The proposal for the current DSS Weekly Saving Scheme for Local Authorities has been produced after consultation with councils, professional bodies and other interested parties and no one could deny that the Department is keen to encourage good practice in delivering housing and council benefits.

The proposals set out to achieve the government's objective of getting it right and keeping it right. The departments own statistics along with that of bodies such as the Audit Commission show that a claim that is administered correctly at the beginning ,is more likely to remain correct through its lifetime. The Department's report 64 on benefit fraud showed that many people did not report a change in circumstance because they believed that the administration, either by the Benefit Agency or the Local Authority, would not be done quickly enough and would be wrong.

Benefit Fraud Inspectorate reports have highlighted that this is borne out on the frontline. However, the reports and again statistics have shown that higher expenditure on resources at the beginning of a claim is likely to be more cost -effective in the long run. Councils which have contracted out their benefits service show that this is the case. Contracting companies competing in an uncompromising market have ensured that the front-end costs that have been kept low in order to win the bid, have suffered with poor performance and hence backlogs when the system has actually started to run. Personally, I believe that some public functions can not be run effectively by the private sector, who logically have to keep their eye on profit margins.

Housing Benefit is too complicated now for the service to run cheaply. Housing Benefit in the past has often been the dumping ground for reorganising councils on the basis that claims ought to be easy to assess. Now, you would need someone with degrees in ethics, mathematics, and accountancy. Not to mention an MBA.

Weekly Benefits Savings started off as a way of encouraging Local Authorities to investigate fraud inherently in the Housing Benefit system has now come to end of it lifetimes. As we all recognise that fraud, identified by the old WBS scheme had little in common with real criminality and more in common with neglect and misunderstanding of the scheme. In fact, the claiming of WBS and the understanding of how "benefit administration" links into the "detection and prevention of crime and the prosecution of offenders" has produced a system of subsidy as complex to administer as Housing Benefit itself.

Therefore, we all welcome the DSS' proposal to change the scheme for something simpler that encourages and rewards good administration. The only problem is that the proposal attempts to be all-things-to-all-men and thus fails to keep it simple.

It is of course easy to criticise. So firstly, I would say that the new scheme does draw out and really tries to resolve the things that were wrong with the old scheme. However, if the proposal is accepted in the form outlined in the consultation document, then before the end of May 2001 changes will be made to the scheme.

I can see that the need to measure performance and the degree and amount of the measurement in the scheme will please most statisticians. The problem is that it's a tough job to identify and count the indicators without seriously rewriting not only benefits systems but also fraud management systems.

The difficulty that I have with the scheme is that the measurement process seems to have little to do with the process map of administration/investigation/penalty. In other words it lacks direction.

I am therefore offering up an alternative, which I believe will keep the focus on getting it right.

One of the strengths of the DSS proposal is the toolbox of items to assist in the administration and inspection of claims. I would like to see in the toolbox the following:

• Advertising. TV and radio Spots, Posters, Handbills, small ads for other forms – covering take-up, hotlines & help lines, and landlord packs
• Claim form and/or recommended wording for different parts of a claim form.
• Administration manual
• Desk aides on Housing Benefit/Council Tax Benefit and other benefits
• Desk aides on counterfeits and forgeries
• Desk aides on Human Rights etc.
• Contact files
• Intranet pages
• UV lights
• Standard letters and forms
• Prosecution and investigation policies

The counts can be done by the use of a simple matrix

Again the same matrix can be used

In year inspection

In the previous section error can be identified in three areas during in year inspection of claims, either as a review or as fraud investigation referral. An additional question should be addressed which is how did fraud get into the system.

The question has multiple parts to it:

Overpayment recovery and penalty need to be recorded and encouraged for the following areas and again a matrix demonstrates this:

Funding should not be available unless councils adopt x number of items from the toolbox.

Baselines should not be set until year two after measurements have been recorded from the first year.

The department should meet through an administration grant then following officers per 1,000 caseload. The cost of the officer should be based on the average grading of the officer for the type of authority (CIPFA family groups could be used). For example

In this example a council with 7,500 RR 4,000 RA and 4,000 CT only cases would be funded for

This is only a suggestion and alternative figures could be used.

Given that currently, admin. staff and assessment staff are funded from the admin. Grant, while visiting officers are funded from verification framework the only funding to come from WBS would be for the 3.5 investigators and the 0.5 court officers. In the long run, it would probably be better for the department to adopt the above form of funding across the board because it's easier to see what is being paid for.

We need to consider the disadvantages and advantages of the above funding arrangements. It does not cover the full funding of the section. It does not cover things such as telephone costs, running call centres or more importantly management costs. However none of the current arrangements meet full finding either and council taxpayers have to fund the difference.

The advantages of the scheme are that the performance targets are clear but councils do not have to follow the model scheme for staffing. It also sets out a model for contracting out arrangements. Some of the below the line costs can come from, or be reduced by using the toolbox supplied by the department. In other words things like posters and claim forms councils can use the department supplied standards or opt to produce their own at their own cost.

This, like any scheme, can be pulled apart and will not meet everyone's need but we all know that WBS must be replaced and we all also know that the current arrangements for overall funding of the service is now more complicated to administer than the actual benefit itself. The problem with the department's proposal is that it is not a simple scheme, although it heart is in the right place. The scheme I am proposing I feel will still meet the department's requirements but would be simpler to administer. It is true that the funding arrangements are not perfect for everyone but no funding arrangement will meet that criterion. When moving from one system to another there will be winners and losers, that is life.

The department should consider the view that was put to me recently by an un-named council's accountant. "Why bother with investigating fraud when it cost us £160,000 to administer but the reduction in subsidy would only be £154,000." Sadly she is not alone in this thinking.