11 Customer Compliance Validation

Mandatory Validation

  1. There is a mandatory requirement to check 1% of all cases where an outcome has been recorded on FRAIMS each month. Where the available cases fall below 100 a minimum of 1 case should be checked.
  2. The purpose of this check is to validate that:
  • the recorded number of Customer Compliance activities is accurate,
  • the recorded number of Customer Compliance change cases is accurate,
  • the recorded amount of Monetary Value of Adjustment (MVA) is accurate, and
  • any overpayment/underpayment has been identified, regardless of the amount.
  1. The 1% validation checks will be undertaken by a nominated officer within the Regional Performance Team. Validation checks should be undertaken by using the information recorded on FRAIMS. The 1% validation check will ensure:
  • All FRAIMS entries are correctly recorded,
  • the case has been actioned correctly, and
  • all errors which have been identified are correctly reported.

Selecting Cases for Validation

  1. When undertaking the selection process for Customer Compliance validation you will need National access to FRAIMS. This can be obtained by completing theFRAIMSAC1.
  2. Cases are selected using the end of month Activity results supplied by the Operational Lead.
  3. The checking officer should randomly select the cases for the check using the random numbers provided by the National Operational Lead. Where fewer than 100 cases have a ‘Date of Outcome’ recorded, a minimum of one case should be validated.
  4. Each month the checking officer must ensure that:
  • 1% of all cases where a Date of Outcome has been recorded on FRAIMSare gathered for the validation check,
  • all validation checks are undertaken.

Performing the Validation check

  1. The only systems available for validating a case are:
  • FRAIMS,
  • OPSTRAT,
  • LMS.
  1. The checking officer should check the following activities when undertaking the validation check:
  • The referral was appropriate for action by the Customer Compliance team, as detailed in Key actions/activities to check;
  • The correct method of intervention was used, i.e. face to face interview, unless Customer Compliance guidance allows for some other method of dealing with the case,
  • All action undertaken by the Customer Compliance Officer (CCO), i.e. letter issued, email sent, etc should be shown on a separate line on FRAIMS,
  • Copies of letters issued should be available to view on FRAIMS,
  • Monetary Value of Adjustments (MVAs) and positive outcomes were correctly claimed in accordance with the guidance in Recording Outcomes,
  • MVAs were only claimed for the benefits listed in Claiming a MVA,
  • Overpayment action is pursued where appropriate, checking that the case has not been closed on FRAIMS first, and
  • All amounts of MVA for each benefit, including Housing Benefit (HB)/Council Tax Benefit (CTB) and overpayment/underpayment amounts have been separately recorded on FRAIMS whether they are claimant error or official error.
  1. The checking officer should then complete Customer Compliance Validation Check each month and issue to each district to notify them of the number of cases that have been checked that month.
  2. The checking officer will then report their initial findings to the Customer Compliance Manager (CCM) on Customer Compliance Validation Checker's Worksheet.
  3. If no validation or procedural errors are found on the case, do not complete Appendix 9. The check will have already been recorded on Appendix 8.
  4. They should allow 5 working days for a response from the CCM before concluding their check.
  5. The CCM should ensure that the appropriate feedback loops are in place to the individual and that all:
  • discrepancies are fed back to the individual, and
  • remedial action is undertaken, if required, for the individual.

Recording the Validation Check

  1. All checks completed must be noted on an A98 or equivalent local recording system. Any discrepancy identified should be recorded along side each entry. As a minimum the nominated officer should record the following details:
  • date of selection,
  • claimant’s name,
  • National Insurance Number (NINo),
  • FRAIMS case number,
  • if the case was correct or incorrect, and
  • if any further action was required, such as a requesting a change to information already recorded on FRAIMS.
  1. Where a change is required to the information recorded on FRAIMS, the checking officer should complete the monthlyMIcorrection stencil, clearly stating the adjustments to be made in terms of activity, outcome and MVA. The stencil should be emailed to xxxxxxxxxxx National Operational Lead Support, along with the Validation Check statistical spreadsheet, by the deadlines stated on the MI and ValidationTimetable 2011/12. The MI will then be adjusted on the Boxed Set and National Scorecard.
  2. The categories of validation failures must be recorded in the main body of the email when sending the stencil to xxxxxxxxxx.
  3. The A98 or local recording system should be noted to confirm that this follow up action has been undertaken.

Retention of Monthly Validation List

  1. Each monthly validation list must be held by the checking officer.
  2. The 12 monthly lists to be produced for each checking year must be retained as a “whole checking year validation document” for 14 months from the end of that checking year. The checking year runs from 1st April to 31st March.
  3. The Regional Performance Manager will sign off the “whole checking year validation document” for each Customer Compliance Team in the first week of May.
  4. The Regional Performance Manager will ensure compliance with this process.
  5. This process may also be periodically validated by DWP Internal Audit. The Performance Manager in each Region must be able to provide their monthly validation report for audit purposes at any time during the checking year.

Validation Definitions

Definition of an activity

  1. An activity is a robust and challenging face to face interview with the claimant, either by office interview or home visit, unless Customer Compliance guidance allows for some other method of dealing with the case.

Definition of a change

  1. A change is a decrease or increase in benefit, and/or an overpayment or underpayment.

Definition of a Monetary Value Adjustment

  1. For a definition of a Monetary Value of Adjustment (MVA) see Definition of MVA.

Definition of an overpayment/underpayment

  1. Any past period overpayment/underpayment, regardless of the amount, resulting from a change identified during Customer Compliance activity.

What is an error

  1. There are two types of errors to consider when validating a case:
  • Validation error.
  • Procedural error.

Validation error

  1. Cases failing validation will have an impact on the Key Management Indicator (KMI).
  2. A case will fail the validation check if the following circumstances apply:

Category / Type
1 / The referral should not have been accepted as it did not fulfil the criteria for an intervention. See Types of Customer Compliance referrals.
2 / A positive outcome/MVA has been claimed but it is not appropriate, i.e. the Customer Compliance Officer (CCO) is not directly responsible for the change in benefit. See Claiming a positive outcome.
3 / A positive outcome/MVA has not been claimed when it is appropriate to claim. See Recording outcomes.
4 / An incorrect amount of MVA has been claimed. See Claiming a MVA.
5 / Housing/Council Tax Benefit claimed when not appropriate to do so. See Claiming a MVA.
6 / An overpayment/underpayment has not been identified/claimed for.
7 / Causal link applied incorrectly/not applied, i.e. claiming an outcome after commencing the causal link period from the second or subsequent interview. See Causal Link.
8 / An incorrect outcome and outcome result category has been used. See Recording outcomes. An example of this would be if the case should have been closed “no result”, “abandoned”, “cleared before receiving case” or “duplicate referral” but was closed “no result” and “no change” it would incorrectly generate an Activity to be counted for stats purposes.
9 / Claiming a future change.
10 / Identifying a positive outcome but failing to record the amount of the decrease/increase on FRAIMS. See Recording outcomes.
11 / Any inconsistent recording on FRAIMS, i.e. recording the outcome result as a benefit decrease but recording the MVA as an increase. See Appendix 5 – Examples of positive and unsuccessful outcomes.
12 / If the case was live and the CCO has cleared it and claimed and claimed either No result/No Change orPositive Outcome without having any contact with the claimant, when a robust and challenging face to face interview to ensure the Compliance effect was required, as per guidance.
13 / The information needed to validate a case is not on FRAIMS, OPSTRAT notepad or LMS.
14 / Other (explain).

NB: this list is not exhaustive.

Procedural error

  1. In these circumstances, the CCO will not have followed guidance appropriately in arriving at the outcome and, therefore, is a quality issue rather than a failed validation case. A procedural error will not fail a validation check.
  2. The following scenarios are examples of procedural errors and would not fail a case for validation:

Category / Type
1 / Raising a Fraud Referral Form (FRF) under the wrong category but it was a genuine allegation, i.e. raising the case as a Risk A or B, an allegation of living together/civil partnership where no other party is declared in the household.
2 / Issuing incorrect Customer Compliance letters/no copy of any letter being sent in FRAIMS so unable to verify that the correct letter has been sent.
3 / Contacting an employer directly without having first obtained the claimant’s permission, even if the correct letter is used.
4 / Not B/Fing appropriate cases for the 28 day causal link check, i.e. closing a living together case “no result” and “no change” but failing to leave the case open for 28 days following denial of Living Together As Husband And Wife/Civil Partnership (LTAHAW/CP), where the claimant did not declare LTAHAW/CP and benefit did not alter during this period.
5 / Not notifying an interview within the timescales as defined in Customer Compliance guidance.
6 / No note in notepad showing ‘Customer Compliance interest/do not delete until date’ or incorrect ‘Do not delete date’ held.
7 / When the claimant says they want time to think about moving in with an alleged partner and the CCO exceeds the 10 day rule for re-interviewing the claimant. SeeAction required in specific circumstances - Living together cases only.
8 / All the information needed to validate a case is not on FRAIMS but can be found on OPSTRAT notepad or LMS as well as FRAIMS.
9 / Other (explain).

NB: this list is not exhaustive.

Examples of Validation Failure Cases

Example 14 – GMS Prisoner Referral

  1. On 11/05/09 the benefit section received a telephone call from the claimant’s mother saying that he was in prison. Benefit was suspended at that point, a case control was set and a letter sent to the prison asking for details of admission to prison. On 12/05/09, having received the General Matching Service (GMS) referral, the Customer Compliance Officer (CCO) sent a fax to the prison asking for confirmation of entry to prison. On the same day they received a fax in reply and sent this to the benefit section. On 13/05/09, the benefit section receives form EBS1 from the Prison Liaison Officer giving the same dates as on the fax. Benefit was terminated by the benefit section and they raise the overpayment. The CCO claims a positive outcome, a Monetary Value of Adjustment (MVA) and overpayment on this case.
  2. This referral was appropriate for Customer Compliance, however, the action to stop benefit had been instigated by the benefit section following the telephone call from the claimant’s mother. The benefit section then followed up, closed the claim and raised the overpayment. Customer Compliance were not primarily responsible for benefit being stopped, therefore, the case should have been recorded as “No Result” and outcome result as “Cleared Before Receiving Case”.

Example 15 – Inappropriate “R” Case

  1. This referral was a “Risk F” case from the RMS4D scan and a Fraud Referral Form (FRF) was raised by the CCO on 20/03/09. A visit was conducted on 07/04/09 where the claimant told the CCO that he had already sent his ES form to sign off back to the office and was now in full time work, although the claim had not been closed down. An MF47 was taken, however, the claimant had not signed on since February and no benefit was in payment at the time of the intervention. The CCO claims a positive outcome and a MVA.
  2. This case should not have been accepted by Customer Compliance because a preview of the claimant’s case prior to the interview would have shown that the claimant had not signed on since 16/02/09 and he had not received any payment since then although his claim had not been closed down. The fact that the CCO provided information to allow the claim to be closed is not justification for a positive outcome. Some monetary saving must result.

Appeal procedure against Validator’s findings

  1. If you disagree with the validator’s findings you must complete a validation appeal sheet giving your reasons for the disagreement and send it by email to: xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx.
  2. Following an appeal if you still disagree with the validator’s findings re-submit the matter to the Customer Compliance National Validation Team who will then refer the matter to Customer Compliance Expert Domain who will arbitrate and make a final decision.
  3. The Customer Compliance Expert Domain will send their decision to the National Validation Team who will then forward this decision to the Customer Compliance Officer.

CC 11- Validation (12/11)