Guidance

Chapter 14: Validation

Updated 4 April 2024

Please note: Please follow the processes outlined for both WHP Core and WHP Pioneer. Elements that are exempt from this can be found in Chapter 2b WHP Pioneer eligibility and entry points.

Please note: Where WHP is referenced in this chapter this applies to pre and post extension.

ESF Requirement Changes

1. When referring to ESF Requirements within this chapter please note the following changes to ESF Requirements effective from 24 July 2023 (England)

• providers no longer need to submit or process ESF 14-20 Initial or ESF 14-20 End forms for Participants
• products can be updated to remove ESF logos. Changes to existing products and any new marketing and publicity materials should be sent to WHP.ENQUIRIES@DWP.GOV.UK for approval.
• providers should continue to use the current template for Good News Stories, until notified of amendment.
• participants you have already submitted ESF 14-20 Initial and ESF 14-20 End forms for over the lifetime of your WHP contract continue to be subject to ESF obligations. This includes Audit requirements and the ESF Document Retention Policy which at present is expected to be 2034.

In addition to the above, ESF requirements do not apply to participants started on or after 1 November 2022’

Please note: You are expected to continue to complete and to share Good News Stories with your Performance Manager as part of your contract with DWP.

General Information

2. 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 or Non-Qualifying Earnings) you must inform DWP to avoid incorrect performance being recorded. Further information can be found in Work and Health Programme including WHP Pioneer Provider Guidance Chapter 13 – Funding Model.

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

4. 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.

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

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

7. 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)

8. 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

9. 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, except for those gained by SCR Participants which you should report clerically (see paragraph 74 onwards for details).

10. Occasionally income milestones or earnings thresholds may have been achieved through the Participant having received Non-Qualifying Earnings as defined in your contract.

11. This income will not be counted towards an outcome. It could however result in the outcome line being claimed and the closure of the HMRC RTE line following payment of the final earnings threshold.

12. In these instances, as HMRC RTE earnings data will not be available, no further outcome information will be sent by DWP to evidence subsequent eligible employed outcomes. DWP will undertake for WHP an end of cohort reconciliation (ECR) exercise which will identify any eligible employed outcomes and DWP will notify relevant findings to each Provider, as applicable.

13. From June 2023, Providers will be paid on a quarterly basis in arrears based on a forecast of outcomes that each CPA would have achieved in that period. These ongoing forecast payments (along with the reconciliation payment) will then be reconciled and offset from the ongoing ECRs.

14. Please Note: It is only the WHP outcomes impacted by JETS that are part of the forecast payment.

15. For Self-Employed Outcomes you must report a qualifying outcome to DWP via PRaP (except in the circumstances outlined in Paragraph 10 and 11). Self-Employed validation will be a mix of automated and manual checks pre and or post payment. Currently (see para 9), WHP manual validation is primarily pre-payment. If applicable, the SCR claims process will also apply to self-employment validation.

16. If the Participant has received Non-Qualifying Earnings as defined in your contract whilst on the programme, resulting in the PRaP outcome lines being claimed, any subsequent Self-Employed Outcome must be submitted clerically using the PRaP 11 form.

17. 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.

18. If a Self-Employed Outcome is being claimed after PRaP lines have closed because of Non-Qualifying Earnings as defined in your contract, the Provider will submit the PRaP 11 form to DWP which will then prompt DWP to undertake the relevant checks outlined above.

19. 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.

20. For WHP 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.

21. For WHP DWP will recover any overpayment(s) including any associated with Cost Claims failing validation. This will be in accordance with the provision in your contract.

22. 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.

23. 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

24. 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 74 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.

25. Your outcomes will be based on the information contained within this - HMRC PAYE on-line earnings data. Further details can be found in Work and Health Programme including WHP Pioneer Provider Guidance Chapter 13 – Funding Model.

26. The Outcome achievement period runs for 639 calendar days for the Work and Health Programme from the Participant’s start date. Only earnings received within that period will count.

27. For WHP, 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 completes 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.

28. The earnings threshold may have been achieved through Non-Qualifying Earnings as defined in your contract. This income is not counted towards an employed outcome. It could however result in the closure of the PRaP line following payment of the final earnings threshold.

29. In these circumstances, DWP will notify you of any subsequent employed outcomes as part of the end of cohort reconciliation exercise.

30. If DWP has ended interest with HMRC as a result of Non-Qualifying Earnings as defined in your contract DWP will notify you of any subsequent employed outcomes as part of the management information reconciliation exercise undertaken at the end of the programme.

31. 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.

32. 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: Only one validated 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.

33. 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.

34. If the PRaP line has closed as a result of Non-Qualifying Earnings as defined in your contract, generating a report will not be possible.

35. The Employed Outcome and validation process is automated, once an Outcome has been achieved, or 639 days 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.

36. When an Employed Outcome has been achieved you must complete and return an ESF 14-20m End form if not already submitted. There is an exception to this when an Employed Outcome has been achieved as a result of Non-Qualifying Earnings as defined in your contract. For details on what to do in these circumstances please refer to Work and Health). Programme Chapter 11 Programme Completers Exits.

Cost Validation

37. 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 later.

Self Employed Outcome - Validation Process

38. 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.

39. If the PRaP line has closed as a result of Non-Qualifying Earnings as defined in your contract, then a PRaP 11 form must be submitted to DWP.

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

41. 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 Work and Health Programme, 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 56 for primary contact method and paragraph 4 for robust control system).

42. 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.

43. 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 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/earnings
• Invoices, purchase orders received/sent recently which are clearly in relation to the running of business

Note: this list is neither prescriptive nor exhaustive

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

45. 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 (see paragraph 56).
• The Participant’s contact details, where different from above
• Start date of self-employment
• End date of self-employment (where already known)

46. As it is not possible to fully automate Work and Health Programme (WHP) 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.

47. A Self-Employed Outcome for The Work and Health Programme 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 (made up of a maximum 456 calendar days on programme, and 182 days qualifying period). As part of making a successful claim for performance, the supplier will need to identify and must submit Self-Employed Outcome claims within 90 days of the Self-Employed outcome being achieved.

Please note: Where a self-employed outcome is achieved between day 601 and 639, at the end of the qualifying period, you still have up to day 700 to submit a claim in PRaP. If an outcome is achieved on the last day (day 639), the maximum time limit to claim is 61 days.

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

48. Where a Participant moves into self-employment 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.

49. If the PRaP line has closed as a result of Non-Qualifying Earnings as defined in your contract, DWP must be notified of the Providers wish to extend the Participants time on the programme no later than day 456 via a clerical form.

50. 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.

51. 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.

52. 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 paragraph 4, paragraph 5, paragraph 41, paragraph 45 and paragraph 56). 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 failure 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 64.

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

54. 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.

55. 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 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 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 paragraph 4, paragraph 5, paragraph 41, paragraph 45 and paragraph 56 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 paragraph 4, Paragraph 5, paragraph 52, paragraph 53 and paragraph 61), 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 or submitted clerically. 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.

56. 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 unable to make 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.

57. 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.

58. Validation processes may differ dependent on whether the Participant is in receipt of UC or not.

59. 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

60. For UC claimants DWP will be checking that during a cumulative period of 182 calendar days or more for The Work and Health Programme:

• 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 of trading; or
• a combination of the above, that is: 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.

61. 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.

62. 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.

63. 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

64. 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.

65. 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 (pre and post extension)

66. The UTV claims will then be apportioned, paragraph 64 refers.

67. 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.

68. The reconciliation will consider 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

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

70. 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.

Management Checking

71. 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.

72. 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.

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

Special Customer Records – clerical claim process

74. Most 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 for example: 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.

75. Where you have a SCR claim, you are required to print off the PRaP11 form and complete manually.

76. 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.

77. 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.

78. 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.

79. 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.

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

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

81. 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