Guidance

Appendix A: Housing Benefit Award Accuracy Initiative - frequently asked questions

Updated 20 December 2021

Introduction

The Department for Work and Pensions (DWP) circular HB A9/2020 was published on 7 August 2020 and gives details about the Housing Benefit (HB) Award Accuracy Initiative re-launch.

This circular includes a list of the most frequently asked questions (FAQs) about the Initiative from local authorities (LAs). These FAQs were compiled by the Local Authority Partnership, Engagement and Delivery (LA-PED) division with support from LA representatives for use by the wider LA community.

This document contains these published FAQs, as well as additional FAQs that LA-PED has received since the date of publication.

Any questions not covered by this document should be sent to: lawelfare.frauderrordebt@dwp.gov.uk

Where appropriate, further answer to questions will be added to these FAQs and circulated.

HB Award Accuracy risk model

Q1. How is the HBAA Indicator calculated?

A1. The HB Award Accuracy Indicator score is calculated by dividing the value of reductions to entitlement achieved (calculated directly from the Single Housing Benefit Extract (SHBE)) by the value of reductions to entitlement expected (calculated using a model, based on SHBE caseload information).

Q2. How is the HBAA Indicator score calculated and attributed to an HB case?

A2. HB Award Accuracy Score = HB reductions achieved divided by HB reductions expected.

The value of reductions achieved is calculated by adding together the value of terminations (when a claimant ceases to receive HB) and decreases (when a claimant receives less HB than in the previous month). The value of the termination is the value of HB entitlement in the previous month. We identify decreases by comparing the HB entitlement in consecutive months. The value of the decrease is the difference in entitlement between the two months. This gives a value of reductions to entitlement achieved for each claimant in each month. The individual values are then summed across months to get national, regional and LA level figures for each quarter.

We also take into account cases that migrate to Universal Credit (UC). If a claim does not appear on SHBE for at least two consecutive months we assume that the claim has been terminated. However, a claim would also stop appearing on SHBE if the claimant had undergone a change of circumstances that triggered a move to UC. A claimant who moves to UC may still be receiving housing costs, so it would be misleading to assume that the LA had found a reduction of the full value of HB entitlement. However, it is difficult to see from a UC claim what the equivalent HB entitlement would have been. Therefore, we cannot reliably assign a value of reduction to a HB claim that moves to UC. Instead we identify claims that have undergone natural move to UC (by data matching with the UC caseload) and exclude them from both the achieved and expected values where they are claiming UC Housing costs and remain within the same LA. This allows us to draw meaningful comparisons between the HB Award Accuracy Indicator scores of LAs with different UC rollout schedules.

The expected value of reductions is calculated in the same way as the actual values, in other words by adding together the value of terminations and decreases. The expected value of terminations is calculated by multiplying the probability of a termination by HB entitlement. The expected value of a decrease is calculated by multiplying the expected probability of a decrease by the expected value of a decrease. The probabilities and expected values of decreases are estimated using logistic and linear equations that use the following characteristics; claim type (for example, passported / standard), tenancy type, amount of HB entitlement, claimant’s age, gender, capital, total disregarded income, number of dependants, number of non-dependants, temporary/supported accommodation and partner status. Although HB entitlement is a predictor, it does not follow a linear relationship with the probabilities or expected value of decrease. Therefore, we group claims into those with HB entitlement greater than £120, and those without, and use different equations for each group.

This gives a value of reductions to entitlement expected for each claimant in each month. Monthly values are then summed to get national, regional and LA-level figures for each quarter. We observe seasonality in LAs’ activity. For example, certain tasks are more likely to be undertaken at year-end at the expense of other interventions. To ensure that our expected value of reductions reflects this we use slightly different equations for each quarter.

The value of HB reductions expected is calculated by DWP analysts using the following criteria:

• HB entitlement
• Passported status
• Tenancy type
• Partner flag
• Claimant’s age
• Claimant’s gender
• Claimant’s capital
• Claimant’s total disregarded income
• Number of dependants
• Number of non-dependants
• Temporary or supported accommodation

These characteristics are the ones that have been found to provide the most efficient model for predicting the expected amount of reductions to entitlement.

Q3. Why is the risk model calculated using only reductions and not increases as well?

A3. The HB Award Accuracy Indicator is an estimate of how well each LA is managing its HB caseload. Unidentified reductions in HB entitlement are estimated to be far larger by both volume and value than increases in entitlement. However, activities LAs undertake to identify unreported changes are likely to identify both increases and reductions in entitlement and this is a key element of paying the right amount, to the right person, at the right time. Developing an accuracy indicator which incorporates both increases and reductions in entitlement is very complicated as unreported increases may offset unreported changes and make the indicator less meaningful. We believe it is sensible to focus on reductions in HB entitlement, to keep the measure as simple and meaningful as possible.

Q4. What is Caseload Risk Data?

A4. The Caseload Risk Data is where we take the entire HB caseload and score each case based on the probability of there being a change in entitlement. All LAs, whether participating or not, receive monthly Caseload Risk Data providing a risk score, along with their HBMS files. Each case in the Caseload Risk Data will be ranked from high to low for each HB claim in their live caseload, based on the latest SHBE return. The top 400,000 cases attracting the highest risk scores will be separately identified at a national level, apportioned and then marked accordingly within each LAs monthly data. This will be sent as a separate file and will be part of the HBMS package issued each month to LAs.

Where volumes of separately identified high risk score cases are lower than expected (in other words, based on the resource funded to undertake FCR activity) then the LA should consider undertaking additional FCRs based on the next highest risk score cases within the Caseload Risk Data. The Caseload Risk Data will be refreshed monthly. LAs are likely to see fluctuations in those high risk cases as a result of changes within their caseload due to a number of factors, such as changes in HB claimant’s circumstances and seasonal factors built into the DWP Risk Model, which allocates the risk score.

Activity details

Q5. What activities are required for participating LAs?

A5. DWP is providing additional funding to enable LAs to undertake the following activities:

• HB Full Case Reviews (FCRs)
• Housing Benefit Matching Service (HBMS) referrals, including:
• Self-employed Earnings Reviews (SERs)
• the correct recording of cases and the return of Management Information (MI) to DWP, including:
  • the correct recording of case outcomes on LA Information Technology (IT) systems to inform SHBE
  • the return of clerical management information (MI) to DWP for HBMS case outcomes

Q6. What is the definition of a Full Case Review (FCR)?

A6. A FCR requires the LA to consider and look at all the current claim details and evidence associated with the claim, as well as any other fresher information and evidence they can source, in order for the weekly HB amount to be reviewed.

LAs can validate this information with appropriate evidence in accordance with their verification policies, including application of risk-based verification (RBV), (if the LA operates to an agreed RBV policy – see circular HB S11/2011.

In the event where claimants do not comply with requests for information relating to reviews, these can be counted as a successful review outcome if the case is subsequently suspended and terminated. In this scenario, the review outcome (as per other review type terminations) should be recorded as a review Outcome = Decrease [2. Benefit decreased/…], there should also be an associated change record showing the reason/source of change as [8.] LA Intervention: review.

We are not prescribing how LAs undertake these reviews. In the pilot most LAs issued postal review forms, some used a combination of postal reviews and visits, and some contacted claimants over the telephone. We note that the COVID-19 pandemic may make some intervention types impossible.

Actioning cases

Q7. How do LAs select FCRs and manage these each month?

A7. Each LA has received funding to enable it to undertake an estimated volume of high priority FCRs – the new risk data received as part of the monthly HBMS file will contain each LAs’ HB Caseload in ranked priority order, with those deemed as the highest priority flagged accordingly. At present we have not been able to arrange for the new risk data file to be automatically uploaded into LAs IT systems, so it will be necessary for each LA to decide on the volume of FCRs it plans to undertake each month, (profiled dependent on the start date chosen, and arrange for a proportion of cases flagged as highest priority to be manually uploaded from the risk data file into their LA IT Systems. This will be adjusted where LAs opt for a later start date.

Guidance issued by IT Suppliers should enable LAs to manually manipulate the new risk data into a suitable format for it to be uploaded and accepted into their IT System. LAs will need to ensure that existing functionality and/or other processes can identify appropriate cases that have already been uploaded and review activity commenced/completed, in order to avoid duplication. Note: the risk data file will always provide a risk score for a live HB claim each month, it doesn’t remove the record where the LA has previously undertaken an FCR. There are no plans to remove these FCRs from the report.

Q8. What should we do if an LA receives less or more HBMS referrals (including Self-employed Reviews (SERs)) or FCR cases than resourced to undertake?

A8. Should an LA find itself with spare resource capacity as a result of fewer than expected HBMS/SER referrals, for which it has received funding, it is expected that the LA should look to use that capacity to undertake additional FCRs.

Unlike the Risk data, where the first month’s report provides a reasonable prediction of the high risk case volumes for the year (subject to some quarterly variation linked to the seasonal factors that inform identified cases), the HBMS/SER volumes are likely to vary from month to month. On this basis, we do not recommend that LAs plan monthly volumes of HBMS/SER referrals to be undertaken as a proportion of a single month’s referral volumes. Rather, that all HBMS/SER cases are uploaded each month and LAs aim to complete them all (not necessarily within that month). This will ensure LAs have enough referrals uploaded to undertake the minimum volumes detailed in their allocation.

In the unlikely event that LAs receive more HBMS/SER referrals than resourced to undertake, we would encourage LAs to undertake as many additional referrals as they can (prioritising SER cases); as long as they are not at the expense of achieving the FCR volumes LAs have been resourced to undertake.

FCRs:

• should an LA find itself with fewer than expected FCRs marked as high priority cases, LAs should look at the cases with the next highest risk scores

• it is not the intention of DWP to renegotiate the FCR and HBMS/SER volumes notified to LAs against which they are monitored at any point. An LA could undertake additional volumes against one activity to compensate for shortfalls across another activity

Q9. How do LAs handle cases that might be duplicated on both the High Priority Risk file (FCR) and the HBMS/SER file?

A9. Ultimately, this will depend on the chronology of when you commence/record fraud and error detection intervention activity:

Case 1:

Receipt of high priority risk case (FCR) and HBMS/SER case on the same monthly download of HB Award Accuracy data – Full Case Review activity commenced.

If you commence a FCR, then in all likelihood, you will encompass any further intelligence from HBMS/SER referral as part of that review. Any HB adjustment and resulting over/underpayment should be attributed solely against that review. It is not necessary to apportion any aspect of the over/underpayment recorded under the FCR to an HBMS/SER referral, as ultimately this would result in double counting.

However, you will still need to record an outcome against the HBMS/SER referral on the HBMS MI spreadsheet to clear it. Column N should be completed using Code 4Z.

Code 4Z:

• case already under investigation prior to receiving the HBMS data match
• the LA was already investigating the case before receiving the HBMS referral

In these cases, enter the date you commenced your investigation in Column O – this should be prior to the HBMS ‘Date of Match’.

Column O is then completed with the date you commenced the investigation which should be prior to the ‘Date of Match’ recorded in Column C. Of course if you commenced the FCR following receipt of the monthly High Priority Risk file, which also contained the HBMS/SER referral files, then the commencement date of the FCR date will be later than the ‘Date of Match’ in Column C of the HBMS MI spreadsheet.

In such cases LAs are asked to input the day prior to the ‘Date of Match’ in Column C within Column O, to ensure the HBMS MI spreadsheet doesn’t reject when received by DWP.

Case 2:

Receipt of high priority risk case (FCR) and HBMS/SER case on the same monthly download of HB Award Accuracy data. HBMS/SER activity commenced.

If you have already commenced fraud and error detection activity on a HBMS/SER referral, then discover a duplicate record on the High Priority Risk Report, you should decide whether to either:

• continue with the HBMS/SER activity until an outcome is reached ensuring the HBMS MI spreadsheet is completed in line with guidance, or

• commence an FCR (in effect suspending further activity on the HBMS/SER referral) and take action to clear the HBMS/SER referral on the HBMS MI spreadsheet in line with action outlined in Case 1 above

Case 3:

Receipt of HBMS/SER Case and an FCR has commenced or been completed as a result of a High Priority Risk case being notified on a previous month’s file

The LA will need to consider whether the information provided on the HBMS/SER referral provides sufficient information to contradict the accuracy of the HB reassessment undertaken as part of the previous FCR. If so, then the LA should commence activity on the HBMS/SER referral and record any outcome on the HBMS MI Spreadsheet in line with guidance. If not, then the HBMS/SER referral should be cleared by completion of Column N (4Z Code) and Column O.

In this scenario the date you commenced the investigation, input within Column O, should always be prior to the ‘Date of Match’ recorded in Column C.

Case 4:

Receipt of high priority risk case and an HBMS/SER referral has commenced or been completed as a result of the case being notified on a previous month’s file

LAs have flexibility to consider the appropriateness of undertaking an FCR on a High Priority Risk case, taking into account previous intervention activity on the case. It will therefore be up to the LA to decide on the value of undertaking an additional FCR intervention in such cases.

If the LA does not undertake an FCR on the case and it finds that it doesn’t have sufficient marked high priority risk cases to meet its communicated volumetric expectation, then it should select a case with the next highest risk score from the risk file for consideration of FCR activity.

Q10. How do LAs undertake HB Award Accuracy Initiative FCRs for supported accommodation claims?

A10. A number of LAs have highlighted that a large proportion of their high risk cases that require an FCR (top 400,000 high risk cases nationally) are UC recipients. These UC HB cases are mainly supported accommodation cases where the UC payment covers the living costs and rental liability is covered by HB. With that in mind we have been gathering intelligence from a wide range of LAs on their existing processes. There is still some work to do before any conclusions will be made.

The analysis used to develop the HB Award Accuracy risk model shows that although supported accommodation cases are usually single occupancy households on UC/passported benefit, they are two to three times more likely to have an HB termination. That, coupled with high benefit awards associated with these types of cases, results in a high risk score.

However, the objective of undertaking an HB Award Accuracy FCR is to identify an unreported change of circumstance. The risk model does not take account of recent actions the LA may have taken to review the case or any action planned in the near future. Therefore, in the meantime, for supported accommodation claims we are giving LAs flexibility and discretion to decide which cases they believe it is worth undertaking an FCR, subject to certain parameters.

The aim of the HB Award Accuracy Initiative is for the LA to undertake at least one FCR on a case within a 12-month period. When deciding whether or not to undertake an HB Award Accuracy FCR on a supported accommodation case, the LA should consider whether a FCR has already been completed within the last 12 months or whether one is planned within the next few months. Additionally, some LAs may elect to schedule reviews to coincide with known rent increases or when other changes are due to be made and decide it is sensible to undertake a review at that point.

If an HB Award Accuracy FCR has not been undertaken within the previous 10 to 12 months, and no review is scheduled, we would expect LAs to undertake an HB Award Accuracy FCR. If it was only 1 or 2 months ago since the LA undertook an FCR, or the LA has robust arrangements in place to pick up tenancy changes, the probability of picking up a termination or change is unlikely and it would almost certainly not be worth doing an HB Award Accuracy FCR again. In these circumstances the LA should proceed to the next highest risk case where the probability of identifying an unreported change will be higher.

Ultimately, it is an LA’s decision whether or not to undertake HB Award Accuracy FCRs on supported accommodation cases. However, it is important that such decisions should be made on an informed basis with the aim of identifying as many unreported changes as possible.

Q11. How do LAs correctly record intervention outcomes from HB Award Accuracy FCRs when the outcome includes a mix of changes to the existing live benefit award and/or potential multiple historic overpayments or underpayments?

A11. The importance of accurate recording of FCR information on front end IT Systems was communicated in circular HB A9/2020 - as this information will be captured by the corresponding SHBE fields and used to inform subsequent DWP MI reports. It is imperative that LAs are compliant with their IT supplier guidance in recording information both fully and accurately on the front end IT Systems for activity relating to:

• fraud and error detection
• change
• error

On completion of an HB Award Accuracy FCR, there are a number of potential scenarios to consider for recording the required intervention outcome – outcome of fraud and error detection activity:

• current (‘live’) benefit award increases as a result of the HB Award Accuracy FCR – (with/without a past ‘net’ overpayment or underpayment) – record as code 1 = Benefit increased/earlier underpayment found but no change to live payment

• current (‘live’) benefit award decreases as a result of the HB Award Accuracy FCR – (with/without a past ‘net’ OP or U/P) – record as code 2 = Benefit decreased/earlier overpayment found but no change to live payment

Note: Any change to current (‘live’) benefit award should take precedence in determining the outcome recorded. If there is no change to the current benefit award, then identification of overpayment(s) and/or underpayment(s) should determine the classification to use:

• no change to current benefit (‘live’) award as a result of the HB Award Accuracy FCR, but a past (‘net’) underpayment has been identified/occurred – record as code 1 = Benefit increased/earlier underpayment found but no change to live payment

• no change to current benefit (‘live’) award as a result of the HB Award Accuracy FCR, but a past (‘net’) overpayment has been identified/occurred – Record as code 2 = Benefit decreased/earlier overpayment found but no change to live payment

Note: The FCR might potentially identify multiple historic/past overpayments and/or underpayments, so LAs should use a ‘netting’ off approach to determine whether to classify as a majority overpayment (Code 2 – Benefit decreased/earlier overpayment found but no change to live payment) or underpayment (Code 1 – Benefit increased / earlier underpayment found but no change to live payment). If no ‘netting’ applied or impracticable to use, LAs should use ‘larger amount’ to determine whether to classify as overpayment (Code 2 – Benefit decreased/earlier overpayment found but no change to live payment) or underpayment (Code 1 – Benefit increased / earlier underpayment found but no change to live payment).

• no change to current benefit (‘live’) award as a result of the HB award accuracy FCR, and no past overpayment(s) nor underpayments have been identified – record code 3 = No change to benefit amount

• SHBE guidance for ‘Outcome of fraud and error detection activity’ field extract:

  • 176: Outcome of fraud and error detection activity - HB:
    • 1 = Benefit increased/earlier underpayment found but no change to live payment
    • 2 = Benefit decreased/earlier overpayment found but no change to live payment
    • 3 = No change to benefit amount
    • 4 = Not known/not recorded

Note: Individual IT Suppliers might have opted not to exactly replicate the numbering/wording of these outcome descriptors in the outcome options – if it is not evident which descriptor applies then you should refer to your IT supplier guidance.

On completion of HB Award Accuracy FCRs that identify a change to current benefit awards and/or overpayments/underpayments, it is also important that LAs follow standard business as usual practice in accordance with their respective IT supplier guidance to capture both change and error (overpayment or underpayment) information, in addition to completing the intervention fields.

If you have any questions regarding the above frequently asked questions you can email: lawelfare.frauderrordebt@dwp.gov.uk.

Q12. What happens if an HB claim migrates to UC in the middle of an FCR?

A12. Existing regulations make detailed provision in respect of changes in circumstance and termination of HB entitlement, including UC migration. As with any change that terminates HB entitlement (vacation, income or capital exceeds threshold) the fact it is received after the start of any fraud and error activity does not impact on existing change, suspension or termination rules. The same principle applies with a UC ‘Stop notice’. In relation to the completion of fraud and error activity management information, any change including the UC Stop notice, received after the activity has started and before completion of the same activity should be recorded appropriately. This includes the recording of the outcome of the fraud and error detection activity.

The assumption made is the review activity is the catalyst for the change regardless of reasons. To do otherwise would add additional complexity, and the assumption is consistent in historical fraud and activity initiatives.

Q13. Should LAs carry out FCRs on cases that have already been reviewed recently?

A13. We are giving LAs the flexibility and discretion to decide which cases they believe are worth doing an FCR, within certain parameters. So, for example, if you had done a FCR on any type of case 11 months ago, we’d expect LAs to consider whether it was worth doing again now. If it had only been one month since the FCR, it would almost certainly not be worth doing again. If over 12 months since the last FCR, we’d definitely expect this case to have a fresh FCR completed.

However, if the case had only been partially looked at in the last 12 months, then once again, we would expect LAs to consider whether it was worth looking at for a FCR now. An example would be if a Verify Earnings and Pensions Alert had been actioned last month, but the rest of the case details had not been reviewed for well over 12 months.

If, however, you have commenced a review on a case prior to being notified of a UC award from DWP, it will have to be completed and an outcome recorded against the fraud and error detection activity.

Q14. Should LAs action every case?

A14. If a case is marked as high priority on the Risk file, there isn’t an expectation that you will undertake an FCR on every case; particularly if you have undertaken a recent FCR on the case. Whether you undertake an FCR on these cases will, in part, be driven by what recent review activity has been undertaken on the case and a local assessment on the value of undertaking a further review. We will be monitoring volumes of FCRs you undertake identified via the Risk file, rather than the actual cases identified on the file. If you reach a position where you don’t have the volumes of high risk cases marked on the file to meet the volume you’re expected to undertake, you are encouraged to consider the next highest ‘risk scored’ case on the file; noting that you will have a risk score for every HB case on your caseload.

Q15. Can LAs close outstanding and dormant interventions on systems and how will this impact on management information?

A15. We have received a number of queries from LAs seeking advice on what they should do with long outstanding and dormant work held within intervention systems. In other words, where a fraud and error detection activity has been initiated (captured in SHBE field 171) but an outcome activity entry has not been populated.

Many LAs would like to close these old activities, so that they can manage their HB Award Accuracy Initiative work more effectively without impacting the management information provided to the DWP.

From a DWP perspective, there is no obligation at this time for LAs to ‘close’ these old activities but we understand that some LAs may wish to do so as part of system ‘cleansing’ activity. DWP’s advice to LAs is that you can close/cleanse these long outstanding activities by carrying out both these actions:

• inputting a date the fraud and error detection activity completed (captured in SHBE Field 175)

• recording the outcome as not known/not recorded within the outcome of fraud and error detection activity (captured in SHBE Field 176)

• these actions should not result in any change to an HB award or generate an error record

LAs should note that, for HB Award Accuracy Initiative monitoring purposes, we will only be extracting interventions with a start date that’s within the scope of the Initiative (phased from 7 September 2020).

LAs should ensure that they only apply this type of case cleansing activity to cases that hold a date the fraud and error detection activity initiated prior to 7 September 2020. Where the date initiated falls on 7 September 2020 or later then LAs should complete all the appropriate fields in accordance with their supplier guidance for the HB Award Accuracy Initiative or other types of fraud and error activity.

MI

Q16. What MI will LAs need to manage HB Award Accuracy Initiatives effectively?

A16. You can monitor your own performance for:

• FCRs – by extracting data locally from your SHBE. It is important to accurately record your activity on front end IT Systems, in line with your IT Supplier Guidance, to enable the accurate capture of MI via SHBE, otherwise the MI extracted will not accurately reflect the activity undertaken by your LA

• HBMS Referrals including SERs – by capturing all information on the HBMS MI Spreadsheets issued to LAs with each monthly set of HBMS data referrals. LAs will need to put their own processes in place locally to collate the information from the spreadsheets into a report to meet their own local requirements. Again the accuracy of completion of the spreadsheets is essential in ensuring it reflects the activity undertaken by the LA. Details on the completion of the HBMS MI Spreadsheets has been revised and is contained within the HBMS Rules Guide available on Glasscubes.

Q17. What happens if LAs find that there is an issue in sending their SHBE return to DWP?

A17. If there is a problem returning your monthly SHBE file to DWP you should let us know straightaway by sending an email to: ifd.shbe@dwp.gov.uk. We will then work with you and your software supplier to ensure this is resolved as soon as possible.

Data Delivery

Q18. When will LAs receive the first set of 2021-22 data and who will this go to?

A18. LAs will receive their first set of data in scope for the 2021-22 Initiative in line with March 2021 HBMS data issued between the week commencing 8 March 2021 and the week commencing 29 March 2021. The HBMS file will be delivered via Transfer Your File. This will be adjusted where LAs choose a deferred start date of 5 July or 4 October 2021.

LAs are required to confirm their chosen intention by 23 March 2021 using the options provided below:

• I commit to starting on the 6 April 2021

• without commitment, I intend to start on 5 July 2021 and will confirm this, or otherwise by 21 June 2021

• without commitment, I intend to start on 4 October 2021 and will confirm this, or otherwise by 20 September 2021

• without commitment, I intend to opt out in 2021-22 and will confirm this by 20 September 2021

Performance

Q19. What will happen if a participating LA fails to process activities which they have received funding to undertake?

A19. LA-PED will be monitoring performance and will engage with individual authorities where performance does not appear to be in line with the funding provided. If an authority is experiencing difficulties which are impacting on the ability to undertake any activity – please contact the LA-PED Performance Development Team (PDT) at: lawelfare.pdtprm@dwp.gov.uk

Subsidy

Q20. Will confirming participation in these activities have an impact on subsidy?

A20. No. There are no additional subsidy impacts from opting in to these activities. The subsidy calculation for cases reviewed under these initiatives will be as normal.

Q21. Can the funding be used to cover costs of existing staff carrying out business as usual activities?

A21. The funding is to be utilised to drive the 3 activities. It should not be used for funding IT or business as usual reviews.

To secure this funding DWP has had to assure HM Treasury that it will used to pay for additional staff or backfill for existing staff.

One of the requirements that comes with the funding is that funding is used to generate additional resources to undertake these activities. If LAs choose to use existing experienced HB staff the expectation is that these posts would be backfilled either through redeployment within the LA or by new staff recruitment to ensure the HB delivery activities, they were undertaking are maintained. The feedback we have already received is that many LAs are planning to retain staff they would otherwise have to release due to funding reductions. You can use overtime or outsource the work if necessary. However, if you use overtime your funding may not be sufficient to deliver the expected volumes and you will still be required to process all the activities.

You may be required, on request, to provide evidence that the funding provided to support the delivery of the activities has resulted in additional HB staff resources.

Q22. When will LAs receive the funding?

A22. We expect LAs to be paid their funding for 2021 to 2022 on their confirmed start date. This will be notified to LAs directly with their amount payable. Note: LAs should allow time for internal administration and banking transfers.

Q23. Can LAs obtain additional funding if they agree to undertake review activity on data supplied via the HBMS file between March 2020 and August 2020?

A23. No. Although considered, it was concluded that providing this aspect of flexibility would be counter-productive, given the additional resource intensive burden required to provide accurate MI to enable the intelligent monitoring of performance. Furthermore, the impact of the COVID-19 pandemic on the HB caseload would mean much of the data issued around March to August 2020 is too dated and likely to result in high levels of nugatory work.

Q24. Is there any way DWP can counter the impact of LAs losing out financially in terms of more Fraud and Error resulting in more overpayments, loss of subsidy, the costs of recovery and resources needed?

A24. It is not possible to estimate the level of potential subsidy loss due to LAs finding increased Fraud and Error. LAs have a statutory obligation to ensure HB claims are correct and the HB Award Accuracy Initiative will incentivise LAs to focus more effort in this area.

Overpayments relating to claimant error and fraud attract a 40% subsidy. LAs on average collect 67% of overpayments. If an LA improves its collection it could benefit from recovering the loss of subsidy and the amount of HB paid (equating to 140%). PDT is working to support LAs with recovery and has published the HB Overpayment Recovery Good Practice Guide.

Q25. Overpayment recovery rates are not good enough to compensate for the subsidy penalty of finding the overpayments. What is DWP going to do to reduce the subsidy penalty?

A25. DWP are not planning to change the subsidy penalty. The majority of LAs have recovery rates over 60%, the average being 88%. Therefore, based on current evidence there is no need to change subsidy legislation. It is worth remembering that LAs always have the option of calling in our free PDT consultancy service to support you in identifying further ways to increase your overpayment recovery rates.

Engagement

Q26. How will the PDT work with LAs to understand or improve HB Award Accuracy Indicator information?

A26. The Performance Development Team (PDT) are happy to engage with you. PDT offer free consultancy which is currently being undertaken ‘virtually’.

PDT would also be interested to engage with you if you are a good performer and are able to share any good practice.

You can contact PDT at: lawelfare.pdt@dwp.gov.uk

Miscellaneous

Q27. What is the average change in weekly HB and average overpayment expected from each FCR?

A27. The 2019 pilot found an average change in the weekly HB amount of £34.04, and an average overpayment raised of £1,362.

Q28. What happens if an LA confirms participation but then unexpected events at a later date mean that they can’t meet the promised requirements?

A28. We recognise that the COVID-19 pandemic means we live in uncertain times and, therefore, that unexpected events may occur. In that case, we would expect LAs to inform us as soon as possible by email to lawelfare.frauderrordebt@dwp.gov.uk. We would then work with and support the LA to understand what options we both have to ensure as many of the requirements associated with the funding are met.

Q29. To mitigate the impact of overpayments created as a result of finding more reductions to weekly benefit entitlement, could LAs calculate the overpayment from the week in which the change is identified rather than the date of change?

A29. DWP guidance to LAs in the Calculation of Overpayments Guide (section 3.2) is to calculate the overpayment from the benefit week in which any change in HB should have been actioned up to the date entitlement actually reduced or ended. LAs should also adhere to the provisions of the HB Regulations 2006.