IRRV Response to CTB/HB Circular A9/2007

Mr Frank Newton

Local Government Association Representative

Sent by E-mail to: franknewton@hurstingstone.plus.com

28 September 2007

Dear Frank,

Consultation re HB/CTB circular A9/2007: Proposals for the Right Time and Right Benefit performance indicators to be included in the Performance Framework from April 2008

The Institute of Revenues, Rating and Valuation (IRRV) is pleased to provide this response to the consultation relating to HB/CTB A9/2007.

The IRRV is the professional body concerned with all aspects of local taxation in the United Kingdom. Its members are engaged in local authority benefits administration, the valuation of property for taxation, local tax administration, the appeals process and financial management in local government.  The Institute represents the professional interests of its members who work within this broad church.

The Institute has developed this response through its Benefits Faculty Board, which draws upon the considerable benefits administration expertise of the Board members.  The Institute strives to bring about improvements in the benefits administration processes.

The Right Time indicator

On the whole, we are in support of this change, as long as the proposed performance level is given consideration and not set so low that LA's will struggle to meet it.  Over recent times there has been a fair amount of discussion regarding the monitoring of CIC PI and comparisons to New Claims.  So collating the statistics into one indicator can still enable processing performance to be measured effectively across all Authorities.

However, it doesn't necessarily guarantee a good level of service to a customer. A local authority could achieve the desired level of performance in this area by processing new claims quickly, whilst still taking a long time to process changes in circumstances. Clearly, for those who have had a change in circumstance (or event), the level of service would be seen as poor. Also, it is looking at an average, as opposed to what is 'usual', so a few cases that have taken a long time to process will result in the average increasing to a figure far higher than what would usually be achieved. This again could lead to an unrepresentative picture of the local authority’s performance.

The Right Benefit Indicator and PM10

This indicator only appears to relate to finding reductions in benefit. We disagree with this approach as it is at odds with the concepts of income maximisation and social inclusion and, in our opinion, not fully supporting the Government’s aim of tackling fraud in error in our benefit system. In our view work should also be completed by a local authority to ensure that the customer receives their full, correct entitlement, which could be higher.  We should be identifying customers’ needs, helping them to claim the benefits to which they are entitled, and ensuring that the level of HB/CTB awarded accurately reflects their circumstances. We should not just be looking at taking money away from people.

We are not convinced that by measuring reductions in benefit that this measures 'right benefit'.  What about those that may be underpaid, or even worse, not claiming entitlement at all?  The indicator as it stands at the moment does not support the key objective/outcome of the proposed indicators, for a reduction in poverty and worklessness.  It appears that it is not balanced with the key areas of encouraging benefit take-up and ensuring quality of assessment.  What about those that have been underpaid in error?   We would like to see consideration for this aspect.

Although there are no proposals for national targets, we would be interested to understand the proposals relating to levels of performance expected from LAs.

With regard to basing the Right Benefit indicator on PM10, we offer the following observations. A number of practitioners have expressed concerns with regards to meeting the PM10 target: some have not met the target and others have met the target for this quarter but feel they are unlikely to for the year.  Some are concerned because they have reviewed all their claims at least once, some twice and even three times and this has caused them to receive a lot of complaints.   The problem is that PM10 measures the number of reductions in benefit entitlement.  It is not about how much fraud and error has been prevented from getting into the system in the first place, but how much you can find after the claim has been processed. So there is no incentive to prevent fraud and error creeping into the system because you will be penalised if you do, as there will be nothing to find.  There was undoubtedly a need to change, as prior to this the emphasis was on the amount of interventions processed and a number of LA's were going through the process just to hit their target rather than targeting the claims that were high risk.   However, we feel this is not the way forward as it is very difficult for those LA's who have always been proactive in this area and for those who are up-to-date to be able meet the targets set for them. 

There is an ancillary problem that at present there is no mechanism by which a local authority can monitor progress towards the reduction target as software systems don’t provide a report with this information. This also means that there is no mechanism by which local authorities can sample check the data to make sure it is being recorded correctly.

A consistency of approach across England, Scotland and Wales

We are concerned about the Inspection process and the potential for differences in approach between England, Scotland and Wales; there will be three different audit teams so there will be potentially a lack of consistency.  We are also concerned that best practise will be lost with the demise of BFI as they always summarised findings of good practice.

Concern regarding the reduction in PI’s

We are concerned that there is a reduction in the number of PI's to be reported. The reduction in performance indicators for Benefits indicates that the 'spot light' on this area is diminishing.  Focus should be maintained on Benefits performance and any changes should not compromise the ability to measure efficient and effective performance. There is a risk that Benefit Sections will be perceived as becoming less important within their authorities and we could see performance affected by this.  It is inevitable that some authorities will put extra resources into processes in order to meet the PI; if this is taken away we may see an effect on performance.

Additionally, in respect of the changes to the Inspection regime: the PIs should support the process to enable clear identificationof those Authorities that are appropriate for inspection.

An erosion of performance management

Recent moves to incorporate all the performance data on the HBSD/IAD scan, combined with the changes proposed in A9/2007, may in the long term erode a LA’s ability to manage performance effectively.

Software suppliers provide local authorities with performance data based on the reporting requirements of the DWP e.g. STATS 124. With the decision to use the HBSD/IAD scan to extract performance data on a case-by-case basis, it is likely that local authorities will soon lose the ability to extract that information for themselves as suppliers cease to support the STATS 124 reports. They have as yet not provided a mechanism by which local authorities can extract performance data for themselves from the scan – indeed we know that at least one supplier has no plans to do so.

Local authorities will therefore have to wait for the DWP to produce their performance data and will not be able to break it down into team or individual user level to allow continuous improvement monitoring.

Bespoke system development may then be a necessary result – thereby requiring local authorities to pay for information, which they used to routinely have access to – hardly an efficient use of public funds.

We also raise an issue concerning the accuracy of the HBSD/IAD scan – in its Excel format it is difficult to tell if the correct information is appearing in the appropriate cell and there is no way to compare the data being extracted.

Moving to this means of extracting data would significantly lessen the resources at the DWP statistical divisions but it will do nothing to enhance performance management regimes and nor is it likely to provide local authorities with any confidence in the results.

We would be happy to discuss our response with you further.

Yours truly,

Maureen Neave

Chairman, IRRV Benefits Faculty Board

E-mail: benefits.faculty@irrv.org.uk