Having seen numerous poor quality decisions on fraudulent overpayments, in my view the main need is for a very secure knowledge of the rules of entitlement, overpayments, diminishing capital, underlying entitlement and decision making. In particular the CDs/UTDs on reg 104 HBR and decision making.
Also an objective approach which disregards the fact that the customer may have behaved in a dishonest or disreputable way. Is this more a matter of organisational culture and the style of management than training?
As you also suggest, sufficient time is needed to re-assess cases going back sometimes many years and with less than perfect evidence. Cutting corners and not allowing enough time is not only wrong but counter productive.
There are some issues peculiar to fraudulent overpayments, such as the date that the relevant fact(s) were known by the DWP/LA as this may create an official error OP for part of the OP period and the need to ensure that a system is in place so that evidence of income and capital is passed from DWP to the LA DM or that the DM at least asks DWP to supply what they do have. This often appears to not happen and then dangerous assumptions are made about non entitlement – particularly in living together and undeclared earnings cases.
Some LAs’ notifications also leave a lot to be desired – failing to state the right of appeal without first seeking a reconsideration seems to be a regular favourite.
I write as I have today seen yet another case of an OP where the LA has simply assumed nil entitlement to HB/CTB in an alleged living together case when the customer’s IS has been superseded, even though all the alleged partner’s net earnings are in the bundle for the criminal proceedings. Also no right of appeal is given in the decision notice. The LA in question will be hearing further about this and it will be drawn to the Court’s attention.
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