Support for the Very Long-Term Unemployed – pilot guidance
for Customer Compliance Officers
Purpose
1. This guidance is for customer compliance officers in the four trailblazer
Districts. It will assist Customer pilot officers when dealing with Long-Term
unemployed referrals.
2. This guidance supplements the existing customer compliance guidance
and must not be used in isolation.
Types of Customer Compliance referrals
High risk referrals
3. In addition to submitting an FRF to report an allegation of fraud, the
Customer Compliance team should follow procedures in the Customer
Compliance Risk Cases guidance and input the FRF to route locally
identified high risk referrals through FRAIMS as identified on the Risk
Priority List.
4. High risk referrals are recorded on FRAIMS as follows:
 Risk A - (New Claims) Pre-payment LTAHAW/CP;
 Risk B - (Current Claims) Post-Payment LTAHAW/CP;
 Risk C - Recently Separated;
 Risk D - Previously Self-Employed;
 Risk E - WFI Sanction Cases:
 Risk F - R Case Scans;
 Risk G - Ad Hoc Scans authorised by Operational Delivery Support
(ODS)
 Risk H – Community Care Grants (CCG)
CCG referrals
5. Referrals will be received by email to the Customer Compliance generic
inbox from Social Fund Decision Makers (SFDMs) for pre award CCG
application interventions. These referrals have a high risk of error and
must be visited before a decision on the application can be made. Only in
exceptional circumstances such as a PV marking can these cases be dealt
with by office interview. These referrals must not be overloaded.
6. Applications will be referred for a pre award visit when the Decision Maker
has decided to make an award and the value of the application is around
£500 or over and one of the following national risk criteria apply:
 the customer states three or more main household items have broken
down simultaneously or
 the customer is requesting replacement of all major household items
due to wear and tear or
 the customer alleges they have moved into unfurnished property and
have nothing and yet the move took place some time ago.
7. Referrals will be received on a proforma directly from the SFDM. The
CCO should complete the FRF. These referrals must be dealt with
urgently to minimise the impact on CCG clearance times.
FIS referrals
8. Referrals may be received via the Fraud Investigation Service (FIS), prior
to interview where information gathering/investigation finds that there is
insufficient information/evidence to support a sanction.
Disability Living Allowance (DLA) and Attendance Allowance (AA)
referrals
9. Referrals where DLA or AA only is in payment will not be downgraded
from FIS to Customer Compliance but returned directly by FIS to PDCS,
even when a criminal investigation has not taken place.
10. DLA or AA referrals where a Jobcentre plus benefit is also in payment,
such as Income Support or Jobseekers Allowance may be downgraded by
FIS but the Customer Compliance Officer will only deal with the Jobcentre
plus element. (See sections 06 on Interviews and 07 on Post Interview
Action if new and substantial information comes to light during the
interview that could affect DLA or AA.
Carers Allowance referrals
11. Where a Carer’s Allowance (CA) case has been downgraded from FIS, the
CCO must check that the case has been associated to the FRM PDCS
FSU Inbox on FRAIMS, see FRAIMS guidance - Cases with a PDCS
interest – Actions by Customer Compliance case owner.
12. If the case has not already been associated, the CCO must take action to
associate the FRM PDCS FSU Inbox themselves. Ensure that the activity
description field contains details of the CA in payment and the name and
contact details of the CCO. This ensures the CCO receives a copy of the
latest claim pack and case specific questions to support the CCO
interview.
13. Where the case has been routed directly to Customer Compliance via
FRAIMS and the case has a PDCS benefit interest, i.e. the offence may
have an affect on any PDCS benefits in payment, the CCO must associate
the case to the FRM PDCS FSU Inbox on FRAIMS, see paragraph 10.
Child/children not in the household referrals
14. If Department for Work and Pensions (DWP) benefits are in payment
because a child/children is/are in the household and a referral is received
alleging that the child/children is/are no longer living in the household, take
action as outlined in FRAIMS guidance - Child Dependency Exception
Routing.
15. If no DWP benefits are in payment for the child/children, action must still
be taken to ascertain whether the claimant is required to sign on.
Abroad Fraud referrals
16. Via FRAIMS, all FRFs with ‘Abroad Fraud’ selected will route to the
Abroad Fraud ‘in box’ in Edinburgh. Those cases that are unlikely to result
in a sanction will be handed off to Customer Compliance.
Long Term Unemployed referrals
17. Following an Ongoing Customer Management (OCM) interview with
someone who is long term unemployed, the case may be referred by a
Personal Advisor (PA) for a customer compliance intervention. These must
be entered on FRAIMS under ‘OCM’. The contact details of the PA will be
shown in the free text box of the FRF.
Training for Work Allowance referrals
18. Occasionally FIS may downgrade cases in circumstances where the
customer is claiming a Training for Work Allowance. These cases should
be accepted by Customer Compliance and appropriate action taken, even
though the Training for Work Allowance is paid under the Employment and
Training Act and is not classed as a benefit.
19. The allowance is based on the customer’s rate of JSA (IB) the day before
they began training (less 10p) plus the training premium. The customer is
still paid 10p of JSA (IB) in order for passported benefits to be claimed.
Please see Section 8 – Claiming an MVA for details of how to claim an
MVA in these cases.
Pension Service referrals
20. Currently FRAIMS is unable to distinguish Pension Service referrals from
all other referrals. These types of cases should only be routed to Customer
Compliance from FIS if the case is unlikely to result in a sanction. They
should not be sent to Customer Compliance at the outset.
21. Customer Compliance teams may receive a small number of Performance
Measurement referrals - High Suspicion Tracking (HST) cases for Pension
customers. These referrals must be actioned and not handed off to PDCS,
see paragraphs 15 to 21 for further information. They are identified by the
source type Performance Measurement Referral.
22. In all other cases, if the case scores insufficiently and is received by
Customer Compliance it should be passed to the relevant Pension Centre
to take action. The following action should be taken:
Step
Action
1
2
3
Print the FRF
Close the case on FRAIMS
Return the case to the relevant Pension Centre
GMS referrals
23. Via FRAIMS from the Database and Matching Service (DMS) via
Generalised Matching Service (GMS), as per the national GMS Rules list.
GMS custodial referrals
24. GMS Referrals are received for customers who have received a custodial
sentence. The Compliance Support Officer (CCSO) must immediately sort
the cases received into cases paid by direct payment or by cheque
payment.
Action to take when customer has been or is due to be released from
prison
25. If the prisoner has been released from prison or is due to be released
within 4 weeks, the referral must not be closed without interview. If
appropriate, BF the case to the release date and arrange for the interview
to take place, taking into consideration that the customer has been in
prison.
26. Take the following action for customers paid by Direct Payment:
Step
Action
1
if the customer is in receipt of Jobseekers Allowance (JSA),
confirm if evidence of signing has been input after sentencing
took place which suggests an active impersonation fraud;
2
confirm ongoing imprisonment and once received, record on
FRAIMS as per “New Case Received – Case Owner Actions’
instructions in the FRAIMS guidance. If appropriate, complete
a FRF with the offence type of “ID fraud”.
3
for all other benefits, confirm ongoing imprisonment
4
Refer the case to the Benefit Delivery Centre (BDC) via email, for termination and overpayment action. Send hard
copies of documents to the BDC and record the activity on
FRAIMS as per ‘Benefit Decision, FIS and Customer
Compliance’ instructions in the FRAIMS Guidance.
5
notify the Pension, Disability and Carers Service of the
custodial sentence if the customer is also in receipt of
Pension Credit.
27. Take the following action for customers paid by cheque payment:
Step
Action
1
if the customer is in receipt of JSA, confirm if evidence of
signing has been input after sentencing took place which
suggests an active impersonation fraud;
2
confirm ongoing imprisonment and once received, record on
FRAIMS as per “New Cases Received – Case Owner
Actions” instructions in the FRAIMS guidance. If appropriate,
complete a PPQ with the offence type of “ID fraud”.
3
if the customer is in receipt of JSA and only advance
evidence payment has been made, refer the case to the BDC,
via e-mail, for termination and overpayment action. Send hard
copies of documents to the BDC and record the activity on
FRAIMS as per ‘Benefit Decision, Suspension and
Reinstatement’ instructions in the FRAIMS guidance.
4
for all other benefits consider if the number of cheques issued
since imprisonment suggests the active collusion of a third
party to maintain the claim. Contact FIS (O) for advice; and
5
notify the Pension, Disability and Carers Service of the
custodial sentence if the customer is also in receipt of
Pension Credit.
Follow up action
28. To prevent further payments being made, follow up action must be taken
on all GMS Custodial cases. Take the following action:
Step
Action
1
track the progress of termination action on each case. The
BDC should close cases on the same day as receiving the email notification from the CCSO;
claim the appropriate outcomes and close the case as per
‘Closing a Fraud/Customer Compliance Case’ instructions in
the FRAIMS guidance.
2
Performance Measurement - High Suspicion Tracking Referrals
29. Performance Measurement Referrals High Suspicion Tracking (HST)
cases now go through FRAIMS and are routed according to the
information contained within the FRF. Appropriate referrals are sent
directly to the Customer Compliance Inbox.
30. If HST referrals contain sufficient information to pursue a sanction they are
automatically routed to FIS by FRAIMS. If, prior to interview, it becomes
clear that a sanction is not the likely outcome, the referral is then routed by
FIS to Customer Compliance for action. Once received by Customer
Compliance they must be actioned as a matter of priority.
31. Customer Compliance Managers must allocate HST referrals timeously via
‘My Team’s Incidents’ on FRAIMS. They should:
Step
Action
select ‘My Team’s Incidents’ in Incident List view;
select ‘Query’ button – a yellow bar will appear across the
screen;
3
click on the yellow bar under the heading ‘Source Type’ –
using the drop-down arrow select ‘Performance Measurement
referral’.
32. By selecting the ’Go’ button will produce a list of Performance
Management referrals allocated to that team. Scroll along the columns
until ‘Incident Owner’ header is located. Any Performance Measurement
referral not allocated to an individual owner will display the team inbox
number.
33. To allocate an ‘unallocated’ case to a CCO, select the hyperlink on the
‘Case Name’ – this should move the user to the ‘Cases’ screen for that
individual case. Normal allocation action can be taken. To go back to a list,
use the browser back arrow.
34. On receipt, the CCO must give priority to Performance Management
referrals allocated. Users should:
1
2
Step
Action
select ‘My Incidents’ to locate a Performance Measurement
referral;
2
select ‘Query’ button – a yellow bar will appear across the
screen;
3
click on the yellow bar under the heading ‘Source Type’ –
using the drop-down arrow select ‘Performance Measurement
referral’.
35. Selecting the ‘Go’ button will produce a list of Performance Management
referrals allocated to that individual user.
36. When the CCO identifies the case via FRAIMS they must associate the
PM Single Point Of Contact (SPOC) to the Case, see FRAIMS guidance –
FIS or Customer Compliance action when a PM Case is received. This
ensures the PM SPOC is able to view and track PM Cases and Outcomes
on FRAIMS.
37. Referrals should be treated in the same way as any other Customer
Compliance case.
1
38. In cases where the PM team need to contact the CCO, this is facilitated
via the FIS Single Point of Contact (SPOC) based at Nottingham (FRAIMS
Position-FRM PM SPOC).
Local Authority referral
39. If Customer Compliance activity is appropriate, consider whether the
referral falls into one of the five categories that must be offered to the LA
below. If the Customer Compliance team already have an agreement in
place to not offer referrals to the LA, do not send them.
 undeclared property – address not known (not current address of
customer);
 abroad – having regard to appropriate benefit regulations;
 boarders in household;
 non-dependant in household – customer in receipt of IS and SDP in
payment;
 not at given address.
40. If the Customer Compliance team have a local agreement in place not to
offer referrals to the LA, do not send them.
41. If the referral falls into one of the five categories, take the follow action:
Step
Action
1
Print the FRF and send the original referral to the LA in
accordance with locally agreed arrangements, where
appropriate, on an FPA1 and record the activity on FRAIMS
as per “Customer Compliance Cases with a Local Authority
Interest” section within “New Case Received – Case Owner
Actions” instructions in FRAIMS guidance.
Allow the LA 10 days to turnaround the case.
BF 14 days for a response from the LA on the FPA1.
If no response is received after 14 days, commence
Customer Compliance action.
If the LA return the FPA1 and have accepted the case,
update notepad and close the case on FRAIMS.
2
3
4
5
Local Authority investigations
42. Local Authorities (LA) can access the Notepad screen of benefit payment
systems. If they identify from checking Notepad that Customer Compliance
activity is taking place and they have an on-going investigation, the LA will
contact the Customer Compliance team and ask that all Customer
Compliance activity be terminated.
43. Action must be taken to close the case on FRAIMS.
44. The LA may continue the investigation and will invite FIS to jointly
investigate and interview under caution, which could potentially lead to a
sanction. If the LA request any documentation gathered previously by the
Customer Compliance team it can be provided.
45. If the LA require information from a previous CC case they should request
the information using the FPA1 form, as agreed in the procedures for joint
working with FIS. LAs should not contact CC teams directly for documents.
FIS will make local arrangements for the recovery of the Customer
Compliance file.
Credits only cases
46. Credits only cases must be accepted for Customer Compliance activity if
appropriate. If the CC interview results in the disallowance of the credit an
MVA or overpayment cannot be claimed but a positive outcome must be
recorded on FRAIMS, see 07 Recording Outcomes – Credit Only Cases
within this guide.
JSA Contributory cases
47. Living together referrals for JSA Contributory benefit, JSA (C) only cases
may be received even though there may be no risk at the time as living
together doesn’t affect entitlement. However, action should be taken by
the CCO to set a future case control in JSAPS or ISL Legacy dialogue to
undertake Customer Compliance action at the six month stage, when the
customer transfers onto JSA Income Based (IB).
Service Personnel and Veterans Agency (SPVA) referrals
48. Customer Compliance does not undertake activity for Service Personnel
and Veterans Agency (SPVA) referrals. These should be returned to the
originating SPVA office if received.
49. Where the claimant is in receipt of both SPVA and DWP benefits, a copy
of the FRF and other relevant information must be printed off and sent to
the relevant SPVA Department. Record the details of the handover to
SPVA on the FRAIMS Case, appropriate Customer Compliance action
should then continue on the DWP element.
Instrument of Payment (IOP) referrals
50. Instrument of payment (IOP) referrals are not dealt with by Customer
Compliance and should returned to the sender if received.
New FRAIMS Incident received
51. When a Fraud Referral Form (FRF) is received into FRAIMS the system
will check to see if any live Incidents / Cases are already held for the same
suspect.
52. If live Incidents / Case are found the new incident (referral) will be
forwarded to the Case owner of the live Incident / Case.
53. Customer Compliance Officers and Managers must ensure that any
matching Incident(s) received are actioned on a daily basis and either:
 Linked to the live Case,
 Re-routed, or
 Closed.
54. Where a claimant has been notified of an interview and a matching
Incident is received prior to the actual interview, the CCO should discuss
both referrals at the same interview.
55. If both new and substantial information is received prior to the interview
the CCSM will decide whether the case is suitable to refer to FIS, see
FRAIMS guidance - New and Substantial Information received - Customer
Compliance Actions.
56. For details on how to identify matching incidents that have been received
and the actions to be taken, see FRAIMS guidance – Matching to Existing
Incident and Cases
 Single Incident Found
 Single Case Found
57. If the new Incident has the Source type of ‘Proactive Investigation’ the new
Incident must not be linked to the Customer Compliance Case, create an
activity on the Incident and send the new Incident to the owner of the fraud
Master file, see FRAIMS guidance – Proactive Investigation Incident
received.
Duplicate referrals
58. If a new Case is received on the same matter for a claimant, within a 3
month period, the Customer Compliance Support Manager (CCSM) can
decide not to accept the case for Customer Compliance action, for
example, a duplicate referral is received for a claimant alleged to be
working and the description of the work details are identical to the previous
Case. The CCSM should close the Case as a duplicate referral.
59. The CCSM will need to take action to close the case where Customer
Compliance activity is no longer appropriate.
Undertaking the Customer Compliance interview
60. The aim of the Customer Compliance interview is to:

discuss the case having regard to the reason for the referral

obtain accurate information from the claimant

conduct a full review of the claimant’s circumstances

reinforce claimant responsibilities.
Action prior to the interview
61. Prior to the interview it is important that the Customer Compliance Officer
(CCO) removes all sensitive material from the case documents and
completes form RM7 to confirm that this check has been carried out. This
will ensure that the identity of the informant is not revealed to the claimant.
Definition of Sensitive material
62. The official definition of sensitive material is:
‘Any material, the disclosure of which it is believed will give rise to a
real risk of serious prejudice to an important public interest.’
63. The types of sensitive material most frequently falling into this category
are:
 Allegation of non-compliance. This could be a letter or other information
that could identify the person making the allegation
 material relating to national security;
 material given in confidence, that is, material that has been supplied on
condition the contents will not be disclosed or not disclosed at least until a
subpoena has been served on the supplier, for example information from a
bank official or a doctor.
These examples are not exhaustive and each case should be considered on
its merits.
During the Interview
64.
At the interview, the CCO will take the following action:
Step
Action
1
Introduce themselves using their identity card for home visits, or
their identity card or appropriate name badge for office visits.
Confirm the claimant’s identity. Suitable documents to confirm
2
3
4
5
identity are the following that state the claimant’s name and
address:
 passport
 driving licence
 utility bill
 rent agreements
 bank statements
 identity card.
If the claimant cannot provide evidence of their identity, cross
check the most up to date personal information held on
Departmental records with the claimant and record details of the
checks on the file. This must also be done if the interview is
conducted over the telephone.
If it is an office interview, offer to reimburse the claimant’s travel
expenses. For Job Seekers Allowance (JSA) claimants, this will
only apply if it is not their normal day of attendance. For guidance
on claimant travel expenses see, the DWP Corporate Customer
Affairs Guidance.
State the purpose of the interview. In cases where there is
information suggesting the case is or has been paid incorrectly
inform the claimant that this specific aspect will not lead to a
sanction. Benefit that has been overpaid may be repayable. If
Disability Living Allowance (DLA) or Attendance Allowance (AA) is
in payment as well as a Jobcentre Plus benefit, such as Income
Support or Jobseekers Allowance, the claimant must only be
interviewed about the Jobcentre Plus benefit. If new and
substantial information is obtained during the interview and the
CCO has grounds for suspecting that the DLA or AA claim is in
doubt, a new FRF must be completed and referred to PDCS FSU
via FRAIMS.
Conduct a robust and challenging interview with the claimant by:
 asking questions in order to establish the truth, checking the
claimant’s understanding of their claim to benefit
 establishing the current circumstances of the claimant to
enable a Decision Maker (DM) to make a decision on
entitlement to benefit which may include an
overpayment/underpayment of benefit
 presenting the details of the Fraud Referral Form (FRF) or
potential incorrectness, without revealing the source, or
disclosing material marked or deemed sensitive
 inviting and listening carefully to the response from the
claimant
 questioning further to establish the facts around benefit
entitlement (for example, when did the alleged fraud/error
start? How long has it been going on for? How often?)
 not being bound to accept the first answer given
 completing the CP2 (LT) where appropriate
 warning the claimant about their conduct and that any future
failure to declare a change in circumstances may lead to




65.
more serious action being taken by the department
asking the claimant for relevant documentary evidence;
limiting questions to current benefit entitlement where new
and substantial information is received
obtaining a statement on form MF47, including where the
claimant has admitted that they knowingly gave false
information or knowingly failed to declare a change of
circumstances; See Section 5 – Completing the MF47
statement.
making a brief record of the interview. All notes made need
to follow Data Protection Act 1998 principals and should be
fact, not opinion.
The summary of the interview must be recorded on FRAIMS in
accordance with paragraph 1 of Post Interview Action.
Action required for specific circumstances
Living Together cases only
66.
Occasionally the claimant may ask for some time to consider their
circumstances in discussion with the alleged partner. The Customer
Compliance Officer (CCO) should make a further appointment to
interview the claimant within 10 calendar days of the initial interview.
67.
They must obtain a statement detailing the claimant’s current
circumstances and their wish to discuss with the alleged partner. If the
claimant reports a change of circumstances that leads to benefit being
adjusted before the date of the second interview, this contact would fall
within the causal link guidance.
68.
At the second and final interview a further statement should be
obtained detailing the claimant circumstances.
Community Care Grant cases only
69.
The purpose of the Community Care Grant (CCG) visit is to confirm
with the claimant:

their circumstances are as stated on the application,

the reason for the application,

their response to any questions raised by the Social Fund
Decision Maker (SFDM).
70.
If appropriate the CCO should challenge the claimant’s response.
71.
If the claimant is in receipt of benefit the CCO must also undertake a
review of the claimant’s claim. (Except in Pension Credit cases) If a
change is identified this should be dealt with on the same case and
new Fraud Referral Form (FRF) is not required.
Key Questions from the Social Fund Decision Maker
72.
The SFDM will supply key questions on the referral for the CCO to ask
the claimant. The SFDM should only list the items and ask questions
about items they are considering an award for.
73.
Items must be listed separately such as cooker, washer, table and
chairs, holiday. For clothing it is sufficient to give a general description
for example winter clothes for applicant, nightwear for partner, etc. The
74.
75.
76.
77.
78.
79.
80.
generic description kitchen utensils, pots and pans, or crockery can
also be used.
When considering what questions to ask the SFDM will be aware that it
is not reasonable to ask the CCO to see items such as beds and
bedding. The CCO must decline any offer by the claimant see these
items but should use their discretion when the claimant lives in a bed
sit. This is a Health and Safety requirement.
The CCO can still ask the customer some of the following questions;

how long the customer has had the bed,

what's wrong with it,

how did it break/get into a poor condition,

why haven't they got protective covers, etc.
It is considered reasonable for the CCO to ask to see items that the
claimant states have broken down such as a cooker or washer. If the
claimant refuses this must be noted on the pro-forma.
CCOs should ask the customer to demonstrate whether the item is
working or not and must record a factual statement on the MF47
stating what was observed and what the customer said about its
condition.
CCOs must not check electrical/gas items or give a technical opinion
on the usability of such items. They are not required to take
measurements for carpets and curtains and must ask the claimant to
do so.
Claimants cannot add further items to the application therefore CCOs
will need to advise claimants to make a further application if
appropriate.
CCOs should not indicate to the claimant what the final decision on the
application will be.
Long-Term Unemployed Referrals
81.
A Personal Advisor (PA) may refer a case for someone who is longterm unemployed following an Ongoing Customer Management (OCM)
interview. The CCO must carry out a robust and challenging interview
with the customer in the same way that all CC interviews are
conducted the difference being that there will be no suggestions of
areas of incorrectness on the FRF.
82.
The purpose of these interventions is to ensure that the customer
receives the correct amount of benefit. If the CCO identifies
incorrectness these should be referred to the DM in the normal way.
Independent Living Funds
83.
If the claimant declares any payments received from the following
funds funded by the Independent Living Fund, they should be informed
that they will be totally disregarded for benefit purposes:

MacFarlane Trust

MacFarlane (Special Payments) Trust

MacFarlane (Special Payments – No. 2) Trust Fund

Eileen Trust

Skipton Fund

London Bombings Relief Charitable Fund.
84.
For further information see Capital Investigations – Independent Living
Funds in the Fraud Guide.
Doubts regarding identity
85.
If there is any doubt regarding the identity of the claimant continue with
the interview. Do not discuss with the claimant your suspicions
concerning the claimant’s identity. Complete an FRF as per ‘Manager
Agrees New Referral Required - Interview Taken Place’ instructions
within the ‘New and Substantial Information received - Customer
Compliance Action’ section in the FRAIMS guidance following the
interview providing full details of the doubt and submit via FRAIMS for
consideration of an investigation.
Interpreters required at the interview
86.
The claimant has the right to request an interpreter at the interview.
The CCO should also arrange an interpreter if they feel there is a
communication difficulty with the claimant and the interview cannot
proceed.
Other person present at the interview
87.
The CCO should have regard to the needs of the claimant if they think
they may not understand what is happening at the interview.
88.
This may include claimants who have a mental health condition or
learning difficulty who are incapable of understanding the significance
of questions put to them or their replies. These claimants may require
the presence of an appropriate adult at the interview. The appropriate
adult must be informed that they are not expected to act simply as an
observer. Their role is:
 to advise the person being interviewed
 to observe whether the interview is being conducted properly and
fairly
 to facilitate communication with the person being interviewed.
89.
The definition of an appropriate adult is:
 a relative, guardian or other person responsible for their care or
custody
 someone who has experience of dealing with mentally disordered
or mentally handicapped people who is not employed by the
organisation
 failing either of the above, some other responsible adult aged
eighteen or over who is not employed by the organisation.
90.
If required, the CCO should ask the claimant if they would like the
interview re-arranging to an alternative date to enable the attendance
of the appropriate adult. If the person says that they do not want the
interview re-arranging or to be accompanied by an appropriate adult,
the interview should proceed. The fact that the person declined the
presence of an appropriate adult should be noted on FRAIMS as per
‘Set up an Interview’ instructions within the ‘Arrange and Conduct an
Interview’ section in the FRAIMS guidance.
Persons at risk identified at the interview
91.
If at the interview there are indications that a child or vulnerable person
is at risk of injury, ill treatment or neglect, take appropriate action as
outlined in guidance available on the Vulnerable Customer hub.
Domestic violence
92.
If during the course of an interview with the claimant or partner they
indicate that they have any concerns or that they are victims of
domestic violence, the CCO must always signpost them to the most
appropriate help available and agree with them how they would like to
receive information about the help available.
93.
If the claimant has access to the internet, signpost them to the Direct
Gov website to enable them to get the expert help and advice they
need or details can be printed from the site and issued to the claimant.
If it is not appropriate for the claimant to use the Direct Gov website
advise them to access other available help through the Citizens Advice
Bureau (CAB), their family doctor or other local organisation or
domestic abuse helplines.
94.
When preparing for a visit, CCOs will need to be aware of the
information contained within this website. It is not necessary to carry
these details at all times, but if required the CCO should agree how the
claimant would like to receive this information.
Recording of interviews
95.
The claimant may ask to record the interview. Requests to do so must
be accepted. The same principles apply in Scotland.
96.
For more information, see Department for Work and Pensions
Corporate Customer Affairs website.
Review of the claimant’s current circumstances
97.
Where the claimant declares a change of circumstance, form A2
should not be routinely completed as most of the information may not
have changed. Completion of the A2 is at the discretion of the CCO
and the reason must be recorded on FRAIMS as per ‘Effective Visit’
instructions within the ‘Visits’ section in the FRAIMS guidance and the
MF47 statement.
98.
When reviewing a claimant’s current circumstances, it is essential that
details of a claimant’s phone number(s) (mobile/landline) are
confirmed. Any changes must be reported at the earliest opportunity,
to:

Benefit Delivery Centre (BDC) for legacy purposes

Jobcentre for Labour Market System purposes.
Documentary evidence
99.
The claimant must be asked to provide all the relevant documentary
evidence to enable the Decision Maker (DM) to decide benefit
entitlement and/or overpayment calculation. Allow the claimant 10
working days to provide the evidence and warn them that failure to do
so may affect benefit entitlement. Record this activity on the FRAIMS
case.
100. If the claimant does not provide the relevant evidence within 10
working days contact the information provider direct. This is
101.
102.
103.
104.
105.
appropriate where the claimant has signed an MF47 Statement
declaring they have been working.
If the information is not provided by the information provider within a
reasonable amount of time, take appropriate action as in documentary
evidence not provided.
In cases where the claimant states that they have been working but will
immediately finish, the claimant is required to:

provide documentary evidence of dates of employment within 10
working days

make a new claim to benefit.
Additionally, if a referral suggests the claimant has undeclared capital
in the form of savings and at interview denies they have an account
with the bank/building society on the referral, the bank/building society
in question must not be contacted.
In cases where the claimant admits to a change in circumstances,
advise the claimant that the case will be referred to the DM and benefit
entitlement may be suspended immediately until the documentary
evidence is provided.
If further information or confirmation is required for benefit correctness
or overpayment calculation, take the following action:
Step
Action
1
For bank details complete form A42 and send to the relevant
Bank/Building Society. Record this activity on FRAIMS and set a
BF date on FRAIMS for the return of the A42 as per ‘Activities’
instructions in the FRAIMS guidance. If the claimant refuses to
sign the A42 obtain as much information as possible from the
claimant about their savings and include the details on the MF47.
If the A42 is not returned, record the details on FRAIMS as per
‘Activities’ instructions in the FRAIMS guidance and take follow
up action with the financial institution. Forward the details to the
DM. Note that use of Social Security Fraud Act Powers is not
appropriate to obtain details from the financial institution. Under
no circumstances should the MF47 be issued to banks/building
societies.
If the Bank/Building Society refuses to accept the A42, contact
the bank to try and resolve this locally. Explain that CCOs can
only obtain bank account information using the A42. If the bank
still refuses to cooperate, pass the case with the information
held, to the DM for a decision to be made on continued benefit
entitlement.
Create an activity and B/F on FRAIMS to record that the case is
booked out to the DM/BDC pending a decision being made by
the DM on future benefit entitlement as per ‘Benefit Decision, FIS
& Customer Compliance’ instructions in the FRAIMS guidance.
For all other information claimant consent is required by inclusion
of authority on form MF47.
2
3
4
Contacting the employer
106.
107.
CCOs must never contact an employer before interviewing the
claimant.
If, during the interview, the claimant denies they have been working the
employer must not be contacted. Any attempts to do so are in breach
of Article 8 of the European Convention on Human Rights. If at
interview the claimant admits to working and gives permission the
employer can be contacted.
Dealing with Bank Charges
108. Customer Compliance teams can pay for bank statements/charges but
should first consider the following:

Ask the claimant, it is their responsibility to provide sufficient
evidence to support their claim. If current entitlement is in doubt,
the DM may agree to suspend the claim on the information or
admittance they have.

Depending how much the overpayment will be, it may not be
worth the cost of paying for them.

As a last resort, agree to pay and pass through to the Finance
team.
Informing the claimant about Jobcentre Plus services
109.
The CCO has the responsibility to inform the claimant of other
Jobcentre Plus services available to them, for example an appropriate
Personal Adviser (PA).
Claimants in receipt of Jobseekers Allowance
110. The CCO may decide that More Frequent Attendance (MFA) would be
appropriate for the claimant. The following are examples of when MFA
could be considered:

Appearance of the claimant suggests they are working but this
was not established during the Customer Compliance interview.
This would include oil or paint on hands that could indicate they
may be working in car maintenance or painting and decorating,

Claimant failed to keep a Customer Compliance interview
without a valid reason,

Claimant was in a rush to complete interview.
Claimant in receipt of other benefits
111. The CCO should consider referring non-JSA claimant to an appropriate
PA. This should be done by completing an A6/minute sheet and issuing
it to the relevant Jobcentre. The Jobcentre will then arrange an
appointment with the appropriate PA.
Bringing the interview to a close
112.
At the end of the interview take the following action:
Step
Action
1
Ensure that the claimant has completed, signed and dated all the
relevant documentation.
Inform the claimant of the next steps, for example referral to Debt
Management.
2
3
Give the claimant a copy of the MF47 statement if they request
one. If the interview has been conducted via a home visit inform
the claimant that a copy will be sent by post.
Claimant refuses to comment
113. If the claimant refuses to comment, after you have asked initial
questions, take the following action:
Step
Action
1
2
Terminate the interview.
Update the interview activity on FRAIMS as per ‘Effective Visit’
instructions within the ‘Visits’ section in the FRAIMS guidance
along with anything the claimant said prior to asking questions.
Refer the case to the Customer Compliance Manager (CCM).
The CCM should consider referring the case to the DM for a
decision to be made on future benefit entitlement. Ensure that all
sensitive material has been removed from the file and the RM7
has been updated before referring the case to the DM.
Create an activity on FRAIMS to record that the case is booked
out to the DM/BDC as per ‘Benefit Decision, FIS & Customer
Compliance’ instructions in the FRAIMS guidance.
3
4
5
Request for the CCO to leave the claimant’s home
114.
The claimant can request the CCO to leave their home at any point
during the interview. The CCO must do so immediately if asked by the
claimant. Inform the CCM and record the details on FRAIMS as per
‘Effective Visit’ instructions within the ‘Visits’ section in the FRAIMS
guidance.
Interviews conducted by telephone
115.
For interviews conducted by telephone, the CCO must take the
following action to conclude the interview:
Step
Action
1
Inform the claimant that the MF47 statement and form A42, if
appropriate, will be posted for them to sign and return along with
any relevant documentary evidence, immediately following the
interview. Ask the claimant to return the forms within 5 working
days.
If the claimant has reported a change in circumstances which
effects current benefit entitlement, notify the DM to review
entitlement immediately, following guidance at step 8 below, do
not wait for the MF47 to be returned.
Record all action on FRAIMS as per ‘Customer Attends the
Interview’ instructions within the ‘Arrange and Conduct an
Interview’ section in the FRAIMS guidance and retain in the file
along with a copy of the MF47 and A42 where appropriate.
Set a 5 working day B/F date on FRAIMS as per ‘Changing a
Due Date’ instructions within the ‘Activities’ section in the
FRAIMS guidance.
Send the MF47 and A42, if appropriate to the claimant.
2
3
4
5
6
7
8
9
10
11
12
13
14
If the MF47 and A42 have been sent to the claimant and have
not been returned within 5 working days contact the claimant to
remind them to return the documents. Record the claimant
contact activity on FRAIMS as per ‘Manually Creating Activities ’
instructions within the ‘Activities’ section in the FRAIMS
guidance.
Set a further 5 working day B/F date and note FRAIMS as per
‘Changing a Due Date’ instructions within the ‘Activities’ section
in the FRAIMS guidance that the claimant has been contacted.
If a reply is not received by the second B/F date, complete form
LT54 outlining details of the case to enable the DM to make a
decision on the case and to arrange to make any necessary
benefit adjustments. Ensure the LT54 is fully complete as the DM
will return forms with information missing.
Where a potential overpayment has been identified, fully
complete form Ref2 and forward with the LT54 and copies of all
relevant documents (i.e. wage slips etc.) to the DM for a decision
to be made on the case. For more information, see Overpayment
Referral Guide for Customer Compliance.
Before referring the case to the DM remove all material marked
sensitive and complete the RM7 to state the check has been
completed.
Pass the case to the Customer Compliance Support Manager
(CCSM) for them to complete the final sensitive material check.
Pension, Disability & Carers Service (PDCS) cases must not be
sent direct to the DM, these must be returned to the PDCS
Operational Intelligence Unit.
Create an activity on FRAIMS to record that the case is booked
out to the DM/BDC as per ‘Benefit Decision, FIS & Customer
Compliance’ instructions in the FRAIMS guidance.
Take the appropriate action once a decision has been made on
the case and has been returned from the DM/BDC.
Claimant fails to attend the interview
116.
If the claimant fails to attend or be available for an office interview a
second interview must be arranged.
Failing to attend a second interview
117. If the claimant fails to attend or be available for the second interview
the CCO must take the following action:
Step
Action
1
If the claimant has a good reason not to attend, rearrange the
interview and update the interview activity on FRAIMS as per
‘Customer Fails to Attend an Interview’ instructions within the
‘Arrange and Conduct the Interview’ section in the FRAIMS
guidance.
If the claimant does not have good reason, complete form LT54
outlining the details of the case to enable the DM to make a
decision on the case and to arrange to make any necessary
benefit adjustments. The LT54 must be fully completed as the
2
3
4
5
6
7
8
DM will return forms that have information missing.
Where a potential overpayment has been identified, fully
complete form Ref2 and forward with the LT54 and copies of all
relevant documents, e.g. wage slips, etc to the DM for a decision
to be made on the case. See Overpayment Referral Guidance for
Customer Compliance.
Before referring the case to the DM remove all material marked
sensitive and complete the RM7 to state the check has been
completed.
Pass the case to the CCSM for them to complete the final
sensitive material check.
DCS cases from PDCS must not be sent direct to the DM, these
must be returned to the DCS Operational Intelligence Unit.
Create an activity on FRAIMS to record that the case is booked
out to the DM/BDC as per ‘Benefit Decision, FIS & Customer
Compliance’ instructions in the FRAIMS guidance.
Take the appropriate action once a decision has been made on
the case and has been returned from the DM/BDC as per
‘Benefit Decision, FIS & Customer Compliance’ instructions
within the FRAIMS guidance.
Ineffective first home visit
118.
If the visit to the claimant’s address is ineffective, the CCO must take
the following action:
Step
Action
1
Complete and leave form A16A and arrange a further visit, an
A16A CCG should be used for CCG visits. The original visit
activity must be updated on FRAIMS and a new activity created
as per ‘Ineffective Visit’ instructions within the ‘Visits’ section in
the FRAIMS guidance. Do not make neighbourhood enquiries
about the claimant and their whereabouts.
There may be occasions where a second visit is not appropriate,
for example the property is unoccupied. In these cases, complete
form LT54, outlining details of the case, to enable the DM to
make a decision on the case and to arrange to make any
necessary benefit adjustments. Ensure the LT54 is fully
completed, as the DM will return forms that have information
missing.
Where a potential overpayment has been identified, fully
complete form REF 2 and forward with the LT54 and copies of all
relevant documents, e.g. wage slips, etc to the DM for a decision
to be made on the case. For more details see the Overpayment
Referral Guide for Customer Compliance.
Before referring the case to the DM remove all material marked
sensitive and complete the RM7 to state the check has been
completed.
Pass the case to the CCSM for them to complete the final
sensitive material check.
DCS cases from PDCS must not be sent direct to the DM, these
2
3
4
5
6
7
8
must be returned to the DCS Operational Intelligence Unit.
Create an activity on FRAIMS to record that the case is booked
out to the DM/BDC as per ‘Benefit Decision, FIS & Customer
Compliance’ instructions in the FRAIMS guidance.
Take the appropriate action once a decision has been made on
the case and has been returned from the DM/BDC as per
‘Benefit Decision, FIS & Customer Compliance’ instructions
within the FRAIMS guidance.
Ineffective second home visit
119. If the claimant has a good reason for not being available, arrange an
interview at a mutually convenient time. Update the activity on FRAIMS
and create a new activity for interview as per ‘Ineffective Visit’
instructions within the ‘Visits’ section in the FRAIMS guidance.
120. If the claimant fails to be available for the second visit without good
reason, the CCO must take the following action:
Step
Action
1
Complete and leave form A16A or A16A CCG to confirm that a
second visit was made and update FRAIMS as per ‘Ineffective
Visit’ instructions within the ‘Visits’ section in the FRAIMS
guidance.
Complete form LT54 outlining details of the case to enable the
DM to make a decision on the case and to arrange to make any
necessary benefit adjustments. Ensure the LT54 is fully
completed, as the DM will return forms that have information
missing. For CCG risk H referrals the CCO should return the
referral pro-forma to the SFDM to make a final decision on the
application.
Where a potential overpayment has been identified, fully
complete form Ref2 and forward with the LT54 and copies of all
relevant documents, e.g. wage slips, etc to the DM for a decision
to be made on the case. For more details see the Overpayment
Referral Guide for Customer Compliance.
Before referring the case to the DM remove all material marked
sensitive and complete the RM7 to state the check has been
completed.
Pass the case to the CCSM for them to complete the final
sensitive material check.
Carers Allowance cases must be returned to the PDCS
Operational Intelligence Unit and not direct to the DM.
Create an activity on FRAIMS to record that the case is booked
out to the DM/BDC as per ‘Benefit Decision, FIS & Customer
Compliance’ instructions in the FRAIMS guidance.
Take the appropriate action once a decision has been made on
the case and has been returned from the DM/BDC as per
‘Benefit Decision, FIS & Customer Compliance’ instructions
within the FRAIMS guidance.
2
3
4
5
6
7
8
Recording Customer Compliance outcomes
121.
Customer Compliance outcomes are:

claim to benefit closed with a Monetary Value of Adjustment
(MVA) and/or overpayment/underpayment;

claim continues but a change of circumstances results in MVA
and/or overpayment/underpayment; and

no change.
Customer Compliance action
122. The Customer Compliance Support Officer (CCSO) will receive all
cases returned by the Decision Maker (DM)/Benefit Delivery Centre
(BDC)/Overpayment Referral Team (ORT). Once the case has been
received, the outcome must be recorded on FRAIMS. Where more
than one benefit is concerned all decisions must be recorded on
FRAIMS.
Recording the case outcome on FRAIMS

Customer Compliance outcomes should be recorded on
FRAIMS as one of the following only:

Outcome

Positive Compliance

No Result
Outcome result

Abandoned

Benefit/grant decrease (the word grant will not be displayed in
the outcome result field)

Benefit/grant Increase(the word grant will not be displayed in the
outcome result field)

Decrease & Overpayment

Overpayment Only (should not be used for CCGs)

Increase & Underpayment

Underpayment Only

No Change

External Handoff

Cleared before receiving case

User error

Duplicate referral

MIDAS Data Error
Exceptionally there will be cases where the outcome result is an
overpayment for past benefit and an increase for the current benefit in
payment.
Date of outcome
123. Today’s date must be input in the date of outcome field. This date must
be entered in order for the outcome to count and correct MI is
recorded. If a past date is used or the date the case is closed, the
outcome will not be counted.
124. A date of outcome is entered when either an MVA is input, even if the
case is being referred for Overpayment action or when an
Overpayment only case is referred to CRT. When the Overpayment
125.
126.
details are returned, they are entered on FRAIMS. To prevent double
counting, the date of outcome must not be changed.
For Community Care Grant referrals the date of change is the date it is
returned from the SFDM.
MVA/overpayments and underpayments are likely to be recorded at
different times within the process.
Abandoned definition
127. The outcome result abandoned only applies to cases in the following
circumstances if:

the claimant has gone abroad;

the FRF/allegation is malicious;

the claimant is deceased or information held that the claimant
is terminally ill, or

the claimant’s claim to benefit is defective.

The claimant’s benefit will not be affected by the allegation, (ie,
allegation of LT and claimant is in receipt of IB, DLA, JSA(C) or
ESA(C) only).

inappropriate referrals (ie. cases which should not have been
referred or accepted by Customer Compliance). See Section 11
– Validation failure examples.

the referral is a GMS rule ESIR001, ISIR001 and ISIR008 or
JSIR001 and JSIR008 (merged July 2010), tax year 08/09 or
before, and the customer is not in receipt of benefit/the claim is
dormant

the referral is in respect of a previous claim and it has not been
possible to interview the claimant or obtain sufficient information
to enable a Decision Maker (DM) to make a decision. This would
include those cases where there has been no response to
appointment letters and the CCO does not have sufficient
information to enable a DM to make an overpayment decision

In long-term unemployed cases if there is an on-going fraud
interest.
128. The reason to abandon any case must be discussed and agreed with
the CCM/CCSM in all cases.
129. The decision for abandoning any case must be noted in the FRAIMS
description box by the CCO.
Cleared before receiving case definition
130. When the IT system is checked upon receipt of a referral and it shows
that the customer has already reported the change to the BDC or the
BDC are aware of the change, have closed the claim down and are
dealing with any overpayment issues, the outcome result “cleared
before receiving case” should be used.
User error definition
131. Cases arriving with incorrect names/NINos/dates of birth should be
closed by using “user error”.
External handoff definition
132. If an allegation contains information on an illegal activity which involves
another authority or OGD, eg, Customs, the outcome result “external
handoff” should be used.
133. Inappropriate Pension referrals are occasionally received by Customer
Compliance. If appropriate these cases should be returned with a copy
of the FRF to the relevant Pension Centre and the case closed using
”external handoff”
MIDAS Data Error definition
134. This category should only be used if an IFD data match has gone
wrong and the specific problem has been identified by the COO Error
Reduction Team
Credits only cases
135. For Credit only cases, do not record a MVA or overpayment amount on
the FRAIMS case, record the:

Outcome Result as ‘Benefit Decrease’, and

Outcome as ‘Positive Compliance’.
Long-Term Unemployed Cases
136. The CCO will record the outcome of the intervention on FRAIMS in the
normal way. Feedback of the outcome will sent to the person making
the referral automatically by FRAIMS.
Claiming a positive outcome
137.
A positive outcome can be recorded when:

a claimant reports a change in circumstances to a Customer
Compliance Officer (CCO) at the interview that leads to benefit
being adjusted or a change to the amount of the CCG – See
example 2 Appendix 5

following a telephone call to arrange the CCG visit the claimant
withdraws the application;

following receipt of a Customer Compliance interview letter and
prior to the interview the customer contacts the CCO or
Customer Compliance section and notifies a pre-existing change
in circumstances leading to a change in benefit – See example 1
Appendix 5

at an ineffective visit the CCO gathers information for example,
property is empty which allows the DM to make a decision to
reduce or disallow benefit;

a customer fails to attend two interviews and the case is referred
to the DM to suspend payment of benefit. The claimant does
not make any contact within one calendar month and their claim
to benefit is terminated (this excluded CCG referrals);

a letter is used to contact the claimant because they are no
longer in receipt of benefit.
Recording positive outcomes on FRAIMS
138. In order for a positive outcome to be counted towards the Customer
Compliance KMI the following should be selected:

Date of Outcome - Today’s Date


139.
Outcome - Positive Compliance
Outcome Result  Benefit/grant decrease
 Benefit/grant Increase
 Decrease & Overpayment
 Overpayment Only
 Increase & Underpayment
 Underpayment Only
NB: Positive outcome should not be selected in cases where the
Customer had been successfully interviewed, but no change to
benefit has occurred.
In cases where benefit increases and an overpayment has occurred,
the outcome result should still be recorded on FRAIMS in the normal
way.
Pre-payment Living Together cases
140.
141.
142.
143.
If the claimant admits living together on a pre-payment visit or the DM
decides that benefit is not payable following the visit, a positive result
‘Outcome - Benefit decrease’ should be recorded but a notional MVA of
Income Support (IS) or Job Seekers Allowance (JSA) or any other
DWP benefit cannot be claimed.
If passported Housing and Council Tax Benefit (HB/CTB) has been
claimed on a pre-payment LTAHAW/CP case, an MVA may be claimed
using average HB/CTB figures for working age customers.
If, at the visit the claimant signs an MF47denying living together and
the DM gives a negative LT decision, benefit will be put into payment. If
within 28 days of the visit, the claimant withdraws their claim as they
are now living with someone as a couple, an MVA may be claimed for
the IS, JSA(IB) or ESA(IB) in payment immediately prior to benefit
ceasing and HB/CTB, if this has been claimed. If the claimant, within
the same timescale, claims for a partner, and income based benefit is
awarded/increased an MVA of this increase may also be claimed. For
further information about this type of scenario, see the section on
Causal Link below.
It is not possible to claim an MVA for JSA/ESA (Contributory Based) in
these circumstances as this benefit would remain in payment
irrespective of whether a living together situation exists.
Causal link
144.
145.
146.
Causal link only applies where the original allegation on the FRF is a
living together/civil partnership case or if the case appears on the Risk
Priority List and is a category Risk A – (new claims) pre-payment
LTAHAW/CP, Risk B (current claims) post payment LTAHAW/CP or
Risk C recent separation.
It can only be claimed where there has been a face-to-face interview
with the claimant and a written statement has been obtained denying
living together.
The Customer Compliance section must hold the file for 28 days
following the activity. If by the end of that period the claimant notifies
the Department that they are living together and withdraws their claim
or claims for a partner, a MVA can then be claimed, as causal link had
147.
148.
149.
been established due to the Customer Compliance activity. Action
should be taken as per ‘Causal Link – Customer Compliance Actions’
instructions within the FRAIMS guidance.
Where a second interview has taken place after the claimant has been
allowed “thinking time”, causal link will only be calculated from the
original interview date and must not be extended from the second
interview date.
MVA cannot be claimed for causal link where benefit terminates or is
adjusted for reasons other than living together.
Examples of positive outcomes can be found in Appendix 5.