INSIDE: TITLE • TITLE • TITLE • TITLE • TITLEINSIDE: BENEFITS BAROMETER • OPINION • BEST PRACTICE • NISBET’S NOTES

APRIL 2019 www.irrv.net

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Look backin anger?

The bi-monthly journal of the IRRV’s Benefits Advisory Service

BENEFIT

The Institute of Fiscal Studies reports on lessons from six years of localised council tax support

Your IRRV Council: Editor’s welcomeContentsFeatures

SENIOR VICE PRESIDENTAndrew HethertonMRICS IRRV (Hons)

IRRVPRESIDENTLouise FreethFIRRV

Allan ClarkMSc FIRRV MCMI

Richard HarbordMPhil CPFA FCCA IRRV (Hons) FIDP FBIM FRSA

Carla- Maria HeathBA IRRV (Hons)

Zoe Kent IRRV (Hons)

Paul McDermottIRRV (Hons)

Jim McCaffertyIRRV (Hons)

Nick RoweIRRV (Hons)

Ian FergusonIRRV (Hons)

Simon Green MRICS IRRV (Hons)

Alan BronteFRICSIRRV (Hons)

Roger MessengerBSc (Est Man) FRICS FIRRV MCIArb REV

Kevin StewartFIRRV MAAT MCMI

Bob TrahernIRRV (Hons)

David ChapmanIRRV (Hons)

JUNIOR VICE PRESIDENTAlistair TownsendIRRV (Hons) MCMI

IMMEDIATE PAST PRESIDENTGordon HeathBSc IRRV (Hons)

HONORARY TREASURERAllan TraynorFCCA IRRV (Hons)

©IRRV 2019. Reproduction in whole or in part of any article is prohibited without prior written consent. The views expressed in this magazine do not necessarily represent the views of theInstitute. Whilst all due care is taken regarding the accuracy of information, no responsibility can be accepted for errors. Any advice given does not constitute a legal opinion.

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April 2019 ISSN 1361-1305

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32 Follow us on Twitter David Magor on Twitter Gary Watson on Twitter Follow us on Facebook Presidents Blogwww.irrv.net • Forums • Conferences • Training Days • News • Online Training • Qualifications • Membership • Jobs • Council • Tel 0207 831 3505

John Roberts IRRV (Hons)is Managing Editor of the Institute’s magazines

As ever, we aim to bring you the very latest on the welfare reform agenda, together with informed comment from our team of expert commentators.Before moving on to the content of this edition, I’d like to use the opportunity to remind readers of the need to submit their bids for the 2019 Performance Awards before the closing date of 31st May 2019. Once again, the award winners will be announced at the gala dinner and ceremony, which as ever provides the pinnacle for our Annual Conference, scheduled for Telford International Centre this October. And let’s not forget that tired and well-used – but ever relevant – cliché, “You’ve got to be in it to win it!” Check out www.irrv.net/awards and prepare your bid now, if you haven’t already done so.

Best practice is always one of our priorities in the Institute’s magazines, and on this occasion we are pleased to focus on the Department for Work and Pensions’ Performance Development Team and the work our colleagues within the team carry out to enhance local authority benefits performance.

Our regular contributors are there, of course, as they cover a range of key topics, from the intricacies of the legislation, the plight of the claimant experiencing poverty, the skills required to develop and maintain an effective workforce, through to the wise words of our resident benefits managers.

Benefit always prides itself on a ‘no holds barred’ approach when it comes to opinion on the state of play in welfare reform, too, and this edition is no exception, as Malcolm Gardner, Ian Nisbet and Mark Underwood speak their minds. The best way to find out what else is in there is to read on and enjoy!

“ Welcome to the April edition of the Institute’s Benefits Advisory Service magazine, Benefit.”

Chief Executive’s notes 04

Book review 04

Nisbet’s notes 05There’s no immediate sign of a change in the landscape for hard-pressed benefit claimants, says Ian Nisbet

Gardner’s world 06

Best practice 09

Benefits uncovered 10

Benefits barometer 12Our ‘fly on the wall’ observer puts ‘Managed migration’ under the microscope

Fimister’s focus 20A little R-E-S-P-E-C-T – that’s what claimants need to see, says Geoff Fimister

Training & development 22

Practitioner’s view 24

Management 27Leadership these days should be about challenging questionable policies and decisions, says Sean Langley

• the in-depth comments of Malcolm Gardner are always worth a careful look

• fighting fraud is the priority of the team from Intec

• more ‘fly on the wall’ observations from our anonymous ‘Benefits barometer’.

What’s in the next issue...

Look back in anger?The Institute of Fiscal Studies reports on lessons from six years of localised council tax support

Cover story 14

Opinion“Wholesale and wide ranging welfare reform is needed”, declares Mark Underwood, while Juan Alvarez-Vilanova suggests five ways councils can get ahead with those looming reforms

Feature 17

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This was an interesting book to read. I was asked to read it by a friend who was quite excited about it. I could see why. The book centres on the idea of ‘organisational health’ and the argument that health is better than wealth. Least ways a healthy organisation will perform better and thus make more money. That is an idea that we all could agree with. The crux of the book is how you improve your organisation’s (mental) health.

I really wanted to like this book, but unfortunately, I found it somewhat disagreeable. That is not to say that there are not some good propositions in it but I simply did not like the style of the book or the writing of the author!

There was a lot of ‘nudge’ in it. Not telling you how to nudge but nudging you to agree with the author and think that there were some wonderful revelations in the book. There are some useful templates and methods of workshopping with staff to create some bonding and disciplines. But you could find similar in better written books. I just could not find much that was new and the overall logic of the book was dictated by the author through anecdotes (which may or may not be true) and creating logic out of his own assumptions and opinions.

You might argue that is true of many management instruction books – and that would be true. Lencioni does collect up some useful stuff in one volume. But you would be better off stripping out the stories and the assumptions and just picking out some of the procedural ideas. It is not the worst book I have ever read on management but Lencioni is no Tom Peters, F W Taylor, Elton Mayo or Elizabeth Kanter.

As an alternative, I re-recommend a couple of books I have reviewed here in the past.

‘The Manager’s Book of Checklists: Everything you need to know, when you need to know it’ by Derek Rowntree and published by Pearson Prentice Hall ( ISBN 0-273-70702-9) and...

‘Strategy Safari: Your Complete Guide Through the Wilds of Strategic Management’ by Mintzberg, Ahlstrand and Lampel, published by FT Prentice Hall ( ISBN 978-0-273-71958-8).

www.irrv.net • Forums • Conferences • Training Days • News • Online Training • Qualifications • Membership • Jobs • Council • Tel 0207 831 3505

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As we move into another financial year, local authorities will have found it difficult to maintain the level of assistance they have been giving through the council tax reduction scheme.

Over the last few years we have seen the award of this benefit to the working age community gradually reduced. As a consequence of these decisions there has been a growth in council tax arrears for those least able to cope with the ever increasing burden. The policy of a large number of local authorities is to continually reduce the level of the awards to a point where they will be virtually worthless.

This situation has been reported on a regular basis, with the Institute of Fiscal Studies being the latest organisation to publicise the plight of the working age claimant. When local authorities consider a change in their scheme they should carry out a full impact assessment. The need for this important step in the review of any scheme has been recognised by the courts. It is essential that local authorities ensure the decision making is supported by an appropriate test of fairness. This test of fairness must be built upon an evidence based test which enables the local authority’s decision to be balanced and equitable.

There is no doubt that the failure to revalue council tax bands and the continuing approach to the ratio between the lowest band and the highest sustain the regressive pattern which impacts on all council tax payers. Even though the operation of the scheme has been subject to a departmental review, there is no doubt in my mind that not enough is being done to establish true fairness in the delivery of this key benefit. It is essential that this shortcoming is recognised by government and rectified as soon as possible.

The level of council tax reduction for those of working age is an important part of the overall scheme. It needs to be reviewed. There should be a better balance to the value of the schemes, with a more effective mechanism to determine the quality of any decision making associated with them. The current process is hopelessly inadequate and vulnerable to challenge.

The Advantage: Why Organizational Health Trumps Everything Else in Business by Patrick M. Lencioni, Published by John Wiley & Sons (ISBN-13: 978-0470941522)

Since becoming the new Works and Pensions Secretary, Amber Rudd has tried to defuse some of the criticism of Universal Credit (UC) by accepting there are problems with the scheme, adopting a pragmatic approach in implementing some changes and delaying the rollout. She has confirmed that the full implementation date is still 2023 but her approach suggests that they are prepared for further delays. In most cases, however, it is simply delaying rather than eliminating the problems with UC.

Cynics may suggest that it is the ‘kick the can down the road’ approach often adopted by governments when faced with a difficult problem. Whilst the delay to the rollout is to be welcomed, it is important to remember that it has been estimated that around two million people will move onto UC this year anyway, via a new claim or a change in circumstances that changes the benefits they need.

One of the key reasons UC is causing problems for households is because it is being introduced in a less generous welfare age. The benefits freeze is perpetuated under UC, as is the Bedroom Tax, Employment Support Allowance (ESA) cut and Housing Benefit cap. On top of that, UC now has the two-child benefits limit, and vanishing disability premiums. This is all with tougher sanctions and work capability assessments for disability benefits, as the Conservatives introduced measures to reflect their attitude to welfare since 2010. Unless the social security landscape changes, UC will continue to create problems for its users.

Whilst Amber Rudd was announcing her changes to UC, the Office for Budget Responsibility (OBR) said predictions by the Department for Work and Pensions dramatically underestimated the costs of rolling out the Personal Independent Payments (PIP) system, which began to replace Disability Living Allowance (DLA) in 2013. A saving was estimated by 2018, but that has since been

revised to an overspend by £1.5 billion, leaving an estimated £4.2 billion gap in the public finances.

The OBR said the growing number of appeals was one of several causes of the unexpected rise in costs. The OBR also said the system had come under pressure from legal challenges, which had altered the scope of the scheme, and an increase in claimants, especially of working age adults when this group was due to see a fall.

The Institute of Fiscal Studies ( IFS) has produced a report looking at the impacts of localised council tax support schemes (CTS). They found that CTS remains a significant part of the means-tested system. Across Great Britain, it was paid to 4.9 million households in 2017/18 – more than any other means-tested payment. Spending on the 2.4 million working-age claimants in England (the entitlements that can now vary between LAs) came to £1.8 billion, implying an average award for those claimants of £770 per year. The report looks at how LAs’ CTS schemes have evolved since they were first introduced and at the changing effects of these scheme choices on claimants and on LAs.

Many LAs have mirrored cuts to national benefits in their CTS schemes, such as the benefits freeze, two-child limit, and abolition of family premium. 90% of LAs have made other changes as well, with 79% in 2018/19 having a minimum payment. There have been various smaller changes including:• increasing the taper rate• reducing the asset limit• capping entitlement at a particular

council tax band.

When CTS started in 2013/14, the government gave a one-off grant if LAs introduced a minimum payment of 8.5% or less. In 2013/14, 100 LAs took up the offer by introducing a minimum payment at exactly 8.5%. In 2018/19,

NISBET’S NOTES

Ian Nisbet is Subsidy and Overpayments Officer with Agilisys’s Enhanced Revenue Collection programme. Contact him on ian.nisbet@lbhf.gov.uk

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It’s high time we had a radical review!

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CHIEF EXECUTIVE’S NOTES BOOK REVIEW

Government is just delaying the problems

“ Whilst the delay to the rollout is to be welcomed, it is important to remember that is has been estimated that around two million people will move onto UC this year anyway, via a new claim or a change in circumstances that changes the benefits they need.”

five years after the incentive expired, 38 LAs still have a minimum payment of 8.5%.

Entitlement for the 3.6 million eligible working-age households in England has been cut by 24%. On average, this loss amounts to £196 per year or 1% of income. 1.4 million low-income households are now liable to council tax who would not have been. The impact has been that poor households are more likely to lose if they live in poor areas but they are likely to lose less. Only 500,000 households, who had their bills covered by Council Tax Benefit, still have them met in full by CTS. In 2018/19, 63% must pay more than £100, a third must pay more than £200 and almost one in ten must pay more than £300.

Introducing a minimum payment has led to a significant increase in the number of people contacting Citizens Advice in respect of council tax or CTS. The IFS report estimates that about a quarter of the additional council tax liability arising from the cuts to CTS is not collected in the year it is due. This is around ten times higher than the 2.5% of council tax that councils failed to collect, on average, prior to the cuts.

by Malcolm Gardner

David Magor OBE IRRV (Hons) is Chief Executive of the Institute

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In my last article, I promised that I would discuss innovation. It is an important part of delivering a service and running a department or an organisation. It is a word that crops up in the IRRV awards village. It trips off the tongues of salesmen and politicians and features in the bids of contractors who want to run your services. ‘Innovation’ is often over-used and under-delivered. The promise of ‘we will bring an innovative approach to the delivery of your benefits system ’ is sexier than ‘we will process your claims on time and accurately’. The latter being a measurable promise of intent, whereas the former is a vague statement meaning almost nothing other than the performance of the delivery team will be different, i.e. it will cost more and the quality will possibly be average!

Innovation is a business process. It is easy to present anything as innovative, especially if the objective is to simply bamboozle the listener. The lack of newness of an idea, product, use or approach can easily be hidden if the customer has no knowledge of the underlying technology, or is not a subject matter expert.

For example, ‘nudge’ was sold to the masses in 2010 as an innovative idea of using economic behavioural science in public policy. When the coalition government arrived in Downing Street, they could be seen clutching their copies of the book. ‘Nudge’ won awards and was a bestselling book. But it was at best pop-science and while many were nudged into believing that it was all new and innovative, it was anything of the sort. It was behavioural psychology (which has been around since the 1800s) dressed down for the 21st century. It was the audacity of the 1950s advertising Mad Men but without the style. Plus Burrhus Skinner and others had already introduced the concept into social policy in the 1960s. ‘Nudge’ was not innovative, but it did bring the ‘nudge’ into common usage and was easier to understand than behavioural psychology.

Let me be straight, Universal Credit (UC) is not innovation either – there is nothing new or original about UC. It is a collection of old thinking repackaged. It fails to tick the innovation boxes on many fronts. It’s not even using previous ideas or old technology in a new and exciting way. However, as much as I would hate to say it, there is an argument that the other welfare reforms could be thought of as innovative. The way in which past decisions could affect current or future entitlement was new and different. The capping of welfare based on a concept as vague as a bedroom was new and different. The belief that sick people could be raised from their beds and made to work was new and different, if you did not take into account that it had been done in myth and fiction.

Innovation, in its purer sense (rather than repackaging sense) is an important part of growing and developing. When budgets are cut to the bone, resources are stripped and demand is increasing, then as Aristotle said, ‘necessity is the mother of invention’.

Innovation is not simply having a good idea – it is having a practical idea that can be implemented and can achieve results. To make best use of innovation you must not rush headlong into turning the idea into reality. An innovation project that fails can cost a lot of money, not just in the cost of development but in reputational damage and the implications on the customer if the impacts are intentionally

disruptive. Consider both UC and the new rail timetable fiasco of 2018.

There is a debate about how many innovation projects fail. The best and most experienced companies seem to be successful around 65% of the time. In government the success rate is closer to 10%. In part, this is because time is a factor. Either projects and ideas are rushed into production and the areas of failure are not identified or ignored and things go to pot, or they take too long to be properly developed. The five-year cycle of a government has much to do with this. When the coalition government came into office, they started a larger programme of reforms than any government before it, including planned reforms of the civil service, the House of Lords, justice, prison services, police,

education, health and of course welfare. Of those reforms, only UC and HS2 are still being implemented. Most of the others have fallen by the wayside or have been ditched because ministers change too frequently and are not as keen on the project as their predecessors.

Labour’s reforms of the courts and NHS records, to name just two, fared no better. Tax credits had a rocky ride and remained criticised until UC sailed onto the horizon. PIP was introduced but was bust before even going live. Tell-us-once arrived as a smaller and less ambitious product. While work assessment and sanctioning are ugly, angry and unloved babies that no-one wants but seem to be

lumbered with. I will not even mention how well the Brexit thing has gone (though at the time of writing we still have about 30 odd days to go, so perhaps by the time of reading this we will have arrived either onto the sunny uplands of the Brexiteer’s New England or tumbled into the Leavers’ ravine of fear and loathing. Or perhaps we all remain trapped on an endless ride of the £350m Boris Bus of Brexit !

My point is the exact number of failures doesn’t matter – it’s just that it is difficult and risky to take innovation from concept all the way through to success. So, it is worth thinking about the factors that influence success.

The first thing is you could be solving a problem that doesn’t exist. Studies dating back to the early 1970s tell us what separatessuccessful from unsuccessful innovationprojects. One defining feature of projects that fail is that the innovation was to rectify a problem that was thought to be there but wasn’t. For example, the idea that work is the only way out of poverty is based on the theory that most households on benefit weren’t in – and would not – work. The acceptance of this premise by MPs and the public alike was not based on empirical evidence but on the feeling that this was true. Allowing excitement clouds judgement and uses ‘nudge’ to get the general public to accept the theory as truth.

Getting excited about a project is common and it is a double-edged sword. You need excitement to get buy-in from those who need to invest in the idea and that same excitement then blinkers everyone from the project’s failure. Here is definitely the story of the early days of UC. The project was pushed through the pain barrier based on the enthusiasm for it. You can see similar things coming out of Council Tax changes. The enthusiasm for banded schemes is blinding some to its shortfalls. So, why the excitement? It is human nature! As innovators we become excited by the idea itself. The buzz of creativity and the satisfaction of solving all

those problems to create a product that works. We become so committed to the idea that we forget to ask all those niggling questions, like ‘what does this enable the customer or citizen or member of staff to do that they couldn’t do before?’, ‘how much do they care?’, and crucially, ‘how much are we willing to pay for the innovation?’ The end user perspective is critical. As a business analyst, it is my job to understand what is required. Talking to end users to find out what their pain points are and asking how they can be helped is a necessary part of the development of innovation. However, often the innovator is too keen to tell the users what they wantand won’t listen to what they need.

Next time, I will look at Team Netsol’s innovation programme and why they adopted the Adobe Red-Box and why local councils don’t have time for, or trust of, real innovation.

Malcolm Gardner is a Director of the Welfare Reform Club Ltd and Senior Business Analyst for Team Netsol Ltd. Contact him on 07946 800171 or malcolmgardner@reformclub.org.uk

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Innovation is an essentialpart of developing a service,of course, but is it always necessary or effective?

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GARDNER’S WORLD

“ The project was pushed through the pain barrier based on the enthusiasm for it. You can see similar things coming out of Council Tax changes. The enthusiasm for banded schemes is blinding some to its shortfalls.”

The motherof invention

“ The capping of welfare based on a concept as vague as a bedroom was new and different. The belief that sick people could be raised from their beds and made to work was new and different, if you did not take into account that it had been done in myth and fiction.”

IRRVPerformanceAwards 2019

Entries must be received by

31st May 2019For more information visit:

www.irrv.net

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Why should I waste my time getting to know you?What can I get out of knowing you?I don’t have time to get to know you.

I’m sure most, if not all of you, reading this article may have felt like this at some point in your job! Especially when you are very busy and frequently need to work with many different people to achieve your goals.

Well, let me tell you a short story about my relationships...I have been working as a Senior Management Consultant for the DWP’s Housing Delivery Division’s Performance Development Team (PDT) for several years now and have been in the civil service for over two decades.

Prior to joining the PDT as a consultant, I had always enjoyed working across different Departmental teams, as well as at times across government. However, internal engagements are not always a true litmus test for how successful a Department is in building great working relationships with external stakeholders.

It wasn’t until I joined PDT that I really grasped the importance of working with external stakeholders, such as the 380 Local Authorities (LAs) across the UK. Discovering the importance of building strong relationships with LA colleagues, which I call the ‘Critical Engagement’ stage, helps me to provide the best advice and consultancy support to my LA partners.

Over the years in the PDT I have had the privilege of working in close partnership with many LAs, delivering a wide range of support (from overpayment recovery, Speed of Processing (SoP), subsidy, Universal Credit, to mention a few).

However, building strong relationships with stakeholders (LAs) isn’t just about us achieving a good outcome for our own work and thereby meeting DWP expectations.

It is just as much about learning from our stakeholders and obtaining information that we would not otherwise be aware of and which could negatively influence policy decision making or operational delivery. It also offers the opportunity to have a much clearer understanding of the impact of DWP decisions on LAs’ resources and service delivery.

DialogueAs a consultant I am all too familiar withthe importance of ‘dialogue’ as this is for me probably the most important part in building any relationship. Having an open and honest dialogue from the outset paves the way forclear understandings and trust.

It is only due to strong collaborative working between DWP and LAs that DWP has been able to take into account views and suggestions when developing and reviewing initiatives such as the Fraud and Error Reduction Scheme (FERIS).

Findings from the lessons learnt from previous initiatives allows DWP to continually stay abreast of changing trends and challenges faced by LAs. It is through the continuous process of effective engagement and dialogue that DWP aims to learn from previous initiatives and take this into account when developing new approaches or interventions, such as the Right Benefit Initiative (RBI ) or Verify Earnings and Pensions Alerts service (VEPS).

And it is with coming together in unison that we can make a real difference to those that really matter – the customer.

ExpectationsIt has always been important that in any work I undertake with an LA that I have a good understanding of the challenges and what is expected of me. Likewise, I leave the LA under no misapprehension on what I can deliver and what I expect in return.

By having this clear understanding right at

the start I feel I have been able to build strong relationships, many of which continue to this day.

TrustLike expectations, trust is something I have always believed is crucial to a good relationship.

It is with trust that I can gain the respect of any LA partner or other stakeholder, securing their agreement and participation in working together and ultimately, achieving our common goals.

I’m not saying that working in partnership is easy and straightforward, as each relationship brings its own challenges and issues. Showing empathy, understanding, communicating with clarity, being open and honest and treating each individual engagement as a unique relationship helps break down barriers and builds trust.

It is through continually building my own competence, expertise and knowledge that I am able to build trust, develop relationships and work with LAs to identify and implement recommendations that improve the service on offer. Ultimately, leading to the delivery of successful outcomes, helping my stakeholders achieve greater performance and providing a better pathway to future working.

So, why not get in touch with a consultant from PDT and see how you can build a brighter future through good working relationships?

The PDT is always looking at opportunities to continuously build better relationships. If you’ve any feedback, or if your LA would be interested in working with PDT, please contact Rod Bennett for more information at hdd.pdtconsultants@dwp.gsi.gov.uk

Amjad Ramzan LLB Hons is a Senior Management Consultant with the Department for Work and Pensions’ Housing Delivery Division

BEST PRACTICE

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Building great relationships is foremost in any collaboration between local authorities and the DWP

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Building brighter futures through good working relationships

REVENUES AND ENFORCEMENT STREAM

TUESDAY 14 MAY

• The Future Of Local Government Finance Richard Harbord, IRRV Past President• Modernising The Rating System Before It Is Too Late!! Andrew Hetherton, Senior Vice President IRRV• Avoiding Rates Avoidance – Can We Learn From The Welsh

Assembly? Matthew Evans, Head of Revenues, Wrexham County BC

• Breathing Space (Or Suffocation!!) And The Impact On Council Tax

Alistair Townsend, Junior Vice President, IRRV• Is Replacing Committal For Council Tax A Viable Option? Nick Rowe, Assitant Director of Finance – Local Tax and

Accounts Receivable, Ealing LBC• Enforcement At The Crossroads – Panel Session - Is Ethical Enforcement a Reality or Myth? Dave Chapman, Managing Director, Rossendales - Is There A Problem With Taking Control Of Goods? Sarah Naylor, Business Development Manager-Dukes - Is There A Need For An Enforcement Regulator? Paul Sharpe, Client Services Director, Newlyn

WEDNESDAY 15 MAY

• Analysing The Potential Impact Of Revaluing And Reforming Council Tax

TBC• Developing The Relationship Between Local Authorities And

The Valuation Office Agency Helen Evans, Head of Strategic External Engagement), VOA Helen Charlesworth, Team Leader, Local Authority

Engagement Team, VOA• The Role Of Insolvency In Reforming Debt Collection Jonathan Woodward, Head of Revenues Birmingham CC• The Future Of Rate Retention Mike Heiser, Local Government Association• Using Big Data To Identify The Vulnerable TBC• Setting Standards For Business Rates Administration Simon Quilter, Head of Revenues, Broadland District Council

WELFARE BENEFITS STREAM

TUESDAY 14 MAY

• Has Parliamentary Scrutiny Of Welfare Reform Been Adequate?

TBC• Housing Benefit And Older People – What Does The Future

Hold? TBC• Universal Credit – Theory Fine, Practice A Disaster? Ed Bowen, Head of Benefits Chiltern District Council• The Delivery Of Housing Benefit – The Latest From The DWP Clare Elliott, Head of Housing Policy, DWP• Citizens Advice And Welfare Reform – Can They Cope? TBC• A New Approach To Recovering Overpayments John Giblin and Alan Sullivan, Formerly Principles DWP• Housing Benefit Subsidy – Maximising Income And

Minimising Risk Zoe Kent, Head of Benefits, Swale District Council

WEDNESDAY 15 MAY

• A New Approach To CTR Sheldon Woods, Head of Benefits, CIPFA• Supported Housing Catherine Nicholson, Managing Director, Fortunatus Housing• The Case For Removing The Housing Element From

Universal Credit Kevin Stewart, Chair of the IRRV Benefit and Welfare Reform

Faculty• Income And Assets Of The Self Employed And Welfare

Reform Michelle Kettles, Benefits Manager, South Staffordshire

District Council• Innovated Delivery of Housing Benefit to reduce

Homelessness TBC

Special Offers, fees and online booking can be found at www.irrv.net/springconference

IRRV ConferencesMembers can book 3 places for the price of 2*

E: conference@irrv.org.uk T: 020 7691 8987W: www.irrv.net/springconference

IRRV Spring Conference and Exhibition 201914 & 15 May, The Queens Hotel, LeedsDue to the success of our 2018 event, the Institute will be returning to The Queen’s Hotel, Leeds on the 14th and 15th May 2019. This event brings together the Welfare Benefits and Revenues & Enforcement Conferences that have taken place at different venues and at different times in previous years. The conference will as always be supported by an exhibition.

There are to be two separate streams running throughout the conference; one focussing on Welfare Benefits and the other on Revenues and Enforcement. Delegates attending the event will not be confined to attending sessions on any one stream. They will have the flexibility to ‘pick and choose’ which sessions to attend. The Queens is the most famous landmark hotel in Leeds. Situated in City Square, it is close by to restaurants, bars and shops and easily accessible by both car and train. It has its own entrance linked to Leeds train station. The main hotel car park, of which there are 80 spaces, is located below the hotel.This year’s sessions will be covering the following topics:

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In my last article, I considered part of Regulation 9, specifically 9 (1)(h), relating to where Housing Benefit (HB) is prohibited for those who previously owned their own home. Of course, Regulation 9 has numerous sub-sections which prohibit HB being paid and this time I’d like to take a look at 9 (1)(d) in light of a decision, CSH/89/2018, made on 4th December 2018.

This part of Regulation 9 excludes from entitlement a claimant where ‘he is responsible, or his partner is responsible, for a child of the person to whom he is liable under the agreement.’ The facts of this particular case may be summarised as follows: • the claimant was married to his ex-wife in

May 1997 and divorced in April 2009 • he is father of two children aged 14 and 16.

‘JC’ is their mother • the children live for one week with the

claimant and one week with their mother, under an arrangement which has been in place for some time and is felt to work well. The claimant receives child benefit for them

• the claimant rents from JC and her new husband ‘AM’, who have a buy-to-let mortgage in place and rent the property under a short assured tenancy agreement

• the rental value was agreed upon following a formal valuation by a surveyor and the rental agreement drawn up by a solicitor

• the local authority was provided with emails chasing up arrears of rent and suggesting that if the account was not brought up to date then a notice to quit would be served.

There wouldn’t seem to be anything out of the ordinary about this arrangement and it appears to create a genuine liability for rent. However, that does not necessarily mean that HB is able to be paid. Indeed, taking into account Regulation 9(1)(d), the local authority reached the decision that HB could not be paid as the claimant was responsible for the landlord’s child. Rather strangely, the First Tier Tribunal

came to a different conclusion and allowed the claimant’s appeal on the basis that the tenancy should be treated as one on a commercial basis.

The IRRV’s examiner would not be pleased with such a muddling of the various parts of Regulation 9! His long-held concern has been that when asking an examination question on either contrived or non-commercial, students take the opportunity to simply brain dump everything they know about Regulation 9 rather than being able to distinguish one part from another.

The local authority appealed on the basis that they had not sought to reply on 9 (1)(a) at all and were not involving the issue of non-commerciality. Why would they, when that part of the regulation is so much more difficult to prove one way or the other? At the Upper Tier Tribunal, Judge Poole determined that the tribunal had erred in law because it acted in breach of natural justice and did not consider the material matter before it. He concluded that Regulation 9 (1)(d) is not limited to sole landlord situations but also covers situations in which there are joint landlords, only one of whom is the parent of the tenant’s child.

For his part, the claimant advanced two main arguments as to why he should be entitled to receive HB: • it is unconstitutional, unfair and inequitable

for people not to be able to get HB in these types of situation because they are obliged to pay rent; and

• the property is not in the ownership only of his ex-wife, but her and her husband.

I have a degree of sympathy with the first point. However, there is often very little within HB that seems fair and equitable.

As Judge Poole highlighted, there was in fact a challenge to the lawfulness of this subsection in the Court of Appeal in Tucker v Secretary of State for Social Security [2001] EWCA Civ 1646; [2002] HLR 27.

The outcome was that the lawfulness of Regulation 9 (1) (d) was upheld. Tucker gives useful background for those applying Regulation 9 (1) (d).

Regulation 9 (1) (d) is an anti-avoidance provision. It was enacted because of concerns about public funds being used for HB where the absent parent or landlord had obligations to their children in any event. It was a deliberate change to the earlier law. The Court of Appeal found that the provision is not irrational because it is founded on the rational belief that, where the tenant is the parent and carer of his landlord’s child, the landlord will generally not view the landlord and tenant relationship in the same commercial way that he would otherwise view it. Although this may result in some genuine applicants being denied HB, a person should be aware that, if he needed HB in order to pay the rent, he should take a tenancy from someone other than the parent of his child. The underlying mischief being addressed seems to be the state funding accommodation after relationships break down, when the effect is the state paying (through HB funding rent) one of the former partners who in any event has obligations towards their children.

In more detail, at paragraph 33 the court said, ‘So one can ask rhetorically what is unjust about the system under which a parent of a child appreciates that if they are to obtain housing benefit there is one person, i.e. the other parent of the child who cannot be the landlord. Forgetting for the moment the separate argument available to this particular appellant that she has ordered her affairs on the basis of so renting and receiving housing benefit, once the regulations as amended came into force a person such as the appellant

simply knew that if they needed housing benefit in order to pay the rent, then the tenancy had to be with someone other than the parent of the child, and that does not, as I would see it, impose serious hardship.’’

That assumes of course that the potential HB claimant is fully conversant with all aspects of the HB regulations!

At paragraph 42, the court also rejected a challenge based on Articles 8 and 14 of the European Convention on Human Rights, stating that the provision ‘pursues a legitimate aim and any differential treatment bears a reasonable relationship of proportionality to the aim sought to be achieved, viz the eradication of abuse.’

Considering the second part of the claimant’s argument, i.e. whether it makes a difference that the absent parent is only one of the landlords, the Judge pointed out that the wording of the regulation refers to ‘the person’ and not ‘a person’. In his opinion, the underlying ‘mischief’ the regulations seek to address, is the public purse funding family

arrangements where the landlord as parent has a responsibility to accommodate the children and it should not therefore matter whether the landlord is one parent or that parent plus a partner. The First Tier Tribunal decision was therefore set aside and Judge Poole re-made it, confirming that there was no entitlement to HB.

This case may show, as the law acknowledged, that Regulation 9 may see genuine claimants disadvantaged. It is certainly the case that HB would be considered

on another property, which may in fact end up costing the public purse more but each aspect of Regulation 9 must be carefully examined and applied.

Louise Freeth is President of the IRRV and Head of Revenues and Benefits at the Royal Borough of Windsor and Maidenhead. Contact her on louise.freeth@rbwm.gov.uk

The opinions expressed are those of the author.

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The intricacies and manyaspects of Regulation 9require close examination

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“ There wouldn’t seem to be anything out of the ordinary about this arrangement and it appears to create a genuine liability for rent. However, that does not necessarily mean that HB is able to be paid.”

“ It was enacted because of concerns about public funds being used for HB where the absent parent or landlord had obligations to their children in any event. It was a deliberate change to the earlier law.”

Regulation 9 –distinguishing onepart from another!

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The Parliament’s Work and Pensions Committee (the Committee) published its Twentieth Report of Session 2017–19, ‘Managed Migration’ on 22nd November 2018. The government response to this report was published on 14th January 2019 and Benefits Barometer is on the case this edition to report back. A lot has been said about the process, but it bears more analysis, I feel.

In the report, the government is pleased to note the Committee’s acknowledgement that DWP has ‘listened to’ and ‘acted on’ concerns following the Social Security Advisory Committee’s (SSAC) consultation and that draft Universal Credit (Managed Migration) Regulations 2018 laid on 5th November 2018 are a ‘significant improvement on the government’s original proposals’. The government acknowledges SSAC’s support of the 2018 Budget announcement, particularly that it will extend run-on payments to income related JSA and ESA. For clarification, run-on payments are also extended to Income Support. The government also agrees with SSAC that it is impossible to overstate the importance of getting managed migration right both for claimants and the success of Universal Credit (UC) itself.

Here’s a reminder of the 11 recommendations, with summaries and comment on the government’s response.

Recommendation 1We recommend that the government should not ask the House to vote on the Regulations until the Social Security Advisory Committee has been able to report on them.

The government does not accept this recommendation, as draft regulations have already been subject to extensive scrutiny by various bodies including SSAC. SSAC considered the draft Universal Credit (Managed Migration) Regulations 2018 and conducted a

public consultation, receiving 455 responses. SSAC’s report and the government response was laid before Parliament alongside draft regulations on 5th November 2018. The government welcomed SSAC’s advice and accepted, in whole or in part, all but one of its recommendations.

In effect, this means that government is legislating for ‘piloting powers’, rather than for the whole managed migration period. This is in line with a recommendation of the Secondary Legislation Scrutiny Committee in its letter of 12th December 2018 to the Secretary of State.

Recommendation 2We recommend that the government continue its preparations for managed migration while the Social Security Advisory Committee carries out its work.

The government accepts this recommendation in part, agreeing that it should continue preparations for managed migration. The DWP is continuing its engagement with SSAC and other external stakeholders.

Recommendation 3We recommend that the government accept the recommendation of the Social Security Advisory Committee to conduct a segmented analysis of the claimant groups who will be subject to ‘managed migration’, with a view to identifying circumstances in which it does not need to require people to make a new claim. This analysis should be published.

The government agrees to explore options on this point as set out in its response to SSAC’s recommendations. There are a number of reasons why the DWP will not be transferring claimants to UC automatically, but they

acknowledge that it is right that detail of the design of managed migration is flexible, so that the process can adapt to ensure that it works for everyone.

Recommendation 4We recommend that the Department extends run-ons to all legacy benefits that UC replaces. We further recommend that the government publish a set of worked examples showing how claimants in different scenarios will be affected by its changes to the run-ons. This should include, but need not be limited to: single claimants with and without disabilities and in and out of work; and couples, especially where they are receiving different benefits (for example, where one is receiving ESA and the other JSA) or have different employment statuses.

The government accepts this recommendation in part. Claimants in receipt of Housing Benefit are already entitled to a two-week run-on of the benefit when they transfer to UC.

Recommendation 5We recommend that the Department must not proceed with migration on a large scale until it knows in practice whether run-ons deliver the support that claimants need. We therefore recommend the Department start the run-ons from the beginning of testing of managed migration.

The government accepts this recommendation in principle. The DWP will, as stated above, introduce a Discretionary Housing Payment (DHP) to support those claimants who will be managed migrated as part of the pilot phase and who appear to be in hardship. The power for DHP is broad and could be used to pay

the equivalent of the two-week legacy run-on to 10,000 claimants who will be moved to UC as part of the piloting phase and who are in hardship on account of absence of the run-on.

Recommendation 6The Department should eliminate the wait for claimants moving to UC via managed migration, many of whom will have little or no financial backstop to tide them over. It should use this as a basis for considering how the wait could be reduced for claimants migrating naturally, and for new claims.

The government accepts this recommendation in part. Monthly assessments are part of the design of UC and reflect how most people are paid in work. The DWP knows that most people are paid monthly or four-weekly. Therefore, gaining a familiarity with monthly payments through UC ensures claimants are better aligned with the world of work, which makes transition to receiving a monthly wage easier.

Recommendation 7We recommend the Department use its pilot to test different approaches to rolling out managed migration. In particular, it should work with stakeholders to identify and test approaches that limit both stress on claimants, and demands on its own workload. It should consider, for example, using existing intervention points such as the renewal of a tax credit claim or expiry of a Work Capability Assessment to prompt migration, rather than migrating claimants on an arbitrary timetable.

The government accepts this recommendation. The DWP has already begun an extensive programme of engagement and design activity with over 80 stakeholders. The DWP will continue this engagement to identify different approaches to the managed migration pilot from July 2019, such as a non-mandatory approach where claimants are invited to go through the process.

Recommendation 8We recommend that claimants should not lose their entitlement to transitional protection unless their earnings have been above or below the UC threshold for six consecutive months.

The government agreed to seek further evidence on this point. As stated in the DWP response to SSAC’s recommendation 11, they intend to use the pilot phase to assess what impact current

policy may have on claimants. DHP will also be available for claimants who experience hardship in these circumstances.

Recommendation 9We recommend that the government creates exemptions to the rules on couples forming or separating to protect transitional protection in cases where it is clearly justified to do so. In particular, the government should create exemptions for: • survivors of domestic abuse, so that no

one is deterred from leaving an abusive partner by the fear of losing transitional protection; and

• people entitled to the Severe Disability Premium, so that no one loses their SDP entitlement because a couple forms or separates.

The government should also carefully consider what exemptions might be appropriate for couples with disabled children, and for couples where one or both partners has a disability but is not in receipt of the Severe Disability Premium.

Transitional protection is awarded following a ‘like for like’ comparison between existing legacy benefit entitlement and UC entitlement based on circumstances for the claimant household at the point of managed migration. As such the government does not accept this recommendation.

Recommendation 10We recommend that the government urgently assess the impact of a sudden loss of income due to natural migration on different claimant groups and in light of that reconsider whether the triggers for natural migration remain appropriate. We will examine the government’s assessment as part of our future work on natural migration.

The government does not accept this recommendation, as natural migration only occurs when a claimant has a change of circumstance that necessitates making a new claim to a benefit that UC replaces. UC now provides the nation’s vital social security safety net and the government states that as UC is rolled out nationally, it is right that claimants must claim UC instead and any new claim is assessed under UC rules. Any consequential change in the level of income is likely to be on account of the new set of circumstances. As such the DWP has no plans to review its approach to natural migration.

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BENEFITS BAROMETER

Recommendation 11We urge the government to commit to setting tests which must be met before a single claimant is transferred to UC via the managed migration pilot. Given its role in delivering Universal Support on behalf of the Department, and supporting claimants more widely, we recommend that Citizens Advice is given a formal role in defining the tests.

The government does not accept this recommendation, as it has now put beyond doubt that it will pilot the first stage of managed migration. In addition, the government is incorporating involvement from a variety of stakeholders, including Citizens Advice.

The DWP has committed to publishing evaluation of the pilot, which will inform readiness of the managed migration process to increase volumes. We have agreed with SSAC’s first recommendation on the need for criteria and expect to set those in 2020 following evaluation of the pilot. It is more sensible for the success criteria to be determined by the piloting phase, so that it is informed by what the DWP has learned during this period.

The DWP has already demonstrated its effective use of learning in its 2016/17 piloting of the UC process, which informed the criteria that it subsequently used for the successful expansion of UC delivery from October 2017 to date. There are now over 1.5 million households claiming UC and service improvements continue to be introduced.

The DWP has always said that it will pilot the first stage of managed migration and is now introducing a new provision in the draft Universal Credit (Managed Migration Pilot and Miscellaneous Amendments) Regulations 2019, which will provide that once 10,000 awards of UC have been made to persons to whom a managed migration notice has been issued, no further notices may be issued. In effect, this means that the government is legislating for piloting powers, rather than for the whole migration period. For the government to continue with migration activity, it would need to bring forward a further regulation to revoke this provision.

‘Managed migration’ under the microscope

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The most widely claimed form of means-tested support in Britain is council tax support (CTS), which helps low-income households with their council tax. In 2013, responsibility for designing CTS for working-age households in England was devolved to local authorities (LAs) and central government funding before it was cut. Almost six years on, now is an appropriate time to look back and evaluate the experience of localised CTS. Research that we’ve undertaken into the design and effects of local schemes reveals three key insights.

First, cuts to working-age CTS have become much bigger since 2013.

Second, otherwise-similar households can be treated very differently depending on the type of LA they live in.

And third, LAs have struggled to collect the extra council tax liabilities that these cuts have created.

Big cuts since 2013It is not a surprise that LAs have chosen to reduce the generosity of CTS relative to the national system of council tax benefit (CTB) that preceded it. When central government gave LAs responsibility for CTS in 2013, the funding it provided for it was only 90% of what maintaining the generosity of CTB would have cost them – despite requiring LAs to maintain support for pensioners at its previous level. In principle, councils were free to top up this funding from other sources in order to protect households’ entitlements, as the Scottish and Welsh governments did – and some LAs took this route. But given already tight budgets, it is hardly surprising that four-fifths of English councils cut back support. Working-age entitlements in England were 14% lower in 2013/14 than they would have been under CTB.

By 2018/19, however, entitlements were fully 24% lower than if the generosity of the pre-2013 system had been maintained. Partly, the additional cuts reflect the fact that many

councils have mirrored cuts made by central government to the nationwide benefit system – most notably the freeze to most working-age benefit rates that has been in place since April 2015. We might have expected these cuts to be reflected in CTB even if it had not been localised. But by 2018/19, 90% of the 326 English LAs responsible for CTS had made changes beyond mirroring national benefit reforms, almost all of them cuts.

A 24% cut is big – it equates to an average loss of £196 this year for the 3.6 million households who would have been entitled to CTB had its generosity been maintained. Of course these cuts have fallen almost entirely on low-income households, as they are the ones who were entitled to CTB in the first place.

Significantly for many households, a cut in support means that they have a council tax bill to pay when, under the old system, they wouldn’t have had to pay anything. CTB was designed so that the lowest-income households would have their council tax bill covered in full. But the main way in which LAs have cut support is by introducing minimum council tax payments, which requires that all households (apart from any ‘vulnerable groups’ that the LA decides to protect) pay at least a fraction of their council tax bill. This means that many of the poorest households are now local taxpayers. That hadn’t been true in Britain since council tax replaced the poll tax in 1993.

Had the generosity of CTB been maintained, 1.9 million working-age English households would have had no bill to pay this year. Instead, almost three quarters of them have to pay some council tax, and one in three must pay

more than £200. Figure 1 shows that these proportions have risen markedly since 2013/14, the first year of localisation.

CTS cuts are thus significant, not just because they represent a big cut to entitlements on average, but also because they have generated council tax liabilities for 1.4 million more households who would not previously have had to pay it, and from whom it now needs to be collected.

Figure 1: Net council tax liability among working-age households in England who would have no bill to pay under the pre-2013 system

Where you live mattersWhile CTS cuts have been big on average, and generated many new council tax bills, they haven’t affected households in different parts of the country equally. There are still half a million working-age households in England that don’t have to pay any council tax, whereas if they lived in another part of the country they could be paying over £300 a year. This is because some LAs have made bigger cuts than others.

This can be shown most clearly by looking at the minimum payment levels chosen by different LAs (Figure 2 ). A fifth of LAs still have no

minimum payment, while another fifth have a minimum payment of more than 20% (requiring that all households pay more than 20% of their gross council tax bill ). The highest minimum payment is found in North Lincolnshire, which requires all working-age residents (except those with a disability) to pay at least 50% of their gross council tax bill.

Figure 2: Minimum payment levels in 2018/19

These minimum payment levels are not random. LAs that saw bigger cuts in central government funding for CTS in 2013 – typically more deprived areas – were more likely to reduce households’ entitlements. Thus households among the lowest-income fifth in England had a 60% chance of seeing their entitlement reduced if they also lived in one of the most deprived fifth of LAs, but only a 46% chance if they lived in one of the least deprived fifth of LAs – though since council tax tends to be higher in more affluent areas, poor households in affluent areas who have seen a cut to CTS have tended to receive a larger additional council tax bill ( losing £323 a year on average) than those in poorer areas (£229).

After 2013, funding for CTS was rolled into central government’s broader grant to LAs. But

interestingly, the extent of subsequent cuts to that overall funding from central government had no effect on the size of CTS cuts in different LAs. This is despite the fact that overall cuts to funding were much bigger than those in 2013 specifically associated with CTS, and LAs were free to allocate funds however they chose. This suggests that councils’ decisions are influenced by how funding streams are labelled – they’re more likely to cut CTS if the cut to funding is explicitly associated with this policy.

A further oddity in councils’ scheme choices is displayed in Figure 2. On the whole, LAs choose minimum payments that are multiples of 5% (for example, there are ‘spikes’ at 15%, 20%, 25% and 30%). However, 38 councils have a minimum payment level of exactly 8.5%. This quirk is a hangover from the first year of

localisation, when central government provided temporary additional funding for LAs with a minimum payment of no more than 8.5%, and 100 councils chose a minimum payment of exactly that level. That incentive expired five years ago, but many councils have kept an 8.5% minimum payment, while a few have even chosen that level after the incentive expired. Those LAs that do have an 8.5% minimum payment are mostly clustered together in a few areas, such as Derbyshire, Dorset and East Anglia.

The continued prevalence of 8.5% minimum payments shows that there is considerable inertia in councils’ decision-making. Many councils simply keep the scheme they had last year, and so temporary incentives can have long-lasting impacts. But the pattern also suggests that another important factor is what

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COVER STORY

other councils – and especially their neighbours – are doing.

Faced with a bill they wouldn’t have had before, many don’t pay itTo varying degrees, then, LAs have cut support for working-age households. This means households are billed for more council tax, and many households now have a bill to pay when otherwise they wouldn’t have had to pay anything. An important question is whether or not councils have succeeded in collecting the extra tax due. The answer is that, as some predicted, CTS cuts have led to a significant increase in the amount of council tax going uncollected.

Comparing otherwise-similar LAs that chose different CTS schemes, we estimate that councils have only successfully collected around three quarters of the additional council tax billed for as a result of CTS cuts. That leaves a quarter of the additional tax going uncollected, ten times the non-collection rate that is typical for council tax. Because these extra liabilities are small relative to total council tax revenue, this does not have a big impact on the overall council tax collection rate – increasing it from 2.5% to 2.7%. But it does imply that cutting CTS is of limited effectiveness as a way of raising much-needed additional revenue.

While councils might have hoped that any problems in collection might be temporary – perhaps dissipating after households could adjust to their new bill – this is not what we find. Even five years after a minimum payment is introduced, the share of the extra council tax being successfully collected remains at around three-quarters. Low collection rates would thus seem to be a long-lasting feature of CTS reforms, with collection still significantly below ‘normal’ five years after cuts are first introduced.

By comparing otherwise-similar households living in otherwise-similar LAs that cut CTS by

Look back in anger?The Institute of Fiscal Studies reports on lessons from six years of localised council tax support

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different amounts, we can work out which types of household are most likely to go into arrears when they experience CTS cuts.

Figure 3 shows the relationship between the amount a household loses from CTS cuts and the increase in the probability that the household is in arrears, split between those who would have had no bill to pay without the reform and those who would have had some council tax to pay anyway. Households who would have had to pay part of their council tax even without the cuts are barely more likely to go into arrears if their bill is increased. But households asked to pay council tax when, without the cuts, they would have had nothing to pay, see a much bigger increase in their chance of being in arrears. And this is true whether this council tax bill is big or small – households are almost as likely to go into arrears if they are asked to pay £100 a year as if they are asked to pay £300.

Figure 3: Estimated effect of losing CTS on probability of arrears, split by whether households would have had a bill to pay in the absence of cuts

These households required to pay council tax as a result of the reform, while much more likely to be in council tax arrears, are no more likely to be in arrears on other bills. This is despite the

fact that the relatively tough enforcement and penalties for non-payment of council tax mean that it would usually make more sense for households to pay the council tax and ( if necessary) go into arrears on another bill instead. This further suggests that the problem for households is not simply one of adjusting their budgets to pay an extra £1 or £2 a week, rather, faced with a council tax bill they would not otherwise have had to pay, many households simply do not pay it – irrespective of its size.

This experience of persistently low collection rates for the extra council tax generated by CTS cuts, driven by high non-payment of newly generated bills, suggests that going forwards LAs might find it easier to collect additional revenue by increasing the size of existing bills than by generating entirely new ones. That is important for the design of their CTS schemes, but may also affect whether they choose to raise revenue by cutting the generosity of CTS or by increasing council tax rates across the board – an option that has been restricted for much of the period since 2013.

Stuart Adam, Robert Joyce and Thomas Pope are with the Institute for Fiscal Studies. You can view the full report on the IFS website at: www.ifs.org.uk/publications/13827f

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COVER STORY

“ This experience of persistently low collection rates for the extra council tax generated by CTS cuts, driven by high non-payment of newly generated bills, suggests that going forwards LAs might find it easier to collect additional revenue by increasing the size of existing bills than by generating entirely new ones.”

OPINION

Mark Underwood is Head of Exchequer Services with the London Borough of Bexley. Contact him on: mark.underwood@bexley.gov.uk

...and it won’t beachieved with mere tinkering around the edges

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Wholesale andwide ranging welfare reform is needed

Amber Rudd appears to be a rare example in recent memory of a Work and Pensions Secretary who’s prepared to recognise some of the shortcomings of Universal Credit (UC)! During House of Commons Questions on 13th February, she admitted there had been ‘challenges’ with the implementation of the government’s flagship reform and that people being unable to access money after moving onto UC had ‘led to an increase in food bank use’. Her answer to solving the increasing use of food banks can broadly be summed up as follows: extending advances, removing waiting days and introducing Housing Benefit run-on. The problem for Amber Rudd and the DWP more generally is that the problems with UC are far more systemic and incapable of resolution through further piecemeal reform changes. UC will continue to trip up the government because the scheme’s inherent design flaws are a hangover from the chancellorship of George Osborne, who was sacked by Theresa May after the EU referendum. The changes he was reluctant to introduce at the time – which included the removal of the first child premium for new claims, cuts to the work allowance, limiting the child element of support to the first two children in a family, and the cut to employment and support allowance – are all now starting to bite on working families, young people, the disabled and children. This is further compounded by what Chris Town, the Vice Chair of the Residential Landlords Association (RLA) recently described as “The biggest driver of poverty in the private rented sector,” namely the government’s freeze on Local Housing Allowance (LHA) rates. “Support for housing costs is simply failing to keep up with the realities of rented housing and we call on the government to use its spending review to drop the freeze”, he says.

A report for the RLA by Manchester Metropolitan University noted what many managers of council housing departments will

already be familiar with, which is that LHA rates are the main driver of tenancy failures in the private rented sector. As if all this wasn’t already helping to cause a perfect storm, UC call handlers are now due to vote on whether to hold a major strike after being treated with ‘contempt’. Up to 295 DWP agents in Wolverhampton and Walsall are set to walk out for two days in a row over heavy workloads caused by the accelerated rollout of UC. The strike ballot, which runs up to 25th February, has been called by the PCS union which claims the system is crippled by severe under-investment, staff shortages and criticism of employees from claimants on how they are treated. This is leading to demands for 5,000 new staff, full contracts for fixed-term workers, an end to ‘management by statistics’ and a limit on the number of phone calls each case manager has to handle.

Meanwhile, the litany of misery caused to individuals and families by UC continue to surface, ranging from media stories about tenants forced to shoplift because of benefit delays, a steep rise in rough sleeping leading to the creation of a tent city in Leeds, malnourished children in Morecambe taking food from school bins to stifle hunger and the Hartlepool family who claim they’re so hard up they send out their lurcher to hunt, cooking

whatever the dog can kill. Perhaps one recent case which came to light

on social media most clearly exemplifies quite how the DWP has lost all sense of fairness and proportion in terms of its delivery of welfare policy. The image (left) came to light on Twitter recently. It showed a letter from a UC claimant who was given a sanction by the DWP of £10.40 each day because of an apparent failure on the part of the person concerned to attend ‘a telephone commitments review appointment.’ This supposedly ‘low level sanction’ was for a duration of 110 days, but the DWP imposed a further penalty of an additional seven-day period because this was the claimant’s first low-level sanction in the previous 12 months. That’s tantamount to further punishment for previous good behaviour! In what possible world can a total fine of £1,216 – with all the potential negative consequences for a claimant and his/her family – be justified for a missed telephone call (the sort of thing that could innocently happen to just about anyone), let alone act as anything like a possible incentive to getting further employment. When the United Nations feels obliged to probe the impact of this government’s austerity policies in Britain (the organisation’s first visit to a west European country in more than five years), this is the sort of case that demonstrates the shocking levels of deprivation being imposed on our poorer citizens. Quite how this fits in with Amber Rudd’s supposed commitment to delivering a fair and compassionate welfare system isn’t clear, but one thing is certain – the emerging need for wholesale and wide ranging reform if we’re ever going to return to a welfare system of which we can be truly proud.

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This year has already seen a number of significant changes to benefits and there are more welfare policy updates on the way. Whilst most were unveiled in the 2018 Autumn Budget, some changes were announced as recently as this February. With local authorities already grappling with funding cuts, Brexit and the transition to Universal Credit (UC), there are scant resources left to prepare for and potentially benefit from upcoming policy changes. Yet, by using household-level data to identify the impact of these policies and target resources accordingly, there are a number of ways councils can protect vulnerable residents now. In this article, I shall outline how households will be impacted by five significant policy changes coming up and say what data-led action councils can take now to help people on low incomes.

1. January: People on Severe Disability Premium (SDP) will remain on legacy benefitsIn June 2018, the government announced that people receiving the Severe Disability Premium (SDP) within their income-related benefits would not be moved onto UC until transitional protection became available. This move responded to concerns that these households are often amongst the worst off as they migrate to UC, due to the lack of disability premiums payable under UC. The announcement stipulated that, from 16th January 2019, no households in receipt of the SDP within their income-related benefits will be moved onto UC. This would be the case even if that household experienced a change in circumstances that would ordinarily trigger a UC claim.

What can local authorities do now?Local authorities can use existing Housing Benefit (HB) and Council Tax Reduction (CTR)

data to identify households with existing claims for income-related legacy benefits where an SDP is not, but potentially should be, being paid. As well as boosting household incomes significantly, given that the SDP could be worth up to £6,687 per annum per household, it would also ‘future-proof’ these households by ensuring that they’re not moved onto UC and so face the payment delay and potential fall in income, until transitional protection is available to them. Typically, there are no more than a few hundred such households in a given council, so staff may be able to contact each household identified individually to offer support.

2. February: Two-child limit won’t apply retrospectively under Universal CreditSince April 2017, the two-child limit has restricted the amount of Child Tax Credit (CTC) that some families can receive.

Fig. 1 Difference in income received for a third (or

subsequent) child, if the birth was before April 2017

vs. if the birth was after April 2017

This measure also applied to the child element under UC but with one crucial difference. For third or subsequent children, regardless of whether or not they were born after 6th April 2017, no child element will be paid to the parents.

However, since UC has not been available for families with three or more children to claim, this aspect of the two-child limit has not yet come into effect. From February 2019 onwards, however, UC will accept claims from families with three or more children. New or updated claims made by these families will be for UC, meaning they would face the retrospective application of the two-child limit regardless of when their children were born. In January, Amber Rudd acknowledged that this would unfairly penalise families who decided to have three or more children before the two-child limit was conceived. She announced that, from February onwards, the two-child limit will not be applied retrospectively. A family with three or more children will continue to receive the same amount within the child element within UC, for all children born before April 2017. This is a welcome change and means that UC will be more generous to larger families than

previously expected.

What can local authorities do now?Many families with younger children will still be affected by the two-child limit and therefore face receiving less income for their children than they would have previously.

Using monthly HB and CTR records, local

authorities can identify which families had their third or subsequent child after April 2017. These families would not have received CTC for their youngest child, and may be experiencing financial difficulty as a result.

3. April: Work allowances increase under Universal CreditIn the 2018 Autumn Budget, Chancellor

Hammond announced that many people claiming UC would benefit from a £1,000 a year increase in work allowances, as part of a £1.7bn injection into UC. Policy in Practice’s analysis estimated that this would positively affect 1.9m households with children and a further 0.6m households with limited capability for work. Overall, this measure, combined with the impact of a higher National Minimum Wage and personal tax allowance, would increase the average income of people receiving benefit support by around £6 per month.

Fig. 2 The average working-age household does

see a small increase in their income under Universal

Credit as a result of the 2018 Budget

However, average incomes will still be lower than under legacy benefits, with around 40% still seeing their income fall under UC. Plus, some household types will see little benefit from the Budget announcements, or insufficient benefit to cover the loss in income they could experience as they transition. Lone parents and home-owners in receipt of tax credits only, for example, are likely to benefit from increased work allowances, but both groups are still expected to receive less income on average under UC (excluding any transitional protection that they might receive).

What can local authorities do now?Given the uneven impact of the increased work allowances, local authorities may want to identify people who are still expected to see an income loss and take appropriate action. Because transitional protection doesn’t start until managed migration comes into effect in 2020, households that make a UC claim today won’t receive any transitional protection if they’re worse off under UC and could struggle to cope financially. Local authorities can contact households identified as not benefitting significantly from the Budget measures, alert them to their situation and explore ways to build their financial resilience, in case they move onto UC before transitional protection is available.

4. May: Mixed-age couples must claim Universal Credit instead of Pension CreditFrom May 2019, mixed-age couples where the older partner is of state pension age and the younger below, won’t be able to make new claims for Pension Credit. Instead, they’ll have to claim UC. Existing mixed-age couples on Pension Credit will not be affected. In other words, from May 2019 new claims for Pension Credit can only be made from couples where both partners are of state pension age.For many mixed-age couples, UC will be considerably less generous than Pension Credit.

In addition, under UC the partner who is below state pension age will usually be expected to look for or prepare for work.

What can local authorities do now?Local authorities have an opportunity to drive take-up of Pension Credit

among mixed-age couples before May. After May, these couples must claim UC which could mean they receive less income and have conditionality imposed on them. By analysing their existing household-level datasets on HB and CTR payments, councils canidentify who is eligible now and proactively target them to see whether a claim can be made before May. After this point, councils can use the same datasets to identify which mixed-age couples had to make a UC claim instead. The income that these households receive through UC may not be enough to cover the higher caring or disability needs that they may have, and could require financial assistance from the council to prevent significant hardship.

Juan Alvarez-Vilanova is a Senior Policy Analyst at Policy in Practice. For more details: visit www.policyinpractice.co.uk email hello@policyinpractice.co.uk or call 0330 088 9242

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OPINION

“ Because transitional protection doesn’t start until managed migration comes into effect in 2020, households that make a UC claim today won’t receive any transitional protection if they’re worse off under UC and could struggle to cope financially.”

5. July: Minimum income floor won’t apply for first 12 months under Universal CreditAt the moment, self-employed households on UC are assumed to earn a minimum notional income, known as the minimum income floor, which is used to calculate their award. Research carried out by Policy in Practice across 20 London boroughs finds that the majority (78%) of self-employed, low-income Londoners have actual earnings below the minimum income floor. They would therefore face significant income reductions under UC, once any transitional protection payable has ended. In light of this, Chancellor Hammond used the Autumn Budget to announce that from July 2019, self-employed households moving onto UC won’t be affected by the minimum income floor for the first 12 months of their claim. This is intended as an opportunity for self-employed households with lower earnings to increase their self-employed income, or change economic status.

Fig. 3 Using household datasets local authorities

can identify individual households who are most

vulnerable and target support accordingly

What can local authorities do now?From July 2019, local authorities can use their household-level data to identify any self-employed households that move onto UC and make sure they’re aware of the 12-month period before the minimum income floor comes into effect. To avoid a potentially significant drop in income, these households can use the 12 months to explore alternative employment and avoid the minimum income floor. In co-ordination with local Jobcentre Plus offices, councils could contact these households to begin this conversation well ahead of the 12-month deadline and offer budgeting and employment support where relevant.

Five ways councils can get ahead

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“All I’m askin’ is for a little respect” (and maybe the right amount of benefit, paid on time).

Whether you favour Aretha Franklin’s celebrated version, or the Otis Redding original, this lyric should be part of the culture of good benefit administration.

A couple of months ago, I attended a meeting organised by the Royal National Institute of Blind People (RNIB) and the Department for Work and Pensions (DWP). The purpose was to discuss, in some detail, the Work Capability Assessment (WCA).

Readers may or may not be aware that the DWP has been quietly reviewing the WCA for some time. This is the assessment that has for some years been used to determine whether an out-of-work claimant will be allocated to the Employment and Support Allowance (ESA) Work-Related Activity Group (WRAG) or Support Group (deemed to lack capability for work-related activity) – or found fit for work and therefore needing to claim Jobseeker’s Allowance. Similar categories, albeit with different names, operate in Universal Credit (UC).

All of this matters a lot, financially. The UC equivalent of the Support Group is called, snappily, the Limited Capability for Work-Related Activity Group, or even in some circles the Limited Capability for Work and Work-Related Activity Group (producing the acronym LCFWAWRAG – which sounds like somebody being strangled). Be that as it may, if you are unlikely to find a job, the consequences of not making it into this group are serious, as the difference in benefit between it and the UC

equivalent of the WRAG (the Limited Capability for Work Group) is currently a cool £78 per week (April 2019 rate for new claims).

Obviously, this creates a problem of incentives. The DWP would like disability organisations to encourage people in the ESA Support Group and UC equivalent to engage voluntarily in work-related activity. But this ignores the serious financial risk of being subsequently re-assessed as capable of work-related activity, thereby losing a lot of money and being exposed to the benefit cap and a

potentially problematic conditionality régime.Historically, benefit rates for claimants with

disabilities and health conditions have been paid at a higher rate, to reflect the pressures of being out of work for a long period, as things wear out and savings run down. (This is not to be confused with Disability Living Allowance or its successor, Personal Independence Payment, which are available in or out of work and are designed to address the additional costs of disability, such as transport or extra heating).

So the disincentive to move towards the labour market is an old one, but years of holding down the levels of unemployment-related benefits (and then cutting the WRAG and UC equivalent rate in 2017) have created an increasingly sharp cliff edge. If you move somebody out of the Support Group or UC equivalent but there is no actual prospect of a job, all you achieve is more poverty.

A key problem here is that, as described above, the system fits you into one of three boxes – able to work; not able to work now,

but maybe later; and not able to work at all. But in reality there is a continuum, not a set of boxes, between fully fit and completely unable to work. And to complicate matters further, some conditions fluctuate, so a person is not necessarily located at a fixed point in this range. How to reflect a continuum in a system of benefit rates is a real challenge.

Squaring circlesWhich returns us to the RNIB/ DWP meeting I mentioned earlier. Squaring this circle was one of the issues with which we wrestled. It would certainly help if high-quality employment services were to be put in place and to lead to actual jobs. These are big policy issues.

Also, we discussed the general administrative style and cultural climate within which the benefit system operates. Several participants, including advice workers and a former ESA recipient, pointed out that assessments are scary, much is at stake and there is a massive power imbalance between the benefit authorities and the claimant.

Which brings us back to the matter of respect. Some assessors, decision-makers, reception staff and so on, are friendly, polite and supportive. But again, there is a continuum – this time of attitudes – and at the other end (and too often) there are officials who are rude, aggressive and disrespectful. ‘Hostile environment’ policies such as trigger-happy sanctions and excessively burdensome conditionality requirements help to create a culture in which such behaviour can be seen as acceptable. It is not.

Slush It is many years since, as a youth, I experienced these divergent attitudes as a claimant. But one story which I have been known to tell to contacts at the DWP concerns an occasion about five years ago when I was mistaken for a claimant.

This was a meeting at a jobcentre in the North East. The weather was terrible, rain falling on deep snow to create a slushy morass. I consequently wore my anorak and boots, leading the man on the door to assume I was trying illegitimately to use the non-claimants’ entrance. In seeking to redirect me to the claimants’ entrance round the corner, he was rude and aggressive, but upon realising his error, he switched instantly to obsequiousness.

Spotting an instructive anecdote (which you are reading) I was not unhappy, but had I

actually been a claimant, the experience would have been offensive. This was a failure of training – and note that this was before even getting in the door!

Get a coffeeAnother instructive anecdote is more recent. A week or so after the RNIB/ DWP meeting, I heard from an ESA WRAG claimant about her experiences in visiting her ‘local’ jobcentre. Her genuinely local jobcentre ( in South London) had been closed (rumoured to be destined to become posh flats). This was good news for DWP estate sales and for any affluent potential occupiers, but not so much for claimants who now had a lengthy bus or train journey.

Now, if you have a lengthy journey by means of the inexact science of bus and rail timetables and officials at the other end have the power, in effect, to impose crippling fines (via sanctions) for being a minute late, you will of course set off very early and therefore usually arrive early.

However, early arrivals at this jobcentre

are not allowed in, whatever the weather. My informant was told:

“You know the rules. If you’re more than ten minutes early for your appointment, you can’t come in. You have to go to one of the cafés in the area and have a cup of tea or coffee”.

It should go without saying that there was no offer to pay for the beverage in question.

Again, this is unacceptable – and is not just a matter of attitudes, but also of local policy decision. Would your bank treat its customers like that?

It will not be easy to flush this sort of thing out of the system. Negative stereotyping and poor treatment of claimants have a long history. Cultural change will need political leadership, a training programme and very active management engagement.

Outsider insideIf you think my analysis above is critical,you should read a recent report byTom Pollard, published by Demos.1 Pollard spent 18 months with the DWP, as Senior Mental Health Policy Adviser, on secondment from Mind. He reports some positive experiences, but:

“By the end of my time there I had come to the conclusion that the DWP is institutionally and culturally incapable of making the reforms needed to achieve... a shift in outcomes for ill and disabled people, or for ‘harder-to-help’ groups more widely.”

He goes on to discuss entrenched at titudes and resistance to change, plus

Geoff Fimister is a writer and consultant on social security and related issues and a member of the Institute’s Benefits Faculty Board

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...that’s whatclaimants need to see!

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“ But this ignores the serious financial risk of being subsequently re-assessed as capable of work-related activity, thereby losing a lot of money and being exposed to the benefit cap and a potentially problematic conditionality régime.”

“the reputational baggage the Department and its jobcentres has with these groups”. He discusses options for transferring DWP functions to other Departments, local government and third sector organisations.

Unsurprisingly, the DWP rejected these conclusions and Pollard may or may not be right about the capacity of the present system to change – but change there must be, if we are serious about positive outcomes for claimants... and showing respect.

1 Tom Pollard, Pathways from poverty: a case for institutional reform, Demos, Jan. 2019.

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“ It will not be easy to flush this sort of thing out of the system. Negative stereotyping and poor treatment of claimants have a long history. Cultural change will need political leadership, a training programme and very active management engagement.”

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Those of you who follow this column will know that in the last publication I began to explore the impact of stress in the workplace. As part of that, I talked about the need to identify the demands that our teams are faced with, giving practical tips in terms of things you could implement to alleviate the impact of this in the coming months.

Whilst many of us will have drawn a sigh of relief, having survived year-end in revenues and benefits, our focus almost immediately will seem to have shifted towards preparations for the new financial year. There is no time like the present, therefore, to focus on the second area that contributes to stress in the workplace – control. In an ever-changing work environment, how much control do we really have over the way in which we expect our teams to work?

The Health and Safety Executive gives organisations pointers as to what should be happening in a work environment where people feel that they can cope with the demands of their role. In relation to control it suggests the following are essential to enable that:• the organisation should encourage

employees to develop their skills and, where possible, focus on developing new skills to help them undertake new and challenging pieces of work

• employees are encouraged to use their skills and initiative to do their work

• where possible, employees have control over their pace of work, e.g. have a say over when breaks can be taken

• employees are consulted over their work patterns.

All well and good on paper I hear you say, but how does it work on the ground?

In the 21st century, never has it been easier to give employees greater control over where and how they work. Modern technology enables people to work in a flexible manner,

furthermore it offers the opportunity for people to work remotely from their main work base.

Gone are the times when our back-office processing teams were all based in one location and in one room. Investment in technology reaps the rewards long term. People can still be present and not be on site. Take a moment to consider our customers – one of the biggest challenges we face is obtaining information from them in support of their benefit claims. In spite of the fact that many Housing Benefit customers work, most authorities will have a service that is aligned to the business hours of nine to five (Monday to Friday) and will be paying a premium for office space.

How many of our customers are accessing our services during those times and how much could we improve our services if we thought outside of the box? We will all be well used to working core hours but are we missing an opportunity for us all to start to explore what our customers really want and how they want to access our services?

When thinking about such things as work patterns, we may find that some people suit certain hours of work better – indeed they are more productive in that time. If we understand that about the individuals in our teams, and if we are able to align that with our customer’s needs, then isn’t there an opportunity to reduce some of the stress that is associated with work patterns and work environments? If work patterns and work environments were

better suited to individuals, how much would absence, lateness and sickness reduce?

A manager’s main focus in revenues and benefits will be how to keep on top of ever changing and fluctuating workloads and how to ensure that decisions are being made on claims in a timely and accurate manner. Remember, though, you are not managing robots, you are managing people. The complex nature of our work means that sometimes people may need five minutes away from their desks after taking a particularly difficult call or may need to work in a quiet environment if they have something complex to work on. Where core hours apply, sometimes people may prefer to carry on working on a piece of work, rather than break off from it, and come back to it after lunch. Does it matter if they take their lunch outside of core hours, as long as they take one?

If we are communicating clearly what our team objectives are, then surely how people choose to manage their workload on a daily basis is down to them, as long as they are

productive and accurate. Everybody works at a different pace – what is right for one person isn’t necessarily right for another. If people feel that they have a certain amount of control over how they structure their work, then they are more likely to be productive and use their initiative to deliver outcomes. If we focus instead on what really matters, that they have the skills they need to do the job in the manner in which we expect

them to do it, then giving people a sense of control back won’t be such a scary thought for those who like to lead in a command and control manner.

So how do we best identify what skills our teams have and how best to put them to good use? If you haven’t already done one, there is no better starting place than a skills audit. Take time to consider what skills are required to do the job that you are expecting people to deliver. Once defined, you need to carry out some analysis of where people are in relation to that. Once established, a training needs analysis is the next logical progression from this. If you engage with your teams in an open manner, people will see training and development as an opportunity to improve their skills. We shouldn’t be looking to manage people out of our organisations because they aren’t displaying the skills that we need – instead we should be looking at ways in which we can retain them and give them what we need.

As a manager you may think you know what people are lacking but how are you arriving at that conclusion? Are you basing your decisions merely upon quality assurance measures

and, if so, how effective are they? Quality assurance outcomes will only give you half the picture. In recognition of that, something we are developing ahead of the new financial year is something that integrates quality outcomes with queries asked of seniors to give a more rounded view of people’s training needs. Our training plan and coaching and mentoring provision will then focus around those areas.

I cannot emphasise enough how important performance reviews and regular one-to-ones are in affording people the opportunity to discuss how they are feeling in relation to how their skills are being used and how else they feel they could be put to better effect. Such things can help to relieve some of the frustration that people may feel when they think they are stuck in a rut in their role. Knowing that an organisation is willing to invest in them and support them with training will not only make them feel more valued but will also help us to ensure that we are minimising the risk of error from entering our systems.

Supported, engaged and well-trained benefit employees are accurate employees.Revenues and benefits administration will continue to be an ever-changing work

Sonia Limm Tech IRRV is a Team Leader with CPBS. Please note that the words contained in this article do not reflect the words of the company. Contact her on sonialimm74@gmail.com

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A bit of flexibility with your workforce goes a long way to effective management

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“ In spite of the fact that many Housing Benefit customers work, most authorities will have a service that is aligned to the business hours of nine to five (Monday to Friday) and will be paying a premium for office space.”

“ So how do we best identify what skills our teams have and how best to put them to good use? If you haven’t already done one, there is no better starting place than a skills audit.”

environment. As legislation changes, so too will our processes and our transformationplans. With an increased expectation to deliver savings within our local authorities, people will face increased pressure in the work environment. This means our employees will need to be managed effectively through change programmes. Discussion forums and feedback tools, making provision for project teams instead of reliance upon key individuals, and effectively planning for change and affording people the time to deliver it, will minimise the risks associated with it.

Stress in the workplace is not going away any time soon. Whilst an individual can control how they choose to react to stress in the workplace, as organisations we can take proactive steps to help individuals to get back control over how they work. For me, that has to be a win/win.

You are not managing robots, you are managing people

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Historically, ‘lean’ has been associated with manufacturing. It was applied to the shop floor and to those processes that were involved with the creation of goods, transportation or storage of goods – administration practices were somehow exempt from being subject to it. But as we know, in a perpetual climate of efficiency savings, we are consistently encouraged to make our processes more efficient, to cut waste and enhance the positive experience and outcomes for service users.

My service was outsourced six years ago and subject to relocation, during which time we have inevitably undergone staffing reductions, which has challenged our ability to manage welfare reform impacts, protect the most vulnerable in our communities and maintain effective working relationships, with partners inevitably experiencing the same. Nevertheless we remain committed to delivering on our KPI outturns, maximising claimant entitlements whilst ensuring that year round activities like billing at year end and maximising the subsidy income of the council run smoothly.

My column in recent times has summarised the increased workload brought about by welfare reform, the impact on our partners and stakeholders, and the changes brought about by dreaded software changes and increased use of technology. My response has been to support our benefit officers by empowering them to make decisions on claims, in doing so reducing the administrative burden, which perhaps is the obvious use of

‘lean’ in the office environment. We have also elected to keep an open mind about automation of processes and gradual implementation of robotics for simple task completion.

In terms of processing new claims and changes, I have encouraged staff to be brave in deciding claims wherever they think they have sufficient information to process that award. We are no longer assessing a claim on partial information and then writing out afterwards for further evidence.

This obviously requires a more holistic view of the claim, and perhaps this fits with the true policy intention of HBR 86 of the 2006 Regulations – ‘a person who makes a claim, or a person to whom housing benefit has been awarded, shall furnish such... information and evidence... as may reasonably be required by the relevant authority’.

I have often worried that benefit officers unsure of something will invariably ‘pend’ a claim, i.e. delay and write another letter. We have tried to address this by getting team leaders to routinely check pended work, passing back anything that in their opinion should be in payment. We have also extended the use of email and telephone contact, being more direct in contacting the public. Texting is also an important means to get the attention of, in particular, younger claimants.

In assessing new claims, if the claim is complete we encourage the benefit officer to assess the claim and phone the customer (this contact includes non-qualifiers). We attempt

one phone call to explain the award, so that we avoid unnecessary contact at reception later. The benefit notification is then enveloped up with the relevant council tax bill as part of an external printing contract. We will print locally where the claim circumstances require.

Where a discretionary award is made (either Discretionary Housing Payments (DHP) or discretionary Council Tax Support (CTS)) the notifications are with claimant consent emailed. This respects GDPR changes and is only completed where the customer is certain that this is what they want and gives full permission. If the claimant has had assistance from Citizens Advice and/or floating support teams, they are also copied into the information exchange. Finally, but most importantly, a detailed but clear and concise note is entered onto the processing system.

If the claim is not complete, staff are encouraged to establish what is essentially required and then use the new options available to us, including Wider Use of Real Time Information (WURTI ) or Verification of Pensions and Earnings (VEPS) to collect the vital financial information required to complete the assessment. We also choose to telephone the claimant either to clarify the details of their circumstances or to pre-warn them of the reason for the outcome. Where we request further proof over the phone and the claimant brings the information into the office, we will process the award there and then, print the notification off and give that out at the counter. We are taking control of the claim, and a real driver during the assessment stage will be to minimise the number of outgoing correspondence requests and being proactive in deciding claims accurately and quickly.

We are also developing the extent to which benefit officers work generically, in that simple council tax changes, for example single discount changes and even more advanced council tax changes, can be actioned as we

process the benefit or CTS claim.What about changes of circumstances?

The volume of work received as part of VEPS, RTI and ATLAS has clearly increased over the last three years. I continually have to restate that I do not believe that we have ever received as many changes in circumstances coming into the Document Management System (DMS) or processing system. There have been enhancements to the processing system to allow us to automate incoming ATLAS and

Universal Credit (UC) notices. We have as yet to be convinced as to how much value these batch processes add, in that we currently choose to look at individual items manually, checking how the incoming report sits with existing file records. I am very keen to ensure that the integrity of the database is sustained and so to blindly assess items without checking that record against CIS or the DMS I believe is dangerous. That said, I agree that we are fortunate to adopt this approach at the current time, when we are up-to-date. I can imagine that large caseloads with large volumes of incoming work and backlogs would not have the same luxury.

As far as the dispute process is concerned, we offer the customer every opportunity to make representations against the decision made. We will carry out our own version of ‘mandatory reconsideration’ where the claimant or their representative ask for an explanation or marks their response ‘appeal’. This is explained over the telephone rather than in

writing at that stage and is intended to speed up the dispute process, leading hopefully to an advantageous outcome, rather than submitting to the Ministry of Justice to convene a tribunal, which could take some considerable time.

Basically, there is a shift in emphasis, in that the onus is now firmly on staff to chase down claimants, to ensure that they provide the information immediately so that we can make the most generous decision and in doing so create a complete audit trail that justifies the outcome.

What about prospective UC claims, where the gateway for claiming legacy benefits has closed? Since Full Service rollout, we have made staff aware of the need to direct customers immediately to the Jobcentre to claim UC, whilst taking a claim for DHP and CTS. For all claimant households, we are trying to reduce the bureaucratic experience of the system, by making the means by which we contact customers more personal and lesspaper-based, to ensure that outcomes are sped up. Ultimately this means a better, more efficient service and a culture that maximises claimant entitlements, reduces hardship and cuts delays. I honestly believe that we are delivering more for less.

Paul Radcliffe is Operational Benefits Manager with arvato in partnership with Derbyshire Dales District Council and Chesterfield Borough Council

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“ We have tried to address this by getting team leaders to routinely check pended work, passing back anything that in their opinion should be in payment.”

“ There is a shift in emphasis, in that the onus is now firmly on staff to chase down claimants, to ensure that they provide the information immediately so that we can make the most generous decision and in doing so create a complete audit trail that justifies the outcome.”

We aretaking controlof the claim

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Office discussion this week, about the Seven Deadly Sins, reminded me of a series of articles I wrote for Insight, back in 2012, where I compared religious meanings of those sins to types one might see committed by management in the workplace.

I shared the first of those articles1 with a colleague, who was intrigued by my comment “studying and understanding... (the seven sins) ...can spiritually enhance our own teachings on management.” I remarked, that’s precisely how I see leadership – effective, inspiring leadership is a spiritual calling, embedded deeply in the ability to understand each person is truly different to another. Expecting mere compliance will never accomplish it.

In that same article, I suggested I’d shy away from religious debate. However, I’m about to break that promise. Because, I’d like to illustrate my point about compliance and discuss why conformity is something of a problem for management.

My observation is that causes of many world problems – historic and current – are rooted in religious conflict. Examples would be historical discord in Ireland and the English Civil War. In turn, I don’t feel religious leaders have been strong enough to condemn acts committed in the name of religion or masked by the secrecy surrounding some religious faiths. Examples would be Islamic radicalisation or various heinous abuse carried out by Catholic priests.

And, you’d be right to point out the world’s two most extreme and regrettable conflicts – the 20th century world wars – weren’t so much about religion per se. However, it’s clear to me they involved elements of conformity. Naziism is undeniably about that!

My problem isn’t so much religious teachings – for I’m not well enough informed about different faiths to comment – but, more about expectations of conformity they carry. In order to be seen as a virtuous religious advocate, most faiths require followers to engage in

specific activities, with high degrees of control as to how, when and where those activities take place.

Might I stress, I’m not totally against conformity. For society to operate effectively we all have to moderate our behaviour and conform to a degree – otherwise we have anarchy. It’s more about the expectation that, to be considered ‘real’, all followers must comply.

For example, I’m Church of England born and to be deemed a Christian, I should attend church each Sunday. I disagree. I consider myself God-fearing, but don’t worship religiously. I do it my own way. I don’t conform, but that makes me no less a person.

So, what’s all this got to do with management and leadership? Well, for me, leadership isn’t about generating conformity and compliance with whatever your organisation is doing. In benefits, you’re providing a service. Therefore, your leadership should be encouraging your workforce to engage with your organisational values, developing understanding of your organisation’s purpose, and ultimately inspiring a passion for delivering high quality service to your customers.

For me, it’s not about making your workforce do that; it’s about generating an environment where they want to do it – more than that, an environment where they feel the need.

I touched upon spirituality earlier. I’ve often referred to author Steven Covey. In his Seven Habits2 – is it always seven? Seven Habits, Seven Sins! – anyway, Covey stated “the spiritual dimension is your core, your centre, your commitment to your value system. It’s a very private area of life and a supremely important one.”

Some of what he’s saying, I believe, emphasises my point. We’re all different and driven by a different core. Therefore, conformity to a specified approach, or set of ideals, won’t work for all. We have to find our own spiritual core and, as leaders, work hard to try and

Sean Langley FIRRV is a consultant with CPC Project Services, and author of ©The phat Controller (A Leadership Handbook). Go to www.seanlangley.co.uk

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Leadership these days should be about challenging questionable policies and decisions

Se

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La

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MANAGEMENT

It’s a spiritualcalling. Be that good!

understand what’s at the core of our followers. “It’s good to be born into a religion, but

it’s not good to die in one. Grow and rescue yourself from the limits and regulations and doctrines that fence in your freedom of thought, the ceremonies and rites that restrict and direct. Reach the point where churches don’t matter, where all roads end from where all roads begin.” 3

Use Sai Baba’s words to inspire supreme efforts. I don’t expect people to agree with my disdain for religion, I would just hope people can understand conformity and compliance ultimately leads to disengagement or, at least, disenchantment.

So, don’t expect everyone to be automatons or robots. Give them space to ‘worship their own God’ as they see fit. In the workplace, this translates into allowing them space and freedom to express themselves – verbally and creatively. This way, you’ll inspire them to greatness and your organisation will benefit accordingly.

Failure to accomplish this will leave you exposed to possibilities of people rising up against conformity expectations. Only recently we’ve seen a good example, with UK schoolchildren demonstrating against government failures to address climate change issues. In future, your workforce will simply not comply with anything questionable.

In our world, if you get it right, the beneficiaries will be those we serve – the general public. As I said, it’s a spiritual calling. Be that good!

1 The 7 Deadly sins... Insight, March 20122 7 Habits of Highly Effective People, S. Covey 3 The Embodiment of Love, Sathya Sai Baba

TUESDAY 4 JUNE

• Uncovering Procurement Fraud

• Taking Grants for Granted

• Techniques for Measuring the Impact of Fraud

• Data Manipulation: Working with the Private Sector

• Recovering Investigation Costs

• Insurance Fraud

• Policing Internal Corruption

• Safeguarding Vulnerable Electronic Devices

• Business Rates – Avoidance or Evasion?

• Adult Social Care Fraud – A Time-bomb?

• Blue Badge Investigation and Recharging

• Ask the Experts / Plenary with Conference Speakers

WEDNESDAY 5 JUNE

• The Cabinet Office Public Sector Fraud Professional Scheme

• Fighting Fraud Locally

• Undertaking Proactive Grants Exercises

• Undertaking and Recording Open Source Enquiries

• Recovering Properties Through the Courts

• Housing Fraud: The Current Climate

• Investigation Law Update

• Ask the Experts / Plenary with Conference Speakers

Special Offer: Members can book 3 places for the price of 2

Cheapest pass free. This discount will only be made available to delegates attending from the same organisation. Bookings must be made at the same time. At least one of the delegates must be a member of the institute in order to receive this discount or alternatively if the organisation subscribes to the Forum or Benefits Advisory Service then they will also be able to receive the discount.

Special Offer: Complimentary exhibition only passes available to all non commercial organisations

If you would like to be considered for a pass, please email your request to conference@irrv.org.uk. Please note these passes are only available to employees from non commercial companies and applications are considered on a case by case basis.

InvestigationFacultyInvestigationFaculty

IRRV ConferencesMembers can book 3 places for the price of 2*

E: conference@irrv.org.uk T: 020 7691 8987W: www.irrv.net/fraudconference

IRRV Fraud & Investigation Conference and Exhibition4 & 5 June, The Council House, BirminghamThis is an event which has been designed to meet the needs of frontline Investigators in local government. It will also interest Heads of Revenues and Benefits who are facing ever increasing problems with fraud, avoidance and evasion of local taxes.

The conference sessions will be covering the following topics:

For bookings, fees and comprehensive programme information, please visit:

www.irrv.net/fraudconference

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IRRV Qualifications

IRRV Certificate Level 3

This course is designed for those who wish to gain a professional qualification and further their careers. Streams available:• Revenues and Welfare Benefits• Non-Domestic Rate• Valuation Tribunal

IRRV Professional Diploma

This course is designed for those who wish to progress to senior positions. The Professional Diploma leads to the highest level qualification, IRRV Honours.

Fees• IRRV Certificate Level 3: £1260.00 plus VAT• Diploma: £1380.00 plus VAT• Individual Subjects: on request

Students can enrol for Distance Learning at any time throughout the year.

* This offer is valid on multiple bookings with a minimum of 3 candidates.

E: distancelearning@irrv.org.uk T: 020 7691 8984W: www.irrvdistancelearning.org.uk

IRRV Distance Learning

3 places for the price of 2 on multiple enrolments*

IRRV Scotland

E: scotland@irrv.org.uk T: 07899 877883W: www.irrvscotland.org.uk

Universal Credit Conference 2019

Thursday 18 April 2019The Leapark Hotel, Grangemouth

Includes Free Places Special Offer *

* See website for more details

Universal Credit Conference 2019

IRRV Scotland is pleased to announce this major conference, taking place on Thursday 18th April 2019, and being organised at the request of local authorities, housing associations, other organisations and IRRV members across Scotland.

The advent of Universal Credit heralds the biggest change in welfare benefits delivery in a generation and its likely impact on service delivery in local authorities is hugely significant.

This conference will look in detail at current issues surrounding UC implementation, how this affects local authorities, housing organisations and the third sector – and experiences and lessons to learn to date. The conference will also look at associated issues – including Universal Support, Direct Deduction, rent arrears and UC and preparing for mixed aged couples and UC.

Fees: Day Delegate Charge. . . . . . . . . . . . . . . . . . . . . .£165 + VAT Reduced Charge where delegate is IRRV member or student. . . .£145 + VAT