Superseded by later version
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)
and Long-Term unemployed referred under Trailblazer Pilot Provisions.
 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 (CA)
11. Where a CA case has been downgraded from FIS, the Customer Compliance
Officer (CCO) must check that the case has been associated to the FRM PDCS
FSU In Box on FRAIMS as per ‘Cases with a PDCS interest – Actions by
Customer Compliance case owner’ instructions within the ‘Cases with a PDCS
Interest’ section in the FRAIMS guidance.
12. If the case has not already been associated, the CCO must associate it themselves
by following guidance in para. 6 above. Ensure that the activity description field
contains details of the CAin 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, ie. the offence may have an affect on any
PDCS benefits in payment, the CCO must associate the case to the FRM PDCS
FSU In Box on FRAIMS as per ‘Cases with a PDCS interest – Actions by
Customer Compliance case owner’ instructions within the ‘Cases with a PDCS
Interest’ section in the FRAIMS guidance.
Child/children not in the household referrals
14. If 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 per FRAIMS guidance Section 22 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 customer 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 ‘High Risk Category G’. 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;
confirm ongoing imprisonment and once received, record on
2
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 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, 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;
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”.
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.
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
notify the Pension, Disability and Carers Service of the custodial
sentence if the customer is also in receipt of Pension Credit.
2
3
4
5
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 e-mail
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;
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
3
Step
Action
select ‘My Incidents’ to locate a Performance Measurement referral;
select ‘Query’ button – a yellow bar will appear across the screen;
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 it to the
PMSPOC on FRAIMS as per ‘More Frequent Attendance and Performance
Measurement’ instructions in the FRAIMS guidance. This ensures the PMSPOC
is able to view PM cases in ‘My Cases’ view in FRAIMS and track outcomes.
Referrals should be treated in the same way as any other Customer Compliance
case.
37. 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).
1
2
3
Local Authority referral criteria
38. 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.
39. 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
40. 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. Action must be taken to close the case on FRAIMS as per ‘Closing a
Fraud/Customer Compliance Case’ instructions in the FRAIMS guidance.
41. 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.
42. 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
43. 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
44. 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
45. We no longer undertake Customer Compliance activity for Service Personnel and
Veterans Agency (SPVA) referrals. These should be returned to the originating
SPVA office if received. Where the customer 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. Note FRAIMS as per “Handover”
instructions in the FRAIMS guidance. Appropriate Customer Compliance action
should then continue.
Instrument of Payment (IOP) referrals
46. Instrument of payment (IOP) referrals are not dealt with by Customer Compliance
and should returned to the sender if received.
Duplicate referrals
47. If a second referral is received on the same matter for a customer, 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 customer alleged to be working. If the description of the
work details are identical, then the CCSM can decide not to accept it, the new
referral should be closed as a duplicate referral.
48. Where a customer has been notified of an interview and a duplicate referral is
received prior to the actual interview, the CCO should discuss both referrals at the
same interview.
49. 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 as per ‘New and
Substantial Information received - Customer Compliance Actions’ instructions in
the FRAIMS guidance.
50. The CCSM will need to take action to close the case where Customer Compliance
activity is no longer appropriate.
Undertaking the Customer Compliance interview
51. 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
52.
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
53.
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.’
54.
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
55.
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 identity
are the following that state the claimant’s name and address:
2






3
4
5
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 more




56.
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
57.
Occasionally the claimant may ask for some time to consider their
circumstances in discussion with the alleged partner. The CCO should make a
further appointment to interview the claimant within 10 calendar days of the
initial interview. They should obtain a statement as per the step action above
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.
58.
At the second and final interview a further statement should be obtained
detailing the claimant circumstances.
CCG cases only
59.
The purpose of the 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 SFDM,
60.
If appropriate the CCO should challenge the claimant’s response.
61.
If the claimant is in receipt of benefit the CCO must also undertake a review
of the claimant’s claim.
62.
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.
63.
It is not reasonable to ask to see items such as beds and the CCO must decline
if offered to do so by the claimant.
64.
Claimants cannot add further items to the application therefore CCOs will
need to advise claimants to make a further application if appropriate.
65.
CCOs should not indicate to the claimant what the final decision on the
application will be.
Long-Term Unemployed Referrals
66.
A Personal Advisor (PA) may refer a case for someone who is long-term
unemployed following an Ongoing Customer Management (OCM) interview.
The CCO must carry out a robust and challenging interview with the customer
67.
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.
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
68.
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.
69.
For further information see Capital Investigations – Independent Living Funds in
the Fraud Guide.
Doubts regarding identity
70.
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
71.
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
72.
The CCO should have regard to the needs of the claimant if they think they
may not understand what is happening at the interview.
73.
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.
74.
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.
75.
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
76.
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 the
‘Vulnerable persons’ guidance.
Domestic violence
77.
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.
78.
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.
79.
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
80. The claimant may ask to record the interview. Requests to do so
must be accepted. The same principles apply in Scotland.
See DWP Corporate Customer Affairs website.
Review of the claimant’s current circumstances
81.
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.
82.
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
83.
The claimant must be asked to provide all the relevant documentary evidence
to enable the 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 FRAIMS as per ‘Benefit Decision, FIS & Customer Compliance’
instructions within the FRAIMS guidance.
84.
85.
86.
87.
88.
89.
If the claimant does not provide the relevant evidence within 10 working days
contact the information provider direct. This is 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 - Step four.
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
90.
91.
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
92.
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
93.
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
94.
The CCO may decide that More Frequent Attendance (MFA) would be
appropriate for the claimant. The following are examples of when MVA could
be considered:

Appearance of the claimant suggests they are working but this was not
established during the CC 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 CC interview without a valid reason

Claimant was in a rush to complete interview
Claimant in receipt of other benefits
95.
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
96.
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.
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.
2
3
Claimant refuses to comment
97.
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
98.
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
99.
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.
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
2
3
4
5
6
7
8
9
10
11
12
13
14
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.
See the Overpayment Referral guidance for more detailed instructions.
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 as per ‘Benefit Decision, FIS
& Customer Compliance’ instructions within the FRAIMS guidance.
Claimant fails to attend the interview
100.
If the claimant fails to attend or be available for an office interview a second
interview must be arranged as per ‘Customer Fails to Attend the Interview’
instructions within the ’Arrange and Conduct the interview’ section in the
FRAIMS guidance.
Failing to attend a second interview
101. 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 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
2
3
the Overpayment Referral guidance for more detailed instructions.
4
5
6
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.
7
8
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.
Create
Ineffective first home visit
102.
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
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
the Overpayment Referral guidance for more detailed instructions.
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.
2
3
4
5
6
7
8
Ineffective second home visit
103. 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.
104. 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
2
3
4
5
6
7
8
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. See
the Overpayment Referral guidance for more detailed instructions.
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.
Recording Customer Compliance outcomes
105.
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
106. 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
107. 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.
108. 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 details are returned, they are entered
on FRAIMS. To prevent double counting, the date of outcome must not be
changed.
109. For Community Care Grant referrals the date of change is the date it is
returned from the SFDM.
110. MVA/overpayments and underpayments are likely to be recorded at different
times within the process.
Abandoned definition
111. 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
112.
113.
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.
The reason to abandon any case must be discussed and agreed with the
CCM/CCSM in all cases.
The decision for abandoning any case must be noted in the FRAIMS
description box by the CCO.
Cleared before receiving case definition
114. 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
115. Cases arriving with incorrect names/NINos/dates of birth should be closed by
using “user error”.
External handoff definition
116. 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.
117. 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
118. 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
119. 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
120. 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
121.
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
122. 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

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.
123. 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
124.
125.
126.
127.
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
128.
129.
130.
131.
132.
133.
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 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.