Reply To: Change of address…..again!

Julian Hobson

Ian I trhink you are right, that is exactly what is said.

Received Reply on the outstanding issue:

“This note is a follow-up to my note to you dated 10th September. You’ll recall that at para 12 of that note, the following issues surrounding notification requirements were left unaddressed:

(a) for claimants who move from LA property x to LA property y within the same LA, would it be sufficient for the Housing Dept to notify the HB dept of all “Pensioner” customers’ change of addresses, without there being a separate requirement on the pensioner? and

(b) if that answer is “yes”, could the same view be taken where direct payment is made to a private landlord, and the landlord owns both property x and property y and the claimant moves from one property to the other? and

(c) what would be the verification implications of any of these arrangements, particularly if nothing is received from the customer which would confirm/declare occupancy in order to satisfy s130(1)(a) SSCBA 1992?

3. I’ve had responses from both Housing Benefit Security Division and BFI. In short, their answer to both questions in paras 2(a) and (b) regarding whether or not it would be sufficient for the landlord to inform the HB section of the change of address, is no it would not be sufficient.

4. The main area of concern would be if the HB section accepted automatically that that claimant had a new residency on the basis of the landlord’s word that that was so. At its most basic, other information is needed from the claimant in order for HB entitlement to be established at the new address, such as whether or not other people are living there. But the fundamental point is that regard needs to be given to the security of the system:

4.1. it might not be unreasonable to assume that the LA should be able to notify itself of a change of address, but doing so might give opportunities for fraud within the LA – put another way, procedures should not place LA staff at greater risk of being accused of fraud than is currently the case;

4.2. no doubt most private landlords are fine upstanding citizens, but there are cases where the honesty of the landlord might not be what it should be. Accepting the landlord’s word alone would surely widen the scope for fraud.

5. Regarding the issue in para 2(c), there are no verification implications if we adhere to “no” as the answer to paras 2(a) and (b). Our position is that it seems entirely reasonable to conclude that the claimant him/herself must tell the LA that s(he) has changed address under s130(a) of the Social Security Contributions and Benefits Act 1992.