Single Fraud Investigation Service
(SFIS)
CIPFA North West Audit, Risk and Governance Group
Autumn Seminar 9th October 2015
Andrew Bloor, Jane Whyatt
Creation of the Single Fraud Investigation
Service (SFIS)
Oldham Council’s experience of the move to
the Single Fraud Investigation Service and
the development of a Council corporate
fraud team……
Creation of SFIS
Today’s Agenda
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Background to SFIS
Oldham SFIS Pilot
Project Risks and Mitigations
Oldham SFIS Lessons Learned:
– What went well?
– What didn’t go so well?
– What would we do differently?
• Corporate Counter Fraud at OMBC
• Questions and Discussion
Creation of SFIS
Background – Welfare Reform Act 2012
• Welfare Reform Act 2012 - a wide range of changes
• Creation of a Single Fraud Investigation Service (SFIS):
The SFIS will bring together council, DWP and HMRC
investigation services under one umbrella to investigate all
welfare and tax credit fraud and to conduct a single investigation
covering the totality of the fraud. The SFIS will not be responsible
for investigating non-benefit fraud such as council tax or tenancy
fraud.
• The Go Live of a SFIS was confirmed in the Autumn
Statement by the Chancellor of the Exchequer on 5
December 2013.
Creation of SFIS
National Pilot Programme
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November 2012 - Programme of National Pilots
First Tranche of Pilots – 4 organisations
DWP engaged with Oldham – February 2013
Pilot Objectives:
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Different working arrangements/approaches to SFIS partnership
Testing different locations and co-location
Different structures e.g. outsourced Benefits
Resource plans e.g. buddying arrangements
Track results from all Pilots
Devised single set of policies/procedures to shape delivery model
Creation of SFIS
Oldham Pilot Arrangements
• Key Council Stakeholders:
– Benefits Administered by Partner (Unity Partnership)
– Council’s Client Function monitors service delivery
– Benefit Fraud in Audit and Counter Fraud Team
• SFIS Pilot led by DWP Project Manager with support:
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Universal Credit Pilot – investigate cases
Based at the Council offices/access to two IT systems
Buddy working and joint management arrangements
Review of electronic case file trial
• Staff Development and Learning:
– Bespoke training on DWP system delivered locally
– Cultural awareness for DWP and LA staff/ buddying staff
• Monitor and feedback Results to Team/DWP
Creation of SFIS
Oldham Pilot Risks
Risk:
Pilot Response:
• Resources assigned to
Pilot would affect/ hinder
BAU results
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• Cultural differences would
lead to Pilot failure and
difficult transition
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ICT systems set up failures •
lead to inability to deliver
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• SFIS would not go ahead
on time (sunk cost)
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Managed expectations of managers/
Members re: results during Pilot
Allowed workflows to be captured or
development of corporate team
Management support (DWP & OMBC)
Co-location to “get to know”/ “buddying”
Cultural workshop/training
Project Plan IT focus/Risk Log
System training for both teams
Conference calls between Pilots
Welfare Reform Act – announced by
Chancellor – led to focus
Creation of SFIS
Oldham Pilot Risks
Risk:
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Pilot Response:
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Poor stakeholder engagement •
leading to less than optimal
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investigations
Inability to achieve desired
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results from insufficient
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resource
Too much resource leading to •
cost/ poor VFM
Ineffective process for
investigating fraud leading to
reputational damage
Loss of knowledge leading to
lower than planned results
E2E processes agreed
Corporate Fraud processes redefined
Benchmarking with other Pilots
Support for investigative interviewing
Collaboration across the wider team
Sound procedures/ redefined
Stakeholder management plan
Communicated results to team
Monitored Pilot resources/tracked results
Pilot allowed BAU to be defined
As above, tracking results allowed
appropriate resource to be defined
Creation of SFIS
Mitigating the Project Risks
• Review Project Risk Log from Council perspective
• Engage with staff at all stages for a smoother transition:
– Before, during and after pilot
– Support the agreed HR process
– 121s with staff and group meetings with HR
• Manage stakeholders:
– Close management attention to the Pilot
– Ensure approvals are obtained by briefing senior managers
– Brief Audit Committee
• Creating Corporate Counter Fraud Team:
– Use Prior Year results to determine workflows/demand
– Consider skills for an effective Audit and Counter Fraud Team
Creation of SFIS –
AGMA & Associates* Transferred
AGMA Delegate Authority
Transfer Date
Already Transferred:
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- Oldham
Jul 2014
2
- Tameside
Feb 2015
3
- Bolton
Feb 2015
4
- Wigan
Feb 2015
5
- Rochdale
Mar 2015
6
- Stockport
Mar 2015
7
- Bury
Mar 2015
8
- Blackburn (with Darwen) *
Apr 2015
9
- Blackpool *
Apr 2015
Creation of SFIS
AGMA & Associates* To Transfer
AGMA Delegate Authority
Transfer Date
Awaiting Transfer:
1
- Cheshire East *
Dec 2015
2
- Manchester
Feb 2016
3
- Salford
Feb 2016
4
- Warrington *
Mar 2016
5
- Trafford
Mar 2016
SFIS Transfer Lessons Learned
What went well...?
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Pilot Objectives were met
Good Pilot Results
Smooth Transition and on time on 1st July 2014
Smooth Staff Transfers:
– In accordance with plans and process
– In accordance with skills, development plans
– Some team promotion since
• Retained Corporate Counter Fraud Team:
– All approvals obtained
– Briefed Members – Audit Committee
• Corporate Team - strong results post transfer
SFIS Transfer Lessons Learned
What went well…?
Staff Engagement/Morale:
Training and Development:
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Selected by DWP due to results
Opportunity to consider skills/career
Provided certainty
Helped to shape the design nationally
Understood the joined up approach and
the rationale behind SFIS
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Training material was detailed, well
designed, good quality
Culture workshop aided transition
Opportunity to integrate with potential
colleagues
Buddying and shared IT knowledge
Smooth Transition/On TIme:
Collaboration / Joint Working:
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DWP Project Manager support
Opportunity for managers to shape the
retained team/test BAU
Captured good results vs other SFIS
Pilots
Audit and Counter Fraud team focus on
core business
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Changed the way fraud is investigated
Effective collaborative operations with
the Police, DWP continues
Effective CTR investigations
Electronic case file trial success
Audit and Counter Team opportunities
Manager and Member engagement
SFIS Transfer Lessons Learned
What didn’t go so well..?
• Phase 1 Tight Implementation:
– Challenge for all activities to be undertaken effectively
– Staff communication not always aligned and were often late
– Impact of change in DWP Project Manager
• HMRC involvement remains a Challenge
• Sharing of local data / outcomes since the Transfer
• Cultural Challenges between 2 organisations:
– Local risk management – difference in approach/processes
• Single Point of Contact (SPOC) – process refinement
• Investigative Interviewing Capacity is Tight
SFIS Transfer Lessons Learned
What we would do differently …?
Learning:
Response:
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Liaise with SPOC to review E2E
Audit review of arrangements
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SPOC role to include review of MOU
MOU reviewed annually
Contact DWP re: case outcomes
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Addressed by training and support
Team collaboration
Define Post SFIS arrangements for
SPOC, engage the Benefit Client
earlier in process
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Reputational / local political risk
covered by MOU but remains a
consideration
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Skill set for retained function
Post SFIS
Oldham Corporate Counter Fraud
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Council Tax Reduction
Council Tax Discounts
Business Rates Fraud
Free School Meals
Social Care Misuse
Blue Badge Misuse
Whistleblowing Fraud Hotline/Online Fraud Referral
– Employee Investigations/others
• Proactive Data Matching – NFI and HBMS
• Planned Audit and Counter Fraud Reviews
• Training and Development – Staff and Members
Corporate Counter Fraud Team
2015/16 YTD Results
Investigation Type
Council Tax Reduction
Successful Outcomes
Cases
£
51
38,294
Council Tax Discount/Exemption
230
59,110 *
HB (overpayments identified as part of CTR
investigations – referred to SFIS)
Blue Badge
51
139,000
41
20,500 *
Free School Meals
16
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Employee – Abuse of Position
13
19,715
Procurement
1
224,963
Social Care
8
27,455
National Fraud Initiative
43
85,307
Creation of SFIS
Some Questions from Colleagues…..(1)
• Q: How did the team prepare for the transfer, what happened to
the benefit investigations that were being carried out at the time
of transfer?
• A: There are three elements to the answer:
– Cases were worked on during the SFIS Pilot; therefore no
cases were transferred by Oldham. However, in other
transfers, cases are forwarded to the DWP to set up on
FRAIMS, then allocated back out to the Fraud Investigator.
– Audit Managers also looked at the Corporate Counter Fraud
results, trends and estimated future demand to help to
determine the resources required for the retained team.
– Key stakeholders and Members were kept up-to-date during
the transfer.
Creation of SFIS
Some Questions from Colleagues…..(2)
• Q: How does the remaining fraud team deal with the
work created since the transfer?
• A: All cases are risk assessed in line with in house
protocols. Since the transfer there has been a variety
of different allegations received and investigated as
per Corporate Counter Fraud results earlier. The
team also handles CTR investigations and forwards
relevant information to the DWP.
Creation of SFIS
Some Questions from Colleagues…..(3)
• Q: What arrangements are in place with regards
admin support post SFIS (e.g. access to system
information/claim documentation)?
• A: The Audit and Counter Fraud team currently has
an Apprentice who undertakes the admin support role
on all investigations. The team maintains its access
to all systems including Council Tax, Housing
Benefits and NNDR systems as per pre–transfer to
deliver the retained service and the Audit & Counter
Fraud Plan.
Creation of SFIS
Some Questions from Colleagues…..(4)
• Q: How will the DWP obtain information from the
authority (application forms, calculation of
overpayments etc)?
• A: DWP follow the agreed protocol set up at the start
of the transfer. A signed Memorandum of
Understanding (MOU) needs to be signed by both
parties. All information on Welfare Fraud is provided
by the Revenues and Benefits Service (delivered at
Oldham by the Unity Partnership).
Creation of SFIS
Some Questions from Colleagues…..(5)
• Q: We are considering what to do about the residual CT and
Business Rates fraud work and whether you transferred all your
fraud officers or if you retained any? If you retained any what is
their remit and where do they sit in the organisation?
• A: Oldham Internal Audit and Counter Fraud team continue to
investigate a wide variety of fraud and misuse including Council
Tax and Business Rates. The residual Counter Fraud team
consist of 2 FTE, which includes the Assistant Manager –
Counter Fraud, the Corporate Counter Fraud Officer and also
there is currently Admin Support from an Apprentice.
Creation of SFIS
Post SFIS Team Successes…
• Flexible Audit and Counter Fraud Team:
– Greater joint working/aligned cultures and style
– Ability to focus on corporate fraud risks to support Council
governance
– Deliver Audit and Counter Fraud Plan
– Responsive to demand
• Redefined Corporate Counter Fraud Processes:
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Successes reported to Managers and Audit Committee
Increase in whistleblowing referrals/ demand increased
New case system/aligned to Insurance fraud collaboration
Training proposition under development/intranet content review
Creation of SFIS
Summary: Please consider……
• Track Results to determine resource requirements
• Plan Corporate Counter Fraud resource now
• Engage with staff in scope throughout process
• Brief Members and Managers early
• Determine SPOC/ Post Transfer Arrangements now
Creation of SFIS
Key Contacts
• Audit and Counter Fraud contacts:
• Andrew Bloor
0161 770 1205 andrew.bloor@oldham.gov.uk
• Emma Parker
0161 770 4895 emma.parker@oldham.gov.uk
• Jane Whyatt
0161 770 4773 jane.whyatt@oldham.gov.uk
• Fraud Hotline
0161 770 4969 investigations@oldham.gov.uk
SFIS Transfer
And Finally……
Any Questions?
Thank you!