Guidance

COVID-19 Chapter 4: Action planning

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This guidance was withdrawn on 14 April 2022

This guidance is no longer current and is not being updated.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 and 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.

Action planning (WHP Core and WHP JETS)

1. Your evidence of action planning must comply with the Contract including, without limitation, the revised Customer Service Standards (CSS) for the COVID-19 period, your tender and the Specification.

2. For WHP Core following the initial meeting with the Participant, you should start high-level, initial action planning activity. A signature is not required on the Action Plan at this stage. Further information regarding the initial meeting can be found in COVID-19 Work and Health Programme Provider Guidance Chapter 3 - Acknowledging referrals, initial Participant engagement and registering a start.

3. For WHP Core you are required to complete an Action Plan, which has been agreed and signed by you and the Participant, within 20 working days of Participant referral.

4. For WHP JETS following the initial appointment/first appointment with the Participant, you should start high-level, initial action planning activity. A signature is not required on the Action Plan at this stage. COVID-19 Work and Health Programme Job Entry: Targeted Support (WHP JETS) Provider Guidance Chapter 3b - Acknowledging referrals, initial Participant engagement and registering a start.

5. For WHP JETS, you are required to complete an Action Plan, which has been agreed by you and the Participant, within 10 working days of the Participant’s start date. For ESF participants, the Action plan must have a wet signature. Where you are unable to obtain a Participant signature due to COVID-19, annotate the Action Plan with COVID-19 and email evidence, (for audit) should be gathered and retained to demonstrate the participant’s participation in the programme.

6. For WHP core and WHP JETS this is one of the revised Customer Service Standard (CSS) for the COVID-19 period on which you will be performance managed. Further information can be found in COVID-19 Work and Health Programme including Job Entry: Target Support (JETS) Provider Guidance Chapter 16 - Performance Management.

7. The minimum requirements are that all activities in relation to participants must be recorded in your evidence of action planning.

Actions

• Ensure the Participant understands what they are being asked to do, why they are being asked to do it and when it must be completed by. Where you are notified, or identify that a Participant has complex needs and/or additional support requirements, you must carefully consider any impact these may have on the Participant’s ability to understand or comply with the requirements

• Set activities on Action Plan which are SMART (Specific, Measurable, Achievable, Realistic and Time-bound).

8. Further information on the above bullets can be found in COVID-19 Work and Health Programme including Job Entry: Target Support (JETS) Provider Guidance Chapter 6 – Working with Participants with complex needs and/or additional support requirements and Chapter 16 Performance management and compliance monitoring.

9. Ensure evidence of all interactions are recorded, dated, signed and held for all Participants, in line with the customer journey detailed in your tender. If a Participant cannot or refuses to sign, you must record the reason for this. Where you are unable to obtain a Participant signature due to COVID-19, annotate the Action Plan with COVID-19. Email evidence (for audit) should be gathered and retained to demonstrate the individual’s participation on the programme.

10. For WHP core ensure the Action Plan is reviewed, updated and signed by both you and the Participant in line with the customer journey detailed in your tender. Where you are unable to obtain a Participant signature due to COVID-19, annotate the Action Plan with COVID-19. Email evidence (for audit) should be gathered and retained to demonstrate the individual’s participation on the programme. Make the information contained in the Action Plan available to the Participant at their request (by paper or electronically depending on their preference).

11. For WHP JETS ensure the Action Plan is reviewed, by both you and the Participant every 10 working days. The frequency of these meetings can be amended if the Participant prefers a different arrangement. Where you are unable to obtain a Participant signature due to COVID-19, annotate the Action Plan with COVID-19. Email evidence (for audit) should be gathered and retained to demonstrate the individual’s participation on the programme. Make the information contained in the Action Plan available to the Participant at their request (by paper or electronically depending on their preference).

12. For both WHP core and WHP JETS ensure all relevant information is included in your evidence of action planning in compliance with the Contract, including obtaining Participant signatures (where you have said you will do so in your tender). For the period of “COVID-19” where you are unable to obtain a Participant signature due to COVID-19, you should annotate the Action Plan with COVID-19. Email evidence (for audit) should be gathered and retained to demonstrate the individual’s participation on the programme.

13. For both WHP Core and WHP JETS, as COVID-19 restrictions ease and you move back to face-to-face delivery all ESF documents which require a participant’s signature should be signed and dated by the participant. If the signature box is annotated ‘COVID-19’ you should obtain a signature retrospectively when they are seen in person, and such form/s retained on file, for audit. This applies only to Participants on programme.

14. The Department recommends that you follow the relevant country specific Government guidelines below in relation to safety and only see those participants who request or agree to receive face to face support for all voluntary employment programmes. When you are delivering face to face, a wet signature must be obtained. The COVID-19 period easements are to be used only when you are not seeing the participant face to face due to restrictions imposed by government guidelines.

15. Evidence should be gathered and retained to show the Government guidelines you were adhering to which meant you could not offer face–to-face delivery at the time you supported the participant. This could be due to imposed lockdown restrictions, or the COVID-19 Secure guidance required under health and safety legislation

16. You must retain your evidence of action planning securely to support compliance checks by European Social Fund (ESF) compliance monitoring and for ESF audit activity (England only).

17. Where you have not been able to obtain signatures from Participants for any forms that require them, and the reason for that is not related to any Government Guidelines you were following at the time, you will need to clearly show that all reasonable attempts were made; date and evidence those attempts for your own audit trail and future inspection.

18. Further information regarding ESF requirements can be found in the COVID-19 Generic Provider Guidance Chapter 11b – ESF requirements 2014 – 2020 (England Only).

Consequences

• The 20-day completion of the Action Plan for WHP Core or 10 working days from Participant’s start date for WHP JETS, forms part of your revised CSSs for the COVID-19 period and will be checked during the DWP Compliance Monitoring process. Failure to meet these standards may result in your failing these checks

• Failure to adhere to your contractual requirements on action planning will result in not meeting the audit requirements of the European Social Fund and can potentially lead to the recovery of funds and other financial liabilities.

Detailed background and further information (WHP Core and WHP JETS)

Compliance checks (WHP Core and WHP JETS)

19. The compliance checks will review evidence of your action planning at regular intervals against what you agreed to deliver in your contract. Where the revised Customer Service Standards for the Covid-19 period state that your action planning will include specific criteria, such as agreed actions, target completion dates, frequency of reviews, Participant signatures, the compliance check will check that these steps have been followed to be assured of compliance with your contractual obligations. Further information regarding ESF requirements can be found in Generic Provider Guidance Chapter 11b – ESF requirements 2014 – 2020 (England Only).

Audit activity (WHP Core and WHP JETS)

20. The ESF Audit Authority may undertake annual or ad hoc checks on a sample of provider contracts to inspect that delivery complies with contractual obligations. They will check evidence to verify the eligibility of payments made in respect of a sample of individual Participants. The ESF audit may request the action plan and check the start date recorded against the date put on the ESF14-20 Initial form. Providers will fail the audit where this information doesn’t match.

21. Further information regarding ESF requirements can be found in Generic Provider Guidance Chapter 11b – ESF requirements 2014 – 2020 (England Only).

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