Appendix C
BFI Action Plan - IMPLEMENTATION
BFI Recommendation / Para.Ref. / Priority
(H/M/L) /
Response
/BY
/Target Date
/ACTION
/Current Position
1 / Improves the quality of investigations by:Making more effective use of intelligence gathering agencies / 2.40 / High / New procedures introduced to ensure all intelligence gathering sources are considered and used as appropriate. Any training required on use of sources will be provided to investigators / Benefit Fraud Mngr / 3/2/06 /
- Instruct (e-mail) Investigators to use all sources (refer to Fraud Manual)
- Support above with (brief) procedure note (Fraud Manual – Undertaking Investigations – Method of Investigations)
- Identify any training required (e-mail) & organise
Completed
Ensuring that the fraud file provides a clear audit trail / 2.58 / High / New template introduced to ensure adequate record of all action on individual fraud cases (includes a summary of each investigation). / Benefit Fraud Mngr / 3/2/06 /
- Update file action sheet to include summary and reasons for applying a sanction if applicable
- Update physical file structure (new files/dividers etc)
Completed
Adhering to all relevant legislation / 2.62 / High / New procedures introduced covering investigation processes ensuring compliance with legislation. Instructed investigators to comply & current cases being reviewed.
Management review of cases procedures introduced to include regular compliance with legislation checks / Benefit Fraud Mngr / 3/2/06 /
- Instruct/remind (e-mail) Investigators to comply with Legislation (on Surveillance RIPA & Interviews PACE)
- Support above with procedure note (Fraud Manual – Undertaking Investigations & Interviewing)
- Review current cases
- Produce management review of cases procedure to include checks on legislation (statements/interview records,reminder of changes, decision on RUC). Checks to be carried out by Team Leader (all) & Benefit Fraud Manager (sample) & evidenced on file/system. (Fraud Manual - Man Info – Man File Checks)
Improving investigative techniques / 2.63 / High / New procedures introduced covering investigation processes to ensure use of visits is controlled and monitored (including new visit Approval Form) / Benefit Fraud Mngr / 3/2/06 /
- Implement new visit approval & monitoring form (include max visits 3)
- Include above as procedure note (Fraud Manual – Undertaking Investigations)
Making full use of authorised officer powers / 2.87 / High / Reviewing use of Authorised Officers’ powers together with other source intelligence to ensure Authorised Officers’ powers status is required.
Introduced system to control and monitor the use of authorised powers and other evidence gathering sources (e.g. NAFN/Equifax/Operational Intelligence Unit) / Benefit Fraud Mngr / 3/2/06 /
- Implement new use of Authorised powers approval form (NAFN/AO powers/Equifax)
- Include above as procedure note (Fraud Manual – Undertaking Investigations)
- Review Authorised powers requirements
Completed
(Visit from NAFN 25/7)
Ensuring that managers receive appropriate training in Professionalism in Security / 5.22 / High / Currently recruiting new Senior Benefits Officer responsible for Benefit Fraud who will be PINS qualified.
Investigations Team Leader to complete PINS management training on next available course / Chief Auditor/ Benefit Fraud Mngr / 31/3/06 /
- Recruit Benefit Fraud Manager (KM)
- CE to complete PINS
- AH to complete PINS
2 / Introduces a comprehensive and systematic management and checking and reporting regime that covers:
The quality of investigations / 2.65 / High / New management review of cases procedures introduced including regular quality of investigations checks by Investigations Team Leader and Benefit Fraud Manager / Benefit Fraud Mngr / 3/2/06 /
- Produce management review of cases procedure to include quality checks on cases by Team Leader (all) and Benefit Fraud Manager (sample) & evidenced on file/system (link to 2.62 above). (Fraud Manual – Management Info – Management File Checks)
Completed
Compliance with legislation and the council’s counter-fraud policy / High / New management review of cases procedures introduced including regular compliance with legislation checks by Investigations Team Leader and Benefit Fraud Manager / Benefit Fraud Mngr / 3/2/06 /
- Produce management review of cases procedure to include checks on legislation (as in 2.62 above). (Fraud Manual – Management Info)
Completed
3 / Improves counter fraud workload management and control by:
Making more effective use of risk-assessment of fraud referrals / 2.39 / High / Risk assessment procedures introduced enabling management of investigation resource and management monitoring of referrals to identify trends / Benefit Fraud Mngr / 3/2/06 /
- Produce ‘gradings’ and action required (eg none/brief invest/full invest) for risk assessment scores. (Fraud Manual – Fraud Referrals)
Completed
Ensuring that fraud investigations commence within an average of 10 working days of referrals being sifted / 2.46 / High / Management report produced on referral allocation times for monitoring by Benefit Fraud Manager to ensure no delays in sifting referrals. Use of administrative support for this area. / Benefit Fraud Mngr / 3/2/06 /
- Produce regular management report from Academy on sifting referrals & obtain sign off by Benefit Fraud Manager (Chief Auditor in interim). (Fraud Manual – Man Info)
Completed
Regularly monitoring the caseload allocation / 2.49 / High / Management report introduced to monitor caseload allocation and to ensure tracking of referrals, signed by Benefit Fraud Manager / Benefit Fraud Mngr / 3/2/06 /
- Produce regular management report from Academy on caseload allocation/ management reviews & obtain sign off by Benefit Fraud Manager (Chief Auditor in interim). (Fraud Manual – Management Info)
Completed
Reviewing investigations at key stages / High / New management review of cases procedures introduced including regular review of investigations at key stages, signed by Benefit Fraud Manager / Benefit Fraud Mngr / 3/2/06 /
- Produce management review of cases procedure as in 2.62/2.65 above to include reviews at key stages signed by Team Leader (all) & Benefit Fraud Manager (sample) (Fraud Manual – Man Info – Man File Checks)
Completed
Regularly monitoring and analysing the outcomes of investigations / 2.50 / High / New management reports introduced to ensure adequate management/control of the Investigations activity to include monitoring /analysing outcomes of investigations, signed by Benefit Fraud Manager / Benefit Fraud Mngr / 3/2/06 /
- Produce new regular management reports as in 2.49 above to be used by Benefit Fraud Manager to control Investigations activity (include in report outcomes) (Fraud Manual – Man Info)
Completed
4 / Revises its prosecution policy so that it provides clear guidance to support the identification and authorisation of all suitable sanction cases / 2.105 / High / Prosecutions Policy to be revised in line with best practice to include clear guidance on identification and authorisation of sanction cases
Members to approve revised policy / Chief Auditor / 31 March 2006 /
- KM to get best practice example from BFI
- Revise Policy
- Get Policy Approved
Approved by Members
5 / Encourages more and better quality referrals from Benefits staff by:
Improving the standard fraud referral form / 2.36 / High / Standard referral form revised in line with best practice / Benefit Fraud Mngr / 3/2/06 /
- Revise referral form
Encouraging staff to use the standard fraud referral form / High / Benefits assessment staff to be encouraged to use standard referral form by Senior Benefits Officers at all Assessment Workgroup meetings / Senior Benefit Officers / 3/2/06 /
- SA to instruct SBO’s to encourage assessors to use referral form at Assessment Workgroup Meetings
Encouraging staff to provide full information when making a referral / High / Benefits assessment staff to be reminded by Senior Benefit Officers to provide full information (using revised form to make easier) at all Assessment Workgroup meetings / Senior Benefit Officers / 3/2/06 /
- SA to instruct SBO’s to remind assessors to provide full information on new referral form at Assessment Workgroup Meetings
Ensuring participation of the Investigations Team at fraud awareness sessions / High / Fraud awareness training plan prepared. Investigations Team representative to attend planned training sessions / Chief Auditor/ Benefit Fraud Manager / 31 March 2006 /
- SA to prepare fraud training plan
- SA to ensure Investigations Team representative at training sessions
(Meritec Package arrived - to be online Oct 06)
6 / Ensures its self-assessment against Performance Standards and its performance returns to the Department are accurate / 2.12 / High / Evidence to be obtained in the future to support self-assessment against Performance Standards. To challenge/audit all standards to ensure compliance, and link to Business Plan / Benefits Manager / 31 March 2006 /
- BJ to retain self-assessment evidence in future
- BJ to challenge challenge/audit all standards to ensure compliance, and link to Business Plan
Accurate in accordance with CPA inspection in 2005
7 / Provides senior managers and Members with comprehensive reports that cover all aspects of performance / 5.9 / High / Future reports to Members to include progress on all Best Value Performance Indicators and local targets for Housing Benefits / Benefits Manager / 31 March 2006 /
- BJ to ensure Future reports to Members to include progress on all Best Value Performance Indicators and local targets for Housing Benefits
Monitoring information being passed to Members.
8 / Ensures that recommendations made by Internal Audit are implemented quickly / 5.44 / Medium / All future Audit report recommendations to be implemented within agreed target date / Benefits Manager / 31 March 2006 /
- BJ to ensure All future Audit report recommendations to be implemented within agreed target date
9 / Incorporates reference to the prevention and detection of benefit fraud in the corporate strategy / 5.5 / Medium / Reference to prevention & detection of benefit fraud to be included in future ‘Striving for Excellence’ corporate strategy / Head of Financial Services /Benefits Manager / 31 March 2006 /
- H of FS to ensure Reference to prevention & detection of benefit fraud to be included in future ‘Striving for Excellence’ corporate strategy
10 / Sets more challenging targets for the number of sanctions to be achieved / 5.6 / Medium / To review target setting for all areas of benefit administration within new Business Plan (to include number of sanctions target), and benchmark with similar Authorities / Benefits Manager / 31 March 2006 /
- BJ to review target setting for all areas of benefit administration within new Business Plan (to include number of sanctions target), and benchmark with similar Authorities
11 / Conducts staff appraisal annually for all staff / 5.23 / Low / Introduced system to monitor progress on annual staff appraisals (EDI’s) and bringing up to date any outstanding appraisals / Benefits Manager / Implemented /
- BJ to monitor progress on annual staff appraisals (EDI’s) and bringing up to date any outstanding appraisals
12 / Ensures that staff record cases correctly on the Benefits IT system to allow the provision of accurate statistical information to the Department / 5.13 / Low / Review accuracy of benefit claim data entry to ensure meeting standard, and remind relevant officers / Benefits Manager / 31 March 2006 /
- BJ to review accuracy of benefit claim data entry to ensure meeting standard, and remind relevant officers
Key:
Completed action. Will not be reported to future Committees
Bold Updates/amendments since previous report - 1 -