham (FRAIMS Position-FRM PM SPOC).

Local Authority referral

39.If Customer Compliance activity is appropriate, consider whether the referral falls into one of the five categories that must be offered to the LA below. If the Customer Compliance team already have an agreement in place to not offer referrals to the LA, do not send them.

• undeclared property – address not known (not current address of customer);
• abroad – having regard to appropriate benefit regulations;
• boarders in household;
• non-dependant in household – customer in receipt of IS and SDP in payment;
• not at given address.

40.If the Customer Compliance team have a local agreement in place not to offer referrals to the LA, do not send them.

41.If the referral falls into one of the five categories, take the follow action:

Step / Action
1 / Print the FRF and send the original referral to the LA in accordance with locally agreed arrangements, where appropriate, on an FPA1 and record the activity on FRAIMS as per “Customer Compliance Caseswith a Local Authority Interest” section within “New Case Received – Case Owner Actions” instructions in FRAIMS guidance.
2 / Allow the LA 10 days to turnaround the case.
3 / BF 14 days for a response from the LA on the FPA1.
4 / If no response is received after 14 days, commence Customer Compliance action.
5 / If the LA return the FPA1 and have accepted the case, update notepad and close the case on FRAIMS.

Local Authority investigations

42.Local Authorities (LA) can access the Notepad screen of benefit payment systems. If they identify from checking Notepad that Customer Compliance activity is taking place and they have an on-going investigation, the LA will contact the Customer Compliance team and ask that all Customer Compliance activity be terminated.

43.Action must be taken to closethe case on FRAIMS.

44.The LA may continue the investigation and will invite FIS to jointly investigate and interview under caution, which could potentially lead to a sanction. If the LA request any documentation gathered previously by the Customer Compliance team it can be provided.

45.If the LA require information from a previous CC case they should request the information using the FPA1 form, as agreed in the procedures for joint working with FIS. LAs should not contact CC teams directly for documents. FIS will make local arrangements for the recovery of the Customer Compliance file.

Credits only cases

46.Credits only cases must be accepted for Customer Compliance activity if appropriate. If the CC interview results in the disallowance of the creditan MVA or overpayment cannot be claimed but a positive outcome must be recorded on FRAIMS, see 07 Recording Outcomes – Credit Only Cases within this guide.

JSA Contributory cases

47.Living together referrals for JSA Contributory benefit, JSA (C) only cases may be received even though there may be no risk at the time as living together doesn’t affect entitlement. However, action should be taken by the CCO to set a future case control in JSAPS or ISL Legacy dialogue to undertake Customer Compliance action at the six month stage, when the customer transfers onto JSA Income Based (IB).

Service Personnel and Veterans Agency (SPVA) referrals

48.Customer Compliance does not undertake activity for Service Personnel and Veterans Agency (SPVA) referrals. These should be returned to the originating SPVA office if received.

49.Where the claimant is in receipt of both SPVA and DWP benefits, a copy of the FRF and other relevant information must be printed off and sent to the relevant SPVA Department. Record the details of the handover to SPVA on the FRAIMS Case, appropriate Customer Compliance action should then continue on the DWP element.

Instrument of Payment (IOP) referrals

50.Instrument of payment (IOP) referrals are not dealt with by Customer Compliance and should returned to the sender if received.

New FRAIMS Incident received

51.When a Fraud Referral Form (FRF) is received into FRAIMS the system will check to see if any live Incidents / Cases are already held for the same suspect.

52.If live Incidents / Case are found the new incident (referral) will be forwarded to the Case owner of the live Incident / Case.

53.Customer Compliance Officers and Managers must ensure that any matching Incident(s) received are actioned on a daily basis and either:

• Linked to the live Case,
• Re-routed, or
• Closed.

54.Where a claimant has been notified of an interview and a matching Incident is received prior to the actual interview, the CCO should discuss both referrals at the same interview.