Guidance

Chapter 9: Performance management and compliance

Updated 10 May 2023

Applies to England and Wales

Introduction

The Department for Work and Pensions operates a robust Performance Management (PM) regime to ensure contracts deliver value for money for the taxpayer and to ensure Providers are accountable for delivering what is outlined in their contract.

9.01. DWP Employment Account Division, which has responsibility for performance management, has developed this Performance Management and Intervention Regime (PMIR) to support the delivery of provision and to underpin your contract.

9.02. You will be responsible for managing the contract, including addressing poor performance with sub-contractors, and will need to ensure that all systems and processes (including tracking) used for the monitoring and recording of performance are robust, provide a clear audit trail of evidence, and give confidence to DWP that you and your supply chain are delivering the contract.

Performance Management and Intervention Regime (PMIR)

DWP will employ an active and consistent Performance Management and Intervention Regime (PMIR).

9.03. Provider performance against Required Number of Outcomes (RNOs), Tender Minimum Performance Levels (tMPLs), Customer Service Standards (CSSs) and Performance Indicators (PI) will be managed on both quantitative and qualitative aspects of the contracts, including, but not limited to, an in-month, rolling 3-month, rolling 12-month and cumulative basis from day one of the contract.

9.04. Performance Improvement action will be considered on a monthly basis where contracted targets have not been achieved. Providers will be required to deliver performance in line with Cohort Profiles.

9.05. DWP will manage your performance at the headline Contact Package Area (CPA) level, and may take performance improvement action should your performance against any RNO, tMPL, CSS or PI fall below the levels stipulated in your Contract.

9.06. There are 4 levels of this regime:

• Level 1: Standard Action – DWP Performance Manager-led
• Level 2: Enhanced Action – DWP Performance Manager/Senior Performance Manager-led
• Level 3: Informal Action – DWP National Provision Lead-led
• Level 4: Formal Action – DWP National Provision Lead-led

9.07. Please note that whilst the PMIR follows a sequential order of escalation, there may be occasions where an initial intervention at a higher level may be appropriate.

9.08. For the avoidance of doubt, DWP will be entitled to take action at Level 4 whether or not it has taken all of the steps outlined at Levels 1, 2 and/or 3.

9.09. At each level of intervention, the DWP Performance Manager will continue to work closely with you and the frequency, scope, and types of activity will increase if matters escalate.

Level 1: Standard Action

9.10. DWP will hold regular discussions with you, including Contract Performance Reviews (CPRs), which will focus on performance against the quantitative and qualitative aspects of the contracts, including, but not limited to, an in-month, rolling three-month, rolling 12-month and cumulative basis from day one of the contract.

9.11. DWP Performance Managers will work with you to set up a “PMIR Action Plan”. The purpose of the PMIR Action Plan is to provide assurance that you have identified the priority areas for performance and will include specific actions that you will take in these areas. It will also include incremental performance and pipeline data for you and any subcontractors that may lead to outcomes, review dates and the cohort management information to improve the extent to which you are meeting RNOs, tMPLs of and Customer Service Standards in line with the Contract.

9.12. The PMIR Action Plan is to be populated by you and must fully address any and all areas of performance required to meet the contractual requirements. The actions must be specific about the required activity, and these actions must be specific, measurable, achievable, realistic and time bound. Action plans should be updated monthly and sent to Performance Managers at least five working days prior to a Contract Performance Review meeting. An example of the Provider Action Plan to be used will be provided by the DWP. However, you may use your own version if preferred, as long as it includes all areas covered in the example provided

9.13. The PMIR Action Plan is required to be in place from day one of the Contract and will be reviewed in your discussions with your DWP Performance Manager.

Level 2: Enhanced Action

9.14. If DWP believes that you have not/may not achieve the RNOs, or have not met/may not meet the tMPLs and/or the Customer Service Standards set out in your Contract, the DWP Performance Manager will consult the Senior Performance Manager. This discussion will focus on, but may not be limited to, areas of concern, action already taken, and your current inability to address the performance, compliance, or service delivery issues.

9.15. A management letter confirming the escalation to Level 2 and the reason for this will be issued to you. Following this you will be required to present an enhanced Action Plan including, for example, a flightpath for performance improvement at a subsequent meeting with the DWP Performance Manager/Senior Performance Manager.

Level 3: Informal Action - Nationally Led

9.16. If the remedial actions shown on the enhanced Action Plan have not resulted in the improvement in performance required by DWP, the Performance Manager and Senior Performance Manager will consult the National Provision Lead and other key stakeholders, for example, DWP Commercial Directorate, DWP Policy, and DWP Strategy, to agree next steps.

9.17. A management letter confirming the seriousness of the escalation and the reason for this action will be issued to you and will include an invitation to attend a meeting with, for example, senior DWP performance management and commercial officials to discuss matters further.

Level 4: Formal Action - Nationally Led

9.18. If your performance has not improved sufficiently and you are not meeting the requirements of the Contract DWP may take formal action in accordance with the Contract. This may include issuing a Performance Improvement Notice (PIN) and thereby initiating the Performance Improvement Process in order to address any Service Failures.

9.19. DWP Employment Account Division and DWP Commercial Directorate will work with you to support the completion of a Performance Improvement Plan (PIP) and will undertake activities to monitor and support improvement to your performance. If a Performance Improvement Plan is agreed but you fail to implement it in accordance with its terms such that you fail to rectify the Service Failure by the date specified in the PIN then DWP may, at its absolute discretion, but shall not be obliged to, terminate the Contract.

9.20. Nothing in this Guidance shall exclude any rights or remedies provided to DWP in the Contract, by Law, in equity or otherwise. In the event of any conflict or inconsistency between this Guidance and the provisions of the Contract, the provisions of the Contract shall take precedence over this Guidance.

9.21. Nothing in this Guidance shall exclude any rights or remedies provided to DWP in the Contract, by Law, in equity or otherwise. In the event of any conflict or inconsistency between this Guidance and the provisions of the Contract, the provisions of the Contract shall take precedence over this Guidance.

Performance Indicators (PIs)

9.22. DWP will share the following information with Providers relating to the validation of earnings-based Outcomes:

• when a Participant’s earnings are first declared to His Majesty’s Revenue and Customs (HMRC) following a confirmed start on the Intensive Personalised Employment Support (IPES) provision; and
• when lower and higher earnings thresholds are reached

9.23. Each provider has specified a predicted ‘Earnings PI’. This PI is the number of Participants each month that you anticipate will need to have earned an income from employment to achieve the relevant Outcomes to meet the Lower and Higher Threshold Outcome RNOs.

9.24. If, following a Performance Indicator Review, the ‘Earnings PI’ is not met, or DWP considers that without intervention the Earnings PI will fall below the required standard, DWP may issue a Performance Indicator Course of Action Notice in accordance with Schedule 3 of the Terms and Conditions of your Contract.

9.25. This action may be implemented with a view to avoiding a failure to achieve the relevant RNO.

9.26. DWP is under no obligation to initiate or pursue the Performance Indicator Course of Action and it may choose in its absolute discretion to exercise any other right or remedy available to it under this Contract instead, or running in parallel with, initiating and pursuing the Performance Indicator Course of Action.

Cohort Profiles and Management Information

9.27. DWP will measure your performance using a cohort and a profiled cohort measure based on the information you provided as part of your tender and which has been incorporated into your Contract. You will be measured against the individual cohort profiles in the CPA. A cohort will relate to Starts in a calendar month, for example, all the Participants where the start date entered on PRaP falls in the relevant calendar month. Further information can be found in Chapter 13 - Management Information.

9.28. An Employed Job Outcome may be either a Lower Threshold Employed Outcome or a Higher Threshold Employed Outcome. An Employed Job Outcome is achieved when a Participant’s earnings reach an earnings threshold calculated by DWP as equivalent to the Participant working at the National Living Wage (NLW).

9.29. Earnings equivalent to 8 hours per week for 182 days, at the adult rate (aged 25 or over) of the National Living Wage (NLW). This currently stands at £2,167, (the “lower threshold outcome”) and will be uprated in line with NLW; and,

9.30. At a higher threshold calculated at 16 hours per week for 182 days at the adult rate (aged 25 or over) of the NLW. This currently stands at £4,335 (the “higher threshold outcome”) and will be uprated in line with NLW.

9.31. Achievement of these Employed Job Outcomes will be identified automatically by DWP.

9.32. Please refer to Chapter 7 of this guidance for further information on Outcomes.

9.33. Self-Employed Outcomes will be achieved when the Participant has been trading on a self-employed basis for a cumulative period of 91 days (the “Lower Threshold Self-Employed Outcome”) and 182 days (the “Higher Threshold Self-Employed Outcome”) within the period the Participant is on IPES provision.

9.34. As part of making a successful claim for Self Employed Outcomes, the Provider will need to identify and submit self-employment claims through DWP’s IT systems within (i) a maximum of 90 calendar days from the date the conditions for such Self-Employed Outcome have been met AND (ii) within a maximum of 700 calendar days from the date the Participant in respect of whom the Self-Employed Outcome Payment is being claimed started on IPES provision.

9.35. For employed Participants, data relating to performance against these Cohort Profiles will be taken from HMRC data, the DWP IT system and, in the case of self-employed Participants, such data will be taken from claims submitted by you for Self Employed Outcomes.

9.36. DWP produces Management Information (MI) Packs on a monthly basis and these MI packs will contain the data input to PRaP regarding Participants, and performance against the Cohort Profiles, RNOs, TMPLs and Customer Service Standards in the Contract, and will allow DWP to monitor performance in respect of a cohort across various time periods including 1 month, rolling 3 months, rolling 12 months and cumulative from day 1 of the Contract.

9.37. You will be required to provide a monthly performance return (supplier MI) containing key data that drives the performance of the Contract. This will be in a form agreed with DWP following discussion, and is likely to include, but is not limited to, information such as the following:

• the number of supplier and end-to-end supply chain staff working on this Contract (including data on absences) and in what roles, including a full-time equivalent (FTE) breakdown
• caseload sizes per Key Worker (including the average and maximum caseload size each of your, and your end-to-end supply chain,)
• the number of people participating within the main element of the supplier delivery model
• supplier performance against the Customer Service Standards
• participant attendance face-to-face and other agreed methods of engagement; and
• the performance and management from each prime delivery location and of the supply chain including information on any commercial action you are taking against your supply partners

9.38. Activity will centre on monthly Contract Performance Review meetings (CPRs) to manage your performance. These meetings will be the key vehicles through which DWP manages delivery of services in accordance with the Contract.

Contract Performance Review (CPR)

9.39. The purpose of the Contract Performance Review (CPR) is to formally examine with you your performance for individual contract(s). All relevant aspects of performance will be assessed against contractual requirements.

9.40. The usual frequency of CPR is monthly; however, this can be reviewed as appropriate.

Content of the CPR meeting

9.41. The CPR will focus on the ongoing achievement of performance levels and Customer Service Standards and depending on priority issues for each meeting, is likely to cover some or all of the following areas:

• action points outstanding from previous meeting
• performance
• expected future performance based on information available (for example, earning commencements and current performance levels)
• review of Action Plan – including improvement expectations agreed at the last meeting
• sub-contractor (end-to-end performance) and Supply Chain performance
• employer engagement
• collaborative working (including Operational Process Updates and feedback from the Jobcentre)
• participant experience, good news stories and complaints
• Compliance Monitoring
• Performance Manager checks
• exit feedback/CV/references
• DWP policy changes – latest DWP memos
• partnership working with Local Services and Charities
• resources / premises variations, staffing and caseload sizes
• feedback on delivery of the Additional Services Innovation contract variations, where awarded.

(This list is not exhaustive)

Content in detail

9.42. Action points outstanding: The PM will go through any outstanding action points not cleared before the meeting and update where possible. Any action points raised during the current meeting will be assigned a named person/persons and given a timescale for resolution.

9.43. Performance: The main focus of the CPR is reviewing performance on a cohort profile basis against your performance levels and your delivery of the Customer Service Standards in the Contract. Depending on the priority of issues identified for the meeting, the CPR is likely to last an hour and a half (longer if required). PMs will use the available MI, action logs, supporting documents, results from compliance monitoring checks and the Action Plan to lead performance discussions. Any areas of improvement or weakness will be highlighted during the discussion and captured in your Action Plan. The PM will challenge you to meet your targets and be clear about any intervention action which may be taken should the performance levels or the Customer Service Standards in the Contract not be met.

9.44. Subcontractor and supply-chain performance: You will be asked about the performance of subcontractors delivering end-to-end services on your behalf, as well as the performance of other delivery partners including specialists. You will be asked about the steps you are taking to ensure performance is high, and what actions you are taking to remedy any poor performance.

9.45. Employer Engagement: The PM will ask about the work you have done to engage with local employers, including identifying new employers, sourcing vacancies and collaborating to develop routes into employment for Participants.

9.46. Collaborative working: Discussion will focus on how you are continuing to improve on good local working relationships, liaising regularly with the Jobcentre particularly around resolving issues and sharing information to inform future planning. Discussion should also capture any local delivery issues.

9.47. Participant Experience: Discuss any current complaints and Participant experiences to identify trends and the effectiveness of processes. Independent Case Examiner (ICE) data will help inform discussions. You will be expected to provide figures on the number of complaints received (in-month); number of complaints resolved; and the number of complaints still outstanding in line with your complaints process. You will be questioned on the breakdown of complaints across the Supply Chain and if this has identified any areas of weakness.

9.48. Compliance Monitoring: The PM will feedback outcomes / actions from the latest check.

9.49. Performance Manager Checks: The findings of the checks will be discussed at the CPR.

9.50. Exit feedback/CV/references: Discussion should focus on the quality of Exit feedback and how the process is performing.

9.51. DWP policy changes / latest DWP memos: This item is to ensure all parties are aware of any policy changes since the last CPR.

9.52. Partnership working with Local Services and Charities: Discussion will focus on how you are continuing to improve working relationships with Local Services and charities supporting your Participants.

9.53. Additional Services Innovation contract: where an ASI contract has been awarded, you will be required to provide assurance at the monthly CPR that the contract is being delivered as agreed. Assurance and feedback should be provided on all elements of the ASI bids, including:

• any required marketing and recruitment;
• rollout and delivery;
• successes, issues, and concerns;
• any evaluation, feedback, and good news stories.

(This list is not inclusive).

You will be expected to keep evidence relating to your ASI Contract, both for future CPR’s and any potential Audits. Evidence should be available for DWP to monitor on request.

Performance Requirements

9.54. The performance levels you are required to deliver are set out in schedule 2 of your Contract.

9.55. DWP will actively monitor the service you deliver against these performance levels. This will be done using a combination of IT-based management information and Compliance Monitoring checks. The following tables and paragraphs show the categories under which performance will be measured and managed, and the standards which relate to the delivery of customer service.

9.56. The Tender Minimum Performance Levels (tMPLs) are the performance levels offered by you in your Final Offer which are set out in Schedule 2 of the Contract.

9.57. The Customer Service Standards are set out in Schedule 2 of the Contract.

9.58. The following table shows the Customer Service Standards that will utilise IT based management information:

Table 4 CSSs that will utilise IT based management information

	Customer Service Standards that will utilise IT based management information
1	The contractor must accept or reject 100% of all referrals in PRAP, within 2 (two) working days of the referral
2	For 95% of participants, the contractor must within 15 working days of the date the referral was made by the Authority: (i) hold the initial meeting and (ii) record on DWP ICT system the date of the initial meeting, and the relevant outcome, for example, Start, Did Not Start, or Did Not Attend
3	The Contractor will provide the Participant with a copy of the service delivery standards within 1 (one) Working Day of becoming a Participant. The service delivery standards referred to here are details on the support that the Contractor can provide to the Participant
4	In 97% of cases, an Action Plan must be agreed and signed by both the Contractor and Participant on the day of the initial meeting, and developed over the next 20 Working Days after the initial meeting, and will be based on the Participants needs assessment.
5	If the Participant and the Contractor have pre-arranged an appointment and the Participant cannot be contacted by the Contractor, the Contractor will continue to try to make contact on a daily basis over the next 5 (five) Working days.
6	When the Contractor becomes aware that the Participant is starting work,the Contractor will discuss any in-work support needs with the Participant and will continue to support the Participant for the next 6 (six) months.
7	The Contractor will offer the Participant a minimum of weekly meetings, which can be tailored to meet the Participant individual needs. The Contractor will meet the Participant at least once every 4 (four) weeks.
8	Contractor must complete an IPES progress report and IPES exit activity plan for 100% of participants where required. The reports must be produced within 10 (ten) Working days of IPES provision ending or the Participant ceasing to be a Participant.
9	Every month, the Contractor will be required to obtain information from Participants on the usefulness of the programme. This will be done by the Contractor asking the specific question(s) and follow up (by email, link to a provider portal, website or on-line survey and where no other option available, by telephone) detailed below. Participants will be required to record their response to the question(s) (“Participant Response”). Where Participants provide responses by telephone, the Contractor will create and maintain a detailed written record of the response - this also falls within the definition of “Participant Response”). Contractors are then required to collate Participant Responses split by customer groups. The Contractor will collate Participant Responses in the template as provided in Annex A to Schedule 6 of CV04. The Contractor will send the completed template to the Authority by the 15th day of the following calendar month. If the 15th day happens to be a non-Working Day, then the deadline shall move to the next Working Day. The Contractor will maintain each Participant Response, which the Authority may request to review in the future. Further information on the manner of differentiating different customer groups will be provided in due course. The Authority reserves the right to publish Participant Responses or a summary of Participant Responses (either in the form provided for in Annex A to Schedule 6 of CV04 or in any other form it sees fit). The Authority reserves the right to amend the specific question or add additional questions that Contractors ask Participants on a monthly basis. Additionally, the Authority reserves the right to require Contractors to ask the Participants the question(s) on a more/less regular basis. The frequency of collating Participant Responses and the deadline for providing the Authority with the completed template from Annex A to Schedule 6 of CV04 can also be varied by the Authority. The Authority also reserves the right to amend the template as provided in Annex A to Schedule 6 of CV04. Question: “Thinking about your overall experience of the services provided, how satisfied are you with the IPES programme? – Very satisfied; – Fairly satisfied; –Fairly dissatisfied; – Very dissatisfied. – Please can you tell us more about why you chose your response? Please be as detailed and specific as possible.
10	A Warm Handback Case Conference with the Jobcentre must be arranged and facilitated by the Contractor for 100% of Participants, where required by the Specification.
11	At the end of each calendar month, the Contractor will complete the template as provided in Annex F to Schedule 6 of CV04. This template will be provided to the Authority on the 15th day of the following calendar month. If the 15th day happens to be a non-Working Day, then the deadline will move to the next Working Day.

9.59. Failure to meet one or more of the CSS’s could constitute a Service Fee Deferral Failure and lead to deferral and/or forfeit of the Service Fee.

Deferral and Forfeiture of the Service Fee

9.60. Payment of the Service Fee, as described in Section 5 of the Specification, will be subject to meeting the CSSs. The basic principles for application of deferral and forfeiture of the Service Fee are as follows:

• where a Provider fails to meet any of the CSSs, DWP may defer payment of 50% of each monthly Service Fee payment until the failure is rectified
• where deferral has been ongoing for at least six (6) Months DWP may forfeit any payments which had been deferred during that period
• where the period during which referrals are made under the contract comes to an end any payments which are deferred are automatically forfeit

9.61. Clause C6 of the IPES Terms & Conditions sets out the detail relating to deferral and forfeiture of the Service Fee.

In summary:

• fifty percent (50%) of the monthly Service Fee can be deferred where the Provider has failed to meet one or more of the CSSs
• DWP will consider whether to defer Service Fee payments if a Provider has failed to meet the same CSS in two (2) Months out of three (3). However, this is without prejudice to the wider right of DWP to defer payment of the Service Fee in accordance with clause C6
• where DWP proposes to exercise its right to defer the monthly Service Fee it shall issue a notice to the Provider before doing so
• deferral of the monthly Service Fee payments shall continue until such time as DWP assesses that the Provider has met the CSSs
• DWP retains a discretion to decide when it will measure whether a Provider has met the CSSs, and the period over which the Provider’s compliance with the CSSs will be assessed
• if DWP determines that a Provider has met the CSSs, then the amounts previously deferred become payable unless the amounts previously deferred have been forfeited
• where the deferral of the Service Fee has been ongoing for a period of six (6) Months or more then DWP has the right to forfeit any payments that have been deferred during that period
• where DWP proposes to exercise its right to forfeit the amounts previously deferred, it shall issue a notice to the Provider before doing so
• where the period during which referrals are made under the contract comes to an end any payments which are deferred are automatically forfeit

9.62. If a Provider is unable to remedy a ‘failure’ for which the Service Fee has been deferred, DWP has the option to forfeit any deferred payments if deferral of the Service Fee has been ongoing for a period of six months or more. The Contractor does not have any right to receive, and DWP does not have any obligation to pay, any Service Fee Periodic Payments that are forfeited in accordance with clauses C6.9 to C6.12 of the IPES Ts & Cs.

9.63. DWP Performance Compliance Officer (PCO) checks will be conducted to measure your compliance with IPES Customer Service Standards and your tender.

9.64. You are required to deliver the performance levels against the Customer Service Standards set out in Schedule 2 of your Contract.

9.65. Each CSS will be monitored using the most appropriate method, either IT-based and/or Compliance Monitoring, from day one; any failure to meet the agreed level for a CSS may result in performance improvement action being instigated.

Customer Service Standards (CSS) – Case Conferences

9.66. DWP have taken the decision to allow providers certain flexibility within the delivery of the Case Conference process, as set out in Chapter 13 of this Provider Guidance, and CSS are not presently required.

9.67. Providers should be aware, however, that as the Case Conference process is new to contracted provision, DWP will monitor its usage throughout the lifetime of the programme. Once DWP has an evidence base, Case Conferences will be reviewed and the way forward discussed with providers. This may include introducing specific Customer Service Standards.

9.68. DWP reserves the right to amend the Case Conference process to ensure alignment with DWP business processes.

9.69. An example of the CSS template to be used will be provided by the DWP.

9.70. Nothing in this Guidance shall exclude any rights or remedies provided to DWP in the Contract, by Law, in equity or otherwise. In the event of any conflict or inconsistency between this Guidance and the provisions of the Contract, the provisions of the Contract shall take precedence over this Guidance.

Compliance Monitoring

9.71. DWP staff, including Performance Compliance Officer (PCOs), perform regular evidence-based checks to identify if Providers are adhering to the delivery models set out in their contracts.

9.72. This includes checking samples of Participant records held by Providers for all related activity, and to ensure that a Participant has reached the relevant earnings threshold and that Outcome Payments have been correctly made.

9.73. Final (approved) compliance lists of checks to be carried out have been sent to Providers during contract award/go live.

9.74. DWP will specify the location where the checks will take place and expects them to be centralised in DWP locations or undertaken digitally and remotely by sharing of screens through Microsoft Teams. However, DWP retains the option for PCOs to carry out the checks in Provider’s’ premises where DWP decides this is appropriate. All records must be available on the Provider’s system for inspection.

9.75. The sample of Participants to be checked will be sent to Providers 12 days prior to the PCO checks being carried out. It is expected that Providers will undertake their own compliance checks on the sample and will return their completed checks to the PCO before the agreed compliance meeting date. This 12-day requirement is to ensure Providers can have fully informed discussions regarding the sample when the compliance checks are carried out.

9.76. Providers are expected to have the necessary remote IT equipment, which must comply with the relevant DWP policies as defined in the appropriate section of the IPES Terms & Conditions, which Providers can bring to the location to enable DWP to carry out centralised checks of Providers’ systems; this includes the provision of any necessary electronic evidence that is required by the PCO to undertake the checks effectively.

9.77. The sample of records to be checked will be selected randomly using a method chosen by DWP. The frequency, periodicity and size of the samples may change throughout the contract period. Where a Provider holds more than one IPES contract, a sample may be drawn from across a selection (up to and including all) of the Provider’s IPES contracts.

9.78. All issues arising from PCO checks are reported to the Provider and relevant DWP stakeholders. Contract Performance Review meetings with DWP and Performance Managers will include discussions around compliance issues identified by PCOs. Actions to address areas of concern re: compliance should be included in your PMIR Action Plan.

9.79. DWP reserves the right to carry out physical checks on documentation as part of this process.

Performance Manager Checks

9.80. DWP staff, including Performance Managers, may undertake checks to complement those already undertaken by the PCOs, by looking more in depth at individual cases.

9.81. The checks will focus on the Participant’s journey, seeking assurances that Providers are addressing the Participants’ barriers to employment, and to test that Providers approach is in line with their Contract.

9.82. The checks may also include a ‘go-look-see’ approach where the PM will observe a range of activities, including jobsearch and the initial engagement meetings. These will not only be with the Provider, but also end-to-end delivery partners and sub-contractors (if appropriate). PMs may also undertake “deep dives” into specific areas to understand where there are specific areas of weakness. PMs may also ask to attend sub-contractor end-to-end delivery and supply chain meetings, and accompany Performance Managers on their meetings/visits to Providers’ sub-contractors and supply chain partners.

9.83. The findings from the checks will feed into a Provider’s CPR meeting.

Evaluation and Reporting

9.84. Independent evaluation will be an important element of IPES Provision and Providers will be asked to co-operate in a range of evaluations commissioned by DWP.

9.85. Other interested parties and Government Departments as part of wider cross-government agendas may commission further evaluations and Providers’ assistance will be expected when required.

9.86. As part of this evaluation work, researchers may wish to visit and interview Providers and their sub-contractors and supply chain, Participants and employers involved in IPES provision. Providers may be asked to provide the relevant contact details and in order to facilitate this process Providers should seek advance agreement from Participants to take part in evaluations.

9.87. Advance notice will be given to Providers where cooperation is required.

9.88. An end of project evaluation report will also be required, highlighting innovative delivery practices and achievements against the cross-cutting themes.

Programme Provider Assurance Team

9.89. The primary purpose of DWP’s Contract Management and Partner Delivery (CMPD) Provider Assurance Team (PAT) is to provide DWP with assurance that Providers’ internal control systems are such that payments made to Providers are in accordance with DWP’s and the Treasury’s requirements.

9.90. PAT reviews test Providers’ internal control systems to establish how effective they are at managing risk to DWP in relation to CMPD expenditure, service delivery and data security.

9.91. PAT will review Providers’ internal control systems to assess their ability to manage risk across these key areas:

• Governance Arrangements – this covers the Providers’ governance arrangements, their systems for tracking and reporting performance and their anti-fraud measures
• Service Delivery – this includes the Providers’ systems for starting, ending and moving Participants through provision and aims to ensure that DWP receives the service it pays for. This section also covers management of the supply chain
• claim procedures and payments – this aims to ensure that Providers have effective systems in place to support claims for payment, including segregation of duties where appropriate

9.92. The PAT operates at a national level enabling it to present Providers operating across regions with a single view of the effectiveness of their systems. Each Provider will have a nominated Senior Provider Assurance Manager who will be their point of contact within DWP for management of assurance related issues/concerns.

9.93. On completion of each PAT review, PAT awards each Provider with an assurance rating from four categories – weak, limited, reasonable, strong. PAT sends to each of the Providers a formal report which details the review findings including key strengths and areas for improvement. Where weaknesses are identified, the Provider is asked to complete an action plan setting out appropriate steps for improvement and this is followed up by the PAT at an agreed time.

9.94. The timescale for a subsequent PAT review is determined by several risk factors; these include the Provider’s current assurance rating, the contract value and intelligence from internal stakeholders. PAT reviews are conducted over a period of up to five months. The resource allocated to each review depends on the complexity of the contract delivery.

9.95. Findings from each review are routinely reported to the relevant category managers/Performance Managers and other DWP stakeholders. DWP may take action in the following circumstances:

• if, following a weak or limited assurance level from PAT, the Provider’s subsequent assurance level is the same or worse for the same reasons, or if the Provider is awarded a consecutive third weak or limited assurance, regardless of the reasons
• following a review, if the Provider fails to submit and/or implement the action plan within the agreed timescale
• where there are suspicions that a Provider may be acting inappropriately PAT will refer to the DWP’s Internal Investigations team who are trained to carry out formal investigations; or
• where there are serious concerns around data security these are reported to the DWP’s Provider Security Team

9.96. DWP may periodically publish Provider assurance levels and names (but this will not include reports or supporting information) in order to respond to a Freedom of Information request and to support DWP’s commitment to public transparency.

9.97. The PAT will work with Providers to ensure they understand what is expected of them and are adequately equipped to develop robust systems to support their service delivery model throughout the duration of the Contract.