Verifying Claims and Changes

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  • #38979
    marcia
    Participant

    Hello there,
    I posted this on the procedure forum and haven’t had a reply, so I’m trying again here!!
    I wonder if I could have opinions on our current verification procedure, I’m worried that our current auditors will not be happy with some things.

    We have started to accept some information over the phone, we do not ask for these details to be confirmed in writing. (Our customer contact staff do make some checks that they are speaking to the correct person by asking for DOB and NINO etc.)

    These are the things we currently accept.

    Date of moving in
    Date of moving out
    Date of non-dep moving in and out
    Dates of birth for all household members
    Withdrawing and cancelling of claims
    Child being born (for passported benefit claims only, but not PT claims)
    Child leaving the household
    Passported benefit award (should be checked on CIS anyway)
    Rent charge where there is a gap in the claim
    HB Run-On details

    The DWP have told us that they are still working on a risk based verification document, but this will not be completed until April 2012.

    Does anyone else accept this level of information over the phone?

    #110442
    jmembery
    Participant

    Yes we accept them all and a bit more (Rent charges must come from the LL not claimant do we do accept them over the phone from the LL).

    We do record the telephone calls though.

    #110444
    Kay_Tade
    Participant

    [quote=marcia]I wonder if I could have opinions on our current verification procedure, I’m worried that our current auditors will not be happy with some things.[/quote] Unless you are doing something, other than as specified by HBR 88[CTB equivalent], can’t see why.

    Regulation 88 Duty to notify changes of circumstances

    We accept most of what you have listed, but also request confirmation in writing for file for some things, and we record calls as well.

    #110445
    marcia
    Participant

    Thanks to both of you for your replies. We don’t record our calls, perhaps that’s what we should be looking at! :bigsmile:

    #110446
    jmembery
    Participant

    Recording calls is great, not only for verification issues, but the number of times claimants have complained that they were told a certain thing on the telephone.

    Now we can check. Sometimes the claimants are right they were told something wrong!!

    #110447
    Andy Thurman
    Keymaster

    Where calls aren’t recorded, I would just ensure clear procedures are followed i.e. the person taking such a call from a claimant re-affirms the statement, makes decent notes and the notification letter from any resulting assessment clearly states that this is based on the call of dd/mm/yyyy.

    #110458
    chris harvey
    Participant

    I think it’s a good idea to be wary of external auditors. I have had some protracted correspondence with the DWP about accepting changes over the phone, and they have doggedly stuck to the line that as a pre-cursor you must have adopted tele-claiming by publishing a phone number for that purpose. If you haven’t they say that ALL changes must be made in writing. I’ve argued that 88b(ii)and 88c allows you to accept some by phone even if you are not tele-claim enabled but their take is that this should be the exception and generally changes must be made in writing. I gave them the scenario of someone phoning to say they have got a well paid job and wanting to end their claim, I would process that from the phone call, but the DWP said no, we should suspend, write out giving a month and terminate after the month had elapsed. What a waste of time.
    As far as auditors are concerned we have the Audit Commission and they keep throwing at me the instructions the DWP have given them (what they call their certification instructions). This repeats the DWP view stating that claims and changes must be in writing unless e-enabled, telephone enabled, or SunGard risk analysis site. Furthermore they say that sufficient supporting information must be available to support the change and particularly where we have accepted figures for earnings or other income verbally this is not sufficient. They say the DWP instructions tell them to remove any expenditure from the entitlement cell and put it in the LA error cell for any increases in expenditure for which supporting evidence is not available.
    I hope your auditors are not as picky as mine but I think you should be very wary.

    #110461
    Andy Thurman
    Keymaster

    [quote=chris harvey]This repeats the DWP view stating that claims and changes must be in writing unless e-enabled, telephone enabled, or SunGard risk analysis site.[/quote]

    With no disrespect to Sungard, I fail to see how this criteria can have any legitimacy. If DWP “allow” non-written changes where this product is in place, it must implicitly be allowing any LA to have its own risk analysis policy to achieve the same end.

    #110462
    chris harvey
    Participant

    The DWP have to approve any authorities wanting to adopt the Sungard Risk Based Verification system. They have currently stopped issuing approvals but are expected to resume issuing them soon. The authorities that have been approved are listed individually in the certification instructions (there are 13 of them and each one has the date they were approved from stated). Auditors are expected to check that these sites have correctly followed the risk analysis process (some high risk claims have to have additional verification above the normal standards, some have to have normal verification and low risk cases can accept verbal information)

    #110463
    Andy Thurman
    Keymaster

    While Chris is spot on to warn of auditor headaches, the DWP should be fully challenged on this – HBR 88 b 1 states:
    where the relevant authority has published a telephone number for that purpose OR for the purposes of regulation 83 (time and manner in which claims are to be made) UNLESS THE AUTHORITY DETERMINES that in any particular case or class of case notification may not be given by telephone

    Sub para ii gives even greater discretion to LA’s but the “OR” in the first bit shows quite clearly that there is no legislative basis for the DWP/audit stance of needing to be tele-claim enabled.

    #110464
    Kay_Tade
    Participant

    What can I say? The regs are as clear as it has been written, circumstances allowing, but the DWP want it to mean/say something else. Just change it then. |(

    #110466
    chris harvey
    Participant

    I completely agree Kay, and we continue to accept certain changes (eg cancelling a claim at the claimants request) by phone despite the DWP advice. The law is the law and they can’t try and give it another meaning just because they want to. The auditors don’t generally have a problem if you are stopping benefit, only if you are starting or increasing an award.
    For what it’s worth here is the DWP response I got in full:-

    “You are correct that the regulations state that changes can in some cases be notified to the authority in a ‘manner other wise than in writing.’ This provision is an exception to the general requirement, which we have stated previously, that unless a telephone number is published for the purposes of making a claim, then changes must be reported in writing.

    The exception is there to allow authorities the discretion, in specific cases, to accept information in a different format. An LA may for example decide that it isn’t necessary for the customer to write – perhaps because the change relates to an award of a passported benefit, and has already been notified to them by DWP, or perhaps because the customer has a disability and is unable to write. But, as the regulation refers to ‘in any particular case’ as opposed to ‘any class of case’ it is clearly intended to apply to a small number of customers in very specific circumstances and should not be used as justification for a general policy to allow telephone reporting of changes.

    The regulations requiring written confirmation, and the provisions allowing customers time to provide information are there to protect the customer and the local authority. It is important to make sure that decisions are supported by evidence, and that there is a clear audit trail of decision making. It is also important to make sure that the person reporting the change is either the customer or a person entitled to pass on information on their behalf. The main reason why the regulations specify that changes should only be reported by telephone where there is provision to accept claims in this manner is that we expect authorities to have put in place procedures which ensure the validity of such claims, eg telephone recording. This will obviously mean that evidence is available to support any reported change and so written confirmation is not essential.”

    #110490
    nickkeogh
    Participant
    #110500
    marcia
    Participant

    Thanks for all of your help guys it’s been massively useful! I’ve found out that we do in fact record our phone calls, (although in my defence the contact centre isn’t in the same building as us.)
    But that has thrown up another question if I may. We only have enough storage for the phone calls for approx 3 and a half years, but wouldn’t we need to keep them for 6 years after the end of any claim? (How you’d be able to do that without really keeping all of them forever is totally beyond my brain power today!)
    So does anyone know if document retention applies to recorded phone calls if they make up part of the verification of a claim or change?

    Thanks again.

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