Housing Fraud. Briefing from the CIPFA Better Governance Forum

Transcription

1 Housing Fraud Briefing from the CIPFA Better Governance Forum This paper provides proven ways of how to prevent and stop Council Tax single person discount (SPD) fraud and housing allocation fraud. Dr Bernard Herdan, CB Chief Executive National Fraud Authority "Fraud against the public sector is estimated to cost the UK between 17 billion and 25 billion every year. Preventing fraud can make a significant difference to public sector finances at a time of radical spending cuts, helping to ensure that public services for the most vulnerable are protected. By fighting housing tenancy fraud in particular, councils can ensure that those who are in genuine need are re-housed whilst reducing the cost of putting the homeless into temporary accommodation. "The National Fraud Authority is working with local authorities across the country to deliver an ambitious programme of counter-fraud activities aimed at helping reduce the impact of fraud against the public sector. We are identifying and sharing best practice and spreading new ideas and approaches, learnt from both public and private sectors, on how to better prevent and detect fraud. "We therefore welcome this CIPFA guidance on tackling housing fraud. I urge local authorities to implement the principles in this guide and join the fight to protect vital public funds."

2 Single Person Discount Below are some simple procedures that will help prevent and detect the largest proportion of suspect SPD s. The major problem most councils face is the volume of SPD s. The likelihood of fraud is further increased by the fact that an SPD can be given on request, without evidence or validation. Prevention 27 th October 2010 provision by the Audit Commission of a comparative tool to all councils, allowing evaluation of the level of SPD with Commission predictions and potentially similar councils. Effective prevention is about being able to confirm if a person is genuinely living alone, and this can be done in a number of ways. Some councils may already have data warehouse facilities or single customer records. This means that a number of data sources can be searched in one go very quickly, and any contradictory information can be put to the person trying to claim the SPD. This can be done at the point of contact if the request is made by phone or visit, or later in writing however the request was made. If a council does not have data warehousing or a single customer record, then they can opt to cross reference the request with a limited number of other data sources to minimise resource expenditure while maintaining higher rates of detection. Experience has shown the following internal sources to give a reliable indication that the SPD is not genuine (in order of success) so long as the records are kept reasonably up to date. This is because of the volume of records, their coverage and the ease with which they can be searched or data matched. Electoral Register (full version) Housing Benefits (some systems record two or more adults on a SPD claim) A council s payroll Library and Leisure records Housing records Blue badges, taxi licensing, resident s parking permits School records External data is also valuable and may not necessarily be too resource intensive: National Fraud Initiative (NFI) Credit Reporting Agency Social Networking Sites Visit Detection The detection of suspect SPD s is relatively simple, but a council needs to be prepared for the volume of work that might be generated if their records have not been consolidated or data matched previously. It might be necessary to carry out the work in stages. If a council has the means and expertise, for the greatest rates of detection it can data match SPD records with the Electoral Register (this match is automatically provided as part of NFI), Benefits and Payroll. As with any matches, they can t be seen as proof positive that an SPD is incorrect, but it is justification for contacting the SPD claimant and clarifying the situation.

3 Whether it follows that the SPD is removed or remains, it is critical that a council s records are updated accordingly and are synchronised (removing voters from the register for example where an SPD is genuine). This will prevent SPD s unnecessarily being brought up by matches in the future. If a council doesn t have the means to data match, then it can look to NFI for example. The frequency of NFI (undertaken every two years) should be taken into account when developing a strategy to deal with SPD irregularities. There are a number of organisations that will either provide a matching service or match against data they hold. However, the cost of these might warrant a council (or councils) developing its own data matching regime if the necessary level of resource and skill is available. Effective Cross Referencing and Data Matching Whether looking to prevent or detect suspect SPD s, a council needs to ensure that it s cross referencing mechanisms are robust. This can be done by adopting some basic rules. Keeping all records up to date and accurate. 1. Record first names and surnames in full. 2. Record addresses accurately. Utilise Local Land and Property Gazetteer (LLPG) and match records in the first instance by address - namely LLPG Unique Property Reference Number (UPRN). If LLPG is not available, match by creating a unique reference number derived from the address (all property numbers plus the postcode). This helps negate some of the problems associated with addresses being input inconsistently. Consider putting time limits on SPD s with a view to reviewing them, especially where frequent data matching isn t possible. An overall rolling review of SPD awards to identify trends/anomalies/outliers/exceptions. A detailed percentage check of SPD awards. Data Protection All councils processing, cross referencing and matching data will have to ensure that they comply with the law specifically, consideration of the Data Protection Act 1998 and the Human Rights Act Good practice guidance, including the use of Fair Processing Notices, is available on the site of the Information Commissioner s Office The following are particularly pertinent: Framework code of practice for sharing personal information Data Protection Good Practice Note - Data sharing between different local authority departments Personal information online - code of practice

4 Housing Allocation Fraud Registered Providers of Social Housing (RPSH) need to be assured that a property is allocated in accord with the current Allocations Policy and principles. Traditionally that has been to the person in greatest need, but new powers and changes may now give priority to, for example, those in employment. The priority for allocations may be different from place to place, but a constant is to guard against it not being obtained by deception or false statement. Checks at both the application and sign up stage of the re-let process are therefore essential. Verification checks at the point of access to social housing are undertaken to verify true personal circumstances, and family household details. These checks would usually be performed by an Allocations or Lettings Officer, during the housing application process. Further confirmatory checks in respect of indentify may also take place at the sign up interview. The RPSH may also hold a passport style photograph of the tenant on record. Photographs may be taken by housing staff or be provided directly by the applicant. Take a photograph of the tenant to hold on tenancy records. Whilst verification processes should be consistent and robust, any process must allow a degree of flexibility to support housing applications from individuals that may be unable to produce documents of the required nature. For example, individuals who may previously or currently be street homeless, and for whom the production of such documents would be extremely difficult. Procedures that are totally rigid in their nature can fall short of being open to all members of the community, particularly those that may already be marginalised, and verification processes should be sufficiently flexible to ensure no individuals are excluded from the application process. A similar approach can be used to these cases as is used for housing benefit verification, and in compliance with the Housing Benefit / Council Tax Benefit Security Guidance published by the Department for Work and Pensions. Identification for each person on the application First preference for proof of identity: Full UK or EU driving licence including photograph 10 year UK or EU passport with photograph EU identity cards UK identity card for foreign nationals / residence permit issued by the Home Office UK certificate of naturalisation BR2102, BR2103 or BR5899 letter confirming eligibility for the State Pension Current Child benefit/job seekers allowance book or card If none of the above are available, consider the following: Birth/marriage/adoption certificate Medical card with National Insurance number Certificate of HM forces employment

5 National Insurance card or number Student identity card P45, P60 or pay slip Proof of homelessness Eviction notice Notice to quit Letter from landlord/parent/friend/relative, if have been asked to leave or from employer if employment is linked Summons /orders or warrant These documents are not available for those that are street homeless Proof of residence Official and original letters and documents showing the addresses for the last five years, e.g. rent books, tenancy agreements, Council Tax demands, driving licence, bank statements Utility/household bills TV licence Medical card Correspondence from government departments such as DWP, National Health Service, Borders and Immigration Marriage certificate UK driving licence without photograph NFI check Credit Reporting Agency check

6 Proof of priority need Antenatal card or pregnancy certificate GP/hospital letter or medication details concerning a medical condition Children/child s full birth certificate Child benefit book Pension book Documents relating to care of a child where necessary, e.g. residency order/parental responsibility agreement Documents that confirm full time attendance at a school or college course Divorce papers Proof of employment, income and savings Employment contract and/or wage slips Building society book or bank statements DWP benefit books or evidence of a claim to the DWP Pension statement National Insurance card or number Jobseekers Allowance book or evidence of claim Record details of any documentation provided on the application and take copies. Documents may be forged and/or obtained illegally. Numerous private organisations provide document verification services. The Centre for the Protection of National Infrastructure good practice guide on Document Verification - targeted at pre-employment screening, is helpful as it provides advice and highlights the main security features present in a number of documents and the main methods used to forge such documents. It should assist staff in the detection of basic forgeries. The National School of Government and the UK Border Agency run training courses on document fraud. This Briefing was produced by the CIPFA Better Governance Forum Fraud Advisory Panel, with particular thanks to Lee Cadman Birmingham City Council, Cajetan Chukwulozie Essex County Council, Rachael Tiffen National Fraud Authority, Derek Elliott Audit Commission, Joanne Kent-Smith Chartered Institute of Housing, Greg Marks CIPFA BGF.

7 Greg Marks CIPFA Better Governance Forum No 1 Croydon Addiscombe Road Croydon CR0 0XT Greg.marks@cipfa.org.uk cipfa.org.uk Certificate No.