Guidance

COVID-19 Chapter 14: Validation

Updated 15 December 2021

This guidance was withdrawn on 14 April 2022

This guidance is no longer current and is not being updated. Find the latest Work and Health Programme (including JETS) provider guidance’

Applies to England and Wales

This is Work and Health Programme Coronavirus (COVID-19) specific guidance, including Job Entry Targeted Support (JETS).

Due to measures and restrictions imposed during the Coronavirus (COVID-19) period, some elements of the Work and Health Programme have been varied. These variations also reflect the contract variations CV01, CV04 and CV05 & CV06.

The following temporary guidance is for use only during this COVID-19 period, as defined by the period contract variations are in place. Procedures and guidance will revert to pre-COVID-19 versions as these variations are revised or revoked. A full version of the original Work and Health Programme guidance remains in publication for reference.

General Information (WHP Core & WHP JETS)

For the period of COVID-19, ‘outcome payments’ and ‘Payments’ become employment outcomes. There is no PBR through the COVID-19 period, although we will continue to track outcomes by the same method. For WHP Job Entry Targeted Support (JETS), PBR is currently not applicable for the period of 12 months starting October 2020.

1. You must ensure that you only submit accurate information for employment outcomes to which you are entitled. Where you are aware that a Participant has started employment which cannot be counted towards an Outcome in accordance with your Contract (i.e. any Non-Qualifying Period) you must inform DWP to avoid incorrect performance being recorded.

Further information can be found in COVID-19 Work and Health Programme including Job Entry: Target Support (JETS) Provider Guidance Chapter 13 – Funding Model.

2. DWP will, to the extent it deems necessary, undertake checks on outcomes you have achieved.

3. You are required to maintain, on an ongoing basis, a robust system of internal records and control, sufficient not only to support any Outcome claims you make but also to allow you to undertake internal management checks and enable independent testing and validation by DWP, ESF and other external bodies.

The records maintained must document how and when the appropriate supporting evidence was obtained and must be accurate at the point any validation is to or does take place.

4. The risk of records being inaccurate and/or incomplete is wholly borne by you.

5. Employer names are not received in the HMRC information within RTE.

6. It is an ESF requirement to record the result which shows a Participants status within 4 weeks after completing the programme. You must ensure you have robust systems in place to assure that the information you are providing is correct.

Evidence of an ‘employed’ result may be demonstrated by using information DWP have shared with you in PRaP as part of the automated payment model.

All evidence should be stored and retained in line with Generic Provider Guidance Chapter 11b – European Social Fund (ESF) requirements 2014 – 2020 (England Only).

7. The onus is on you to collect and retain the job outcome evidence as required. Should any penalty be imposed by the ESF managing authority due to the availability or suitability of evidence we may pass on any resulting financial penalty to the appropriate organisation.

Validation Overview (WHP Core & WHP JETS).

8. For Work and Health Programme DWP will be Recording Employed Outcomes automatically, based on HMRC earnings data. The determination of Outcomes will be solely based on this data, with the exception of those gained by SCR Participants which you should report clerically (see paragraph 64 onwards for details).

9. For Self Employed Outcomes you must report a qualifying outcome to DWP via PRaP. Self-Employed validation will be a mix of automated and manual checks pre and or post payment.

Currently (see para 12), WHP core manual validation is primarily pre-payment; for WHP JETS, manual validation will primarily be conducted post-payment. If applicable, the SCR claims process will also apply to self-employment validation.

10. For WHP JETS self-Employed validation will be a mix of an automated check and, or manual checks and will be conducted post-payment on an ad hoc basis If applicable, the self-employed validation process will apply to the SCR claims performance notifications process.

11. For Self Employed Outcomes you must report a qualifying outcome to DWP via PRaP. DWP may undertake benefit check(s) which will identify if the Participant has a relevant period where they have not been in receipt of primary benefits.

This check is typically undertaken prepayment but may be repeated, including post payment. Where the Participant has claimed Universal Credit, a check may be undertaken to establish compliance with appropriate conditionality regime.

12. DWP may move from or to a mix of either a pre-payment and or a post-payment sampling and may vary how the checks are carried out, within the spirit of the contract, to achieve legitimate outcomes. If DWP decides to alter the validation approach in the lifetime of the contract, DWP may include extrapolation where samples of outcomes are checked from across a wider population of claims.

13. For WHP Core and WHP JETS DWP may conduct pre and/or post payment validation checks to determine whether the Provider is entitled to receive payment(s) against the Cost Claims submitted.

14. For WHP Core and WHP JETS DWP will recover any overpayment(s) including any associated with Cost Claims failing validation. This will be in accordance with the provision in Contract Variation CV04 and CV06.

15. In a sampling regime, where DWP identify incorrect Outcomes, not only will these be recovered but the error rate will also inform any extrapolation calculation, which will be applied across untested like for like claims from the same period.

16. The validation of job Outcomes will be determined by the type of employment; either the Participant is employed by an employer or the Participant is self-employed.

Employed Outcome - Validation Process (WHP Core & WHP JETS)

17. Participants moving into employed work will be identified by DWP solely using HMRC PAYE on-line earnings data submitted by employers, subject to the notification by you of any Non-Qualifying Earnings and/or SCR provision for clerical claims at paragraph 64 onwards.

This data is submitted to HMRC each time an employee is paid by an employer and no evidence of this is required from Providers.

18. Your outcomes will be based on the information contained within this HMRC PAYE on-line earnings data. Further details can be found in COVID-19 Work and Health Programme including Job Entry: Target Support (JETS) Provider Guidance Chapter 13 – Funding Model.

19. The Outcome achievement period runs for 639 calendar days for The Work and Health Programme (WHP core) or 238 calendar days for WHP JETS from the Participant’s start date. Only earnings received within that period will count.

20. For The Work and Health Programme (WHP core), DWP will track Participant earnings from HMRC PAYE data for a maximum period of 701 calendar days from the Participant’s start date and will continue to look for earnings received in the 639 calendar days. Where a Participant exits the programme early the Department will end the registered interest with HMRC.

Where an Employed Outcome is achieved, DWP will also end the interest with HMRC.

21. For WHP JETS, DWP will track Participant earnings from HMRC PAYE data for the qualifying period 238 calendar days from the Participant’s start date and will continue to look for late earnings received in the 61 calendar days after the 238 day up to day.

Where a Participant exits the programme early the Department will end the registered interest with HMRC. Where an Employed Outcome is achieved, DWP will also end the interest with HMRC.

22. For the Work and Health Programme (WHP core) earnings will be cumulative from the Start Date of the 639 calendar days. This could be made up of earnings from one employer or a number of employers at the same time or a number of employers during the 639 calendar day period. Earnings prior to starting on the programme will not count towards an outcome.

Earnings from any Non-Qualifying Period will also not count towards an outcome. For the avoidance of doubt, this includes all earnings during this period, regardless of the source of the earnings.

23. For WHP JETS earnings will be cumulative from the Start Date of the 238 calendar days, but will be sought for 299 calendar days. This could be made up of earnings from one employer or a number of employers at the same time or a number of employers during the 238 calendar day period.

Earnings prior to starting on the programme will not count towards an Outcome. Earnings from any Non-Qualifying Period will also not count towards an Outcome. For the avoidance of doubt, this includes all earnings during this period, regardless of the source of the earnings.

Please note - for both WHP core, and WHP JETS, only one Outcome can be achieved per Participant and must be wholly achieved in either employment or self-employment. Self-employed earnings cannot be combined with direct employment earnings for the purpose of achieving an outcome.

24. As Employed Outcomes occur you will be able to generate a report in PRaP which details this information. This report will also contain information about when first earnings are registered for a Participant once they have started on the programme. DWP will not supply the name or address of a Participant’s employer.

25. The Employed Outcome and validation process is automated, once an Outcome has been achieved, or 639 days for The Work and Health Programme (WHP core) or 299 calendar days for WHP JETS have elapsed from the Participant’s Start Date the line will be automatically closed. You will not have a right to appeal or request reconsideration on Employed Outcomes.

26. When an Employed Outcome has been achieved you must complete and return an ESF 14-20m End form if not already submitted.

Cost Validation

27. For the COVID-19 period individual elements of the costs contained in the OBCM returns will be subject to audit, assurance and validation on a sampling basis through the DWP Financial Control Framework.

Where underpinning evidence does not support the costs or the costs being charged to the contract the ‘errors’ will be subject to extrapolation and an escalation process. You will need to retain the necessary evidence to support validation in line with the contract and to be specified in more detail at a later date.

JETs Validation

28. DWP may at its absolute discretion, undertake performance validation for JETs. We may vary the approach to validation to ensure ultimately we only verify legitimate outcomes.

Self Employed Outcome - Validation Process (WHP Core & WHP JETS)

29. As the data supplied by HMRC does not contain earnings from self-employment, these outcomes are based on duration of self-employment and you will be required to claim all self-employed outcomes. You must update PRaP with the date the self-employment started.

30. It is up to you to ensure that at the point of submitting a self-employed outcome you are entitled to do so.

31. To enable a successful Self Employed Outcome claim, you must hold sufficient evidence for the entire claim period (up to and including the last date of the claim period) that satisfies both Work and Health Programme Core and WHP JETS, in England only, ESF requirements and proves that the Participant is self-employed.

In addition you must provide current, accurate and valid contact details for the Participant that enable DWP to gain a response from the Participant and allow full validation to take place (see: paragraph 46 for primary contact method and paragraph 3 for robust control system).

32. For the avoidance of doubt, any Self Employed Outcome claim without a date, inaccurate or invalid contact details for the Participant (to note, the information must be accurate at both the point of submission and the point of validation), including but not limited to not known at this address responses, dead letter boxes and unobtainable or out of date telephone numbers, will result in a claim being categorised as an Outcome Fail.

33. Self-Employment will be tracked solely by you. DWP does not prescribe the way in which you should track or record information about self-employment activity.

However, the evidence should demonstrate that it meets the Work and Health Programme (WHP core) or WHP JETS definition of self-employment. In addition to current, accurate and valid contact details for the Participant, you must obtain evidence to confirm the Participant has been self-employed for the relevant period, this could include:

• HMRC registration
• proof of benefit claim closed (letter issued to claimant by Jobcentre Plus)
• bank statement showing details of recent transactions or earnings
• invoices, purchase orders received or sent recently which are clearly in relation to the running of business

(Note: this list is neither prescriptive nor exhaustive)

34. You will need to retain a suite of evidence to corroborate the totality of the trading period prior to making a claim.

35. There is specific information that you are required to input to the Job Details Screen within PRaP when you submit a Self Employed Outcome claim:

• Current, accurate and valid Contact details, including the current address, contact name, full business telephone number and email address (where applicable).

Please note, a valid telephone number is always required as this is the contact method used when validating a Self Employed Outcome, unless in exceptional circumstances another method is used through your prior agreement with the Department.

• The Participant’s contact details, where different from above
• Start date of self-employment
• End date of self-employment (where already known)

36. As it is not possible to fully automate Work and Health Programme (WHP core) and WHP Jets Self-Employed Outcomes, manual validation will be required.

Where DWP identifies that there are a significant number of Self Employed Outcome claims but the start and end dates, as submitted, are unaligned, DWP may review your internal assurance processes.

37. A Self Employed Outcome for The Work and Health Programme Core will be achieved when the Participant has been in business on a self-employed basis for a cumulative period of 182 days (26 weeks) within their 639 day period.

As part of making a successful claim for performance, the supplier will need to identify and must submit Self Employed Outcome claims within 700 days of a Participant’s start date.

This is made up of the maximum 456 calendar days on Programme, 182 calendar days qualifying period which self-employed job outcomes are claimable and a 61 day period to claim the outcome.

38. A Self Employed Outcome for WHP JETS will be achieved when the Participant has been in business on a self-employed basis for a cumulative period of not less than 56 days’ (8 weeks) within their 238 days qualifying period from their start date.

As part of making a successful claim, the supplier will need to identify and must submit Self Employed Outcome claims within 299 days of a Participant’s start date. This is made up of 238 calendar days qualifying period which self-employed job outcomes are claimable/notifiable. There is an additional 61 days for Providers to claim the outcome performance.

Please note - for self-employment validation purposes, a week is defined as a 7 day period where a minimum of 1 day meets the criteria.

39. Where a Participant moves into self-employment (WHP core) and will not achieve their outcome by day 456 you must extend their time on programme, via PRaP, no later than day 456 to enable any Self Employed Outcome claim to be made. (Please note this is not applicable for WHP JETS).

40. All Self Employed claims are subject to an off-benefit check (OBC). This check seeks to establish whether the Participant was claiming any of the main working age benefits between date 1 and 2 set by Providers on PRaP.

Whilst the check may be undertaken pre and or post payment on a manual or automated basis, it is typically an automated check conducted pre-payment against Department systems.

41. Where the check identifies the Participant was claiming UC or was off-benefit for the required 182 calendar days the claim will move into the next stage of validation. Where neither UC or 182 days off benefit are identified, the claim will fail (The Work and Health Programme core only).

For WHP JETS only, where the check identifies the Participant was claiming UC or was off-benefit for the required 56 calendar days the claim will move into the next stage of validation. Where neither UC or 56 days /weeks of claim period off benefit are identified, the claim will fail.

42. Following the OBC all outcomes will be put on hold for manual validation. Outcomes will be released if they pass the manual validation or they have not been able to be validated within 28 days of the claim being made, where current, accurate and valid contact details are held (see paragraphs 3, 4, 31, 35 and 46).

All claims will be backed out if the claim fails this manual check (not just non-UC cases).

Please note - if your claim passes the OBC but fails manual validation, you are only allowed three attempts in total to claim. If the third claim fails it will remain a fail and be recorded as an Outcome Fail. At this point the line will be closed. If an Employed Outcome is later achieved, this will be identified and counted as a performance outcome as part of the settlement process at paragraph 54.

43. All UC related claims that fail the OBC will be subjected to manual checking of UC records.

44. All OBC passes will be subjected to 100% manual validation – either in the UC system, to determine if they are/were complying with the UC conditionality for self-employment and/or directly with the Participant. These checks will also be appropriate for those Participants who may have been referred by Signposting Organisations (SOs) where no benefit claim may be held.

45. For those claims being subjected to manual validation there are three possible validation results – pass, fail, or unable to validate:

Pass

The UC system provides evidence of a cumulative 182 calendar day period for The Work and Health Programme (WHP core) or 56 calendar day period for WHP JETS of self-reported self-employment or the Participant confirms the condition for performance award, as set out in the Self Employed Outcome validation definition, has been met.

For legacy claims (i.e. not UC) the Participant confirms self-employment status for the relevant period.

Fail

There is insufficient evidence within the UC system of a cumulative 182 calendar day period for The Work and Health Programme (WHP core) or 56 calendar day period for WHP JETS of self-reported self-employment or Participant supplies information which means the condition for performance award, as set out in the Self Employed Outcome validation definition, has not been met and/or a combination of both.

For the avoidance of doubt, where current, accurate and valid contact details for the Participant (see paragraphs 3, 4, 31, 35 and 46) are not supplied, this will result in a claim being a Fail.

Unable to Validate (UTV)

At the manual validation stage, DWP has either not been able to obtain a response from the Participant using the contact details supplied by you (you must ensure such details are current, accurate and valid - see paragraphs 3, 4, 42, 43 and 51), or the Participant is unable/unwilling to provide the information required to validate the Outcome.

DWP will continue to try to validate the Outcome for up to two months after the claim has been approved and entered onto PRaP. After two months the claim will be considered as a UTV and added to the total of UTVs for that cohort and will be subjected to apportionment at the end of the cohort. This is discussed later in the unable to validate action section.

46. Where validation is conducted through contacting the Participant, the primary method for this contact is via the telephone. By exception, for any individual Outcome claim, DWP will consider alternative contact methods to this approach by prior agreement.

In cases where DWP is experiencing difficulty making contact with the Participant via the telephone, DWP may contact you to confirm the details you have supplied in PRaP, which you must supply within five working days of request.

47. You are required to hold and supply correct information which is accurate at both the point of submitting an Outcome claim and at the point of validation of that Outcome and which enables DWP to gain a response from the Participant. If you do not provide sufficient detail with the claim that enables DWP to validate the Outcome, the claim will fail validation.

You will be advised of this and have five working days to reply but the claim will remain as an Outcome Fail, unless and until sufficient information is supplied to enable DWP to gain a response within the prescribed time which then enables the claim to be successfully passed. Outcome Fails remaining at the end of the cohort will be used in the apportionment calculation.

48. Validation processes may differ dependent on whether the Participant is in receipt of UC or not for both WHP Core and WHP JETS.

49. For Participants in receipt of UC, DWP will access pertinent data within a Participants UC record. DWP will use this to determine if a Participant is gainfully self-employed for UC purposes, but may also seek other sources of validation.

50. For UC claimants DWP will be checking that during a cumulative period of 182 calendar days or more for The Work and Health Programme (WHP core) or 56 calendar days or more for WHP JETS the Participant:

• is in receipt of UC and earnings are declared monthly (in line with UC requirements) to DWP. DWP will be checking if earnings are declared not the amount of the actual earnings.

• is not in receipt of any relevant benefit and has a cumulative period of 182 calendar days for The Work and Health Programme (WHP core) or 56 calendar days for WHP JETS of trading

• a combination of the above, i.e. where UC is in payment, earnings are declared monthly (in line with UC requirements), and where UC is not in payment, the Participant is not in receipt of any relevant benefit and continues trading continuously.

51. Where DWP confirm a Participant is self-employed for UC purposes within their manual pre-payment validation checks, subject to also meeting the Self Employed Outcome definition, the claim will be sent for outcome as soon as this is confirmed.

52. Where DWP identify any Outcome Fails whilst completing their manual pre-payment validation, the claim will be backed out of PRaP and will not be counted, if it is found to be an Outcome Fail at the post-payment stage it will be backed out of PRaP and the performance recovered.

Should a supplier establish a subsequent valid Self Employed Outcome for the Participant, the line will be available for them in PRaP, to resubmit another claim. It is expected that the necessary steps will have been taken to establish the validity of the claim and the information supplied with it.

53. When a self-employed outcome has been claimed and validated an ESF 14-20m End form must be completed and returned if not already submitted.

Unable to Validate action (WHP Core & WHP JETS)

54. You will be notified when a Self Employed Outcome has been counted but may become classed as Unable to Validate and therefore subjected to apportionment at the end of the 700 calendar days for the Work and Health Programme (WHP core) or 299 calendar days for WHP JETS.

55. In these cases, DWP will continue to undertake validation activity on the Self Employed Outcome for a further two months after the award of performance date. At this point DWP would cease validation activity on the claim and add the instance to a cohort of UTV claims, prior to apportionment. You will be notified when this occurs.

Apportionment (WHP Core & WHP JETS)

56. The UTV claims will then be apportioned (paragraph 56 refers).

57. Prior to the apportionment a final check may be made to determine if an Employed Outcome had been achieved in the period and would therefore remove the UTV from the apportionment.

58. The reconciliation will take into account the pass and fail rates and the performance achieved by the cohort. The apportionment results will be shared with you and a financial recovery total will be made as and when required.

Settlement (WHP Core & WHP JETS)

59. The Department will conduct a check of the start cohort taking into account factors which may have impacted upon the total figures such as apportionment. If necessary, the Department will recoup any outcomes.

60. The very last Outcome will be made by DWP to the supplier no later than 791 days after the last start on The Work and Health Programme (WHP core) or no later than 299 days after the last start on WHP JETS.

Management Checking (WHP Core & WHP JETS)

61. In addition to the validation principles set out above, DWP may also conduct management checks to further verify the validity and robustness of Self Employed Outcomes claimed.

62. These checks will support the exploration of controls around Self Employed Outcome. Although these management checks will not form part of the standard validation process, they will aid DWP in identifying potential patterns or fraudulent activities.

63. An example of a management check might include investigating jobs undertaken by Participants or if the Work and Health Programme Participant’s (WHP core) business has a footprint such as an operating website etc.

Special Customer Records (clerical claim process-WHP Core & WHP JETS)

64. The majority of claims must be submitted via PRaP however, where you have a Participant who is granted Special Customer Records (SCR) status (as determined by HMRC) due to the very sensitive nature of data to be held on the individual e.g. witness protection, you are required to submit a claim following the SCR clerical claim process.

Where DWP identifies that SCR status is not granted the claim will be rejected.

65. Where you have a SCR claim, you are required to print off the PRaP11 form and complete manually. You must only submit claims on these forms on the rare occasions that SCR status is granted.

66. This clerical process mirrors the PRaP automated process however as the Department will be unable to monitor earnings on an on-going basis you will be required to track the individual’s earnings and then invoke the clerical claim process at the point the employed earnings threshold has been met.

The Provider Payment Validation Team will conduct a clerical off-benefit check and validate employment with employers and/or Participants. Incomplete forms will not be acted upon and will be returned.

67. Where you have a SCR claim, you will need to follow a clerical process. If you receive an SCR2 clerical referral you must only submit claims on the PRaP11 forms after tracking a Participant’s employment and confirming an outcome has been achieved.

68. Guidance to assist you in the completion of the form can be found by opening the excel form and placing the cursor over the small red corners of the relevant cells.

69. For SCR employed outcomes where you submit a clerical claim, we will attempt manual validation of the claim. If the claim cannot be validated it will become classed as Unable to Validate and therefore subjected to apportionment at the end of the 700 calendar days for The Work and Health Programme (WHP core) or 299 calendar days for WHP JETS.

70. You should send your fully completed claim form to:

Provider Payment Validation Team (PPVT)
Department for Work and Pensions
Finance Group - Contracted Health & Employment Services Directorate, Floor 1,
1 Hartshead Square,
Sheffield, S1 2FD

71. All clerical documents carrying personal information should be retained securely in line with the Data Protection Act Principles. For further information please refer to Guide to the General Data Protection Regulations (GDPR). The Principles.

Should you require a copy of any of the forms mentioned in this chapter, please email: whp.enquiries@dwp.gov.uk