03 Initial Customer Compliance action
Check the relevant IT systems
1. Perform an in depth interrogation of the circumstances of the claimant’s
claim to benefit. Check relevant IT systems, for example:
Income Support Computer System (ISCS),
Jobseekers Allowance Payment System (JSAPS),
Disability and Carers Service (DCS) / Personal Independence Payment
(PIP) benefits, via the Common Enquiry System (CES),
the Customer Information System (CIS) including entry to Tax Credit
information for those with access,
Labour Market System (LMS), and
other Departmental IT systems, e.g. National Insurance Pay as You
Earn System (NPS), which was formally called e-Nirs, for those with
access. After accessing NPS it may be necessary to obtain additional
information, such as the full name and address of the employer, from
Her Majesty’s Revenue and Customs (HMRC).
Other Checks
2. Check the following information on the FRAIMS Contact Screen:
the claimant is still in receipt of benefit,
the alleged offence/risk would have an impact on the type of benefit
that the claimant is claiming,
the claimant’s circumstances have not changed,
for special circumstances such as Appointee or Power of Attorney, and
for Potentially Violent (PV)/Unacceptable Customer Behaviour (UCB)
indicators.
Note: That the above list is not exhaustive.
3. Check legacy systems to ensure that details of the allegation have not
already been reported and dealt with by the benefit centre, if the change of
circumstances has already been reported consider abandoning the case.
4. If the Case has been downgraded from Fraud Investigation Service or is a
MIDAS referral, check details of the Offence Type displayed on the
FRAIMS case and if required take action to change the Offence Type.
5. The Customer Compliance Support Office (CCSO) must also check that
any material received that is sensitive is marked in red. Most documents
will have been marked before they reach Customer Compliance, however
a check must be completed and documents marked if they need to be.
6. When the checks identifies that Disability Living Allowance (DLA),
Personal Independence Payment (PIP) and/or Carers Allowance (CA) is in
payment, a DCS/PIP claim pack can be requested by associating the case
to the Fraud Investigation Service Disability and Carers Team (FIS DCT)
Manager on FRAIMS.
7. Record that Customer Compliance activity has commenced on the
appropriate benefit payment system, for example JSAPS or ISCS by
recording the following on Notepad:
CC 03 – Initial Customer Compliance actions (09/13)
“Case selected for compliance activity on (insert today’s date). Do not
delete until (insert 14 months date). FRF/GMS concerning (insert details of
activity)”.
The date of the interview can be added to this note, if known.
Obtaining Employer Information from HMRC
8. If, after accessing National Insurance Pay as You Earn System (NPS),
employer information is required from HMRC it will be necessary for the
Customer Compliance Officer (CCO) to download, complete and issue the
following forms:
MF67 (for tax years from 2004/05), and/or
MF67A (for tax years prior to 2004/05) to HMRC.
9. A separate form must be used for each individual claimant but up to five
requests, which could be for more than one employer or tax year, can be
made on the same form by using the tabs at the bottom of the template.
The claimant details must be completed in full but are only required to be
entered on the first page as this information will be automatically populated
to all the pages.
10. The employer checkbrick name and/or reference number, along with the
Total primary Cont/value are obtained from the appropriate NPS screen.
Occasionally on cases from 2004/05 onwards, a microfilm number may be
present on NPS. Form MF67 should still be used on these cases and e
mailed to HMRC CKU, however the microfilm number should not be
entered on the form.
11. For tax years prior to 2004/05 form MF67A must be sent by email to the
HMRC MRS team via the designated GSI inbox at:
xxxxxxxxxxxxxxxxxxxxxxxxxxx. The responses from the CKU team will be
completed clerically and returned via the courier service.
12. For tax years 2004/05 and later, form MF67 must be sent by email to the
HMRC xxx team via the designated GSI inbox at:
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx. The CKU team will provide
the employer information by way of screen shots attached to the original
email request.
13. For further information on the completion of these forms, see:
E-MF67 Instructions,
E-MF67A Instructions.
Email subject box for HMRC requests
14. In order to comply with the Departmental Security Policy for the
transmission of documents, the subject box on the email for all HMRC
requests must be marked ‘RESTRICTED’ and include the claimant’s name
followed by the number of requests: for example: “RESTRICTED – M.
Bloggs x 4”.
Recording issue of MF67 or MF67A
15. The issue of form MF67 or MF67A must be recorded in FRAIMS as an
outbound Communication Activity, setting an appropriate Due Date for the
response.
CC 03 – Initial Customer Compliance actions (09/13)
Action on receipt of information from HMRC
16. Update the activity to record that the replay has been received and
attached the reply document to the activity.
Member of Staff Implicated
17. If a member of staff is implicated in any way during the course of Customer
Compliance action, the case must be routed to the Risk Assurance
Division (RAD) Single Point Of contact (SPOC) for the case to be
categorised as sensitive or not. If categorised as non-sensitive, it will be
returned to Customer Compliance for continued action to be taken on the
referral.
18. Fraud investigation Service (FIS) receive all cases regarded as sensitive
for a benefit fraud investigation. Sensitive cases are not downgraded to
Customer Compliance.
Check that Customer Compliance activity is appropriate
19. If checks establish that the claimant is no longer in receipt of a benefit, or
the criteria for the case to be abandoned are met, consider if Customer
Compliance activity is still appropriate.
20. Consider whether the claimant needs to be contacted, for example; it
might be appropriate to contact the claimant when they persistently re-
claim benefit in between working and we have a suspicion that they
continue to work whilst in receipt of benefit. The contact with the claimant
will reinforce their responsibilities whilst in receipt of benefit.
Customer Compliance activity is still appropriate
21. If the claimant is not in receipt of a benefit but Customer Compliance
activity is still appropriate, including cases transferred (downgraded) by
FIS or from the Benefit Integrity Centre (BIC), the Customer Compliance
Officer (CCO) must take the following action:
Step
Action
1
Contact the claimant by issuing the CCEL1 / CCEL1W outlining
any irregularities found and request further details.
2
Show the contact with the claimant by creating an activity on the
FRAIMS case, and:
record details of the letter issued and the date sent, and
set a BF date to allow the claimant 14 calendar days to
respond,
record the Activity Sub-Category as ‘Telephone’..
3
If the claimant has not replied within 10 working days, create an
activity to refer the details to the Decision Maker (DM).
4
Complete the LT54 outlining the details of the case to enable the
DM to make either reassess the benefit or make a decision on
the benefit entitlement. See Post Interview Actions.
CC 03 – Initial Customer Compliance actions (09/13)
Customer Compliance activity is no longer appropriate
22. If Customer Compliance activity is no longer appropriate take the following
action:
Step
Action
1
Record the outcome of the case on FRAIMS using one of the
categories available and take case closure action on FRAIMS.
2
Note the appropriate benefit payment system for any relevant
action to be taken if the claimant re-claims benefit; and
3
File the documents in accordance with local filing arrangements.
These should be treated as supporting documents and retained
for the same period as benefit documentation, e.g. documents
should be destroyed 14 months after benefit entitlement ends
(subject to the claim being an exception case). If your office does
not retain Customer Compliance documents, send the Customer
Compliance documents as Non Associated Post (NAP) to the
relevant benefit parent file at Heywood.
23. For more information, see The Benefits Document and Data Retention
Guide.
Review the Customer Compliance case
24. Prior to deciding the method of activity the Customer Compliance Support
Manager (CCSM) may wish to review the case to check that the relevant
information is recorded on the Fraud Referral Form.
Decide the method of intervention and allocate the case
25. There are a number of methods of intervention the CCSM can choose for
each case:
office interview,
visit,
post – If the claimant is not in receipt of a benefit but Customer
Compliance activity is still appropriate,
telephone - If the claimant contacts the office prior to the interview.
26. Office interviews should always be the preferred method, dependant on
room availability and the claimant’s personal circumstances.
27. Cases can be viewed and allocated to a Customer Compliance Officer
(CCO) on FRAIMS, taking into account their workload and experience.
Pre-award of benefit to the claimant
28. Cases that are referred under Risk A (New Claims) Pre-payment Living
Together As Husband And Wife/Civil Partnership (LTAHAW/CP) require a
face to face interview if the claimant wishes to pursue entitlement.
Potential Living Together/Civil Partnership cases
29. Living Together As Husband And Wife/Civil Partnership (LTAHAW/CP)
cases will be received under Risks A and B where another person has
been declared in the household.
CC 03 – Initial Customer Compliance actions (09/13)
30. Customer Compliance Officers (CCOs) will also receive cases from Fraud
Investigation Service (FIS) where there is an alleged partner in the
household.
31. If both the claimant and the alleged partner are receiving Department for
Work and Pensions (DWP) paid benefits, a case should be raised for each
person on FRAIMS, as an outcome may be appropriate on each case.
32. Where possible, interview both the claimant and the alleged partner.
33. Only complete a CP2LT if the claimant admits that a member of the
opposite or same sex is a member of the household but denies that a
Living Together situation exists.
34. If the claimant denies that the alleged partner is in the household but the
CCO has new and substantial information, complete a Fraud Referral
Form (FRF).
35. If a potential overpayment is identified obtain full details from the claimant
regarding the period of the overpayment and any agreement to repay. It is
not necessary to specify any amount of the overpayment. Include this
information in the MF47 statement.
Arrange the interview
36. Prepayment interviews and visits must take place within 5 working days of
date of receipt by Customer Compliance. The Advisor will have already
told the claimant that a visit will be undertaken.
37. All other office or home appointments should be notified in writing and
must be a minimum of 14 calendar days in the future, but see ‘Arranging
short notice visit appointments’
Office Interviews
38. Try to arrange the Customer Compliance interview to coincide with their
Fortnightly Jobsearch Review if they are a Jobseekers Allowance (JSA)
claimant. Check if there is an outstanding interview with another part of
Jobcentre Plus, for example, a Personal Adviser (PA).
39. Where a Labour Market System (LMS) account already exists, note LMS
Conversations that a Customer Compliance interview has been arranged,
along with the interview date and time. For more information, see
Appointment Booking System – ABS Interview Types, sub-heading
‘Benefit Related’.
Home Visits
40. Take into account the number of visits and the geographical area being
visited by the CCO.
41. If it is a prepayment visit, the claimant should be notified if possible by
telephone due to the urgency of the visit, to arrange a suitable time and
day. Only notify the claimant for this type of visit in writing if they cannot
be contacted by telephone.
42. Where the CCO has already notified a number of visits to a particular area,
but following the initial notification being issued, they have gaps in their
day, for example claimants may have notified they will not be available to
be visited, it may be appropriate to contact claimants by telephone to
CC 03 – Initial Customer Compliance actions (09/13)
arrange to see them at short notice, see ‘Arranging a short notice visit
appointments’.
Arranging the interview/home visit
43. Confirm the availability of the Customer Compliance Officer (CCO) using
local diary arrangements.
44. The appointment date must be a minimum of 14 calendar days in the
future, but see ‘Arranging short notice visit appointments’.
45. Locate the claimant’s mobile telephone number and create the SMS text
message and schedule the text message for the day before the interview
date. This step is not required if a mobile telephone number cannot be
located.
46. Record details of the planned interview/home visit by creating an activity
on FRAIMS ensuing a B/F date is set the day before the scheduled
interview date, so that the SMS text message schedule can be checked,.
47. Complete and send the appropriate:
CCOI1 / CCOI1W – for office interviews,
CCV1 / CCV1W – for home visits.
48. Record the issue of the letter on the FRAIMS interview/visit activity.
49. For more information on creating the interview/visit activity.
50. Pass the case to the CCO if the above action was undertaken by someone
other than the CCO.
Un-notified visits
51. Taking into account Article 8 of the Human Rights Act, un-notified visits
may only be conducted on Risk A (Pre-payment Living Together As
Husband And Wife/Civil Partnership (LTAHAW/CP) cases, identified at the
gateway where the Financial Assessor has told the claimant we will be
visiting them.
52. Prior to the visit full justification by the CCO must be documented detailing
why the visit was un-notified. Record details of the un-notified visit on
FRAIMS.
53. The Customer Compliance Manager (CCM) may wish to perform a
management check on all un-notified visits.
SMS Text Messaging
54. A SMS text message should be sent to the claimant in advance of the
scheduled interview to remind them of the date and time to attend.
55. Standard messages for Customer Compliance in English and Welsh have
been provided and no changes or additions to these messages are to be
made.
56. Examples of the SMS text wording is shown below:
English:
This is to remind you of your appointment at <venue> ('Your home' or
'XXX jobcentre') on <date> <at or between><Time>. If you have any
problems please call <insert local compliance team number>.
Welsh:
CC 03 – Initial Customer Compliance actions (09/13)
Mae hyn i’ch atgoffa y bydd eich apwyntiad yn <venue> ('Your home' or
'XXX jobcentre') ar <date> <at or rhwng><Time>. Os oes gennych unrhyw
broblemau ffoniwch <insert local compliance team number>.
Note: Where we use ‘Your home’, these will be the actual words used in
the text message, not the customer’s address.
57. For guidance on how to create a message and schedule it for delivery, see
5. How to send a message.
58. For further information about the Rapide SMS text messaging service, see
SMS Homepage.
Arranging short notice visit appointments
59. When making the initial telephone call the CCO must ensure they speak to
the claimant only and establish their identity using random security
questions.
60. If a message is to be left on the claimant’s answerphone, follow the
guidance in ‘Leaving a messages on a Claimant’s answerphone’.
61. When claimant’s identity has been established, advise the reason for the
call and ask if the claimant will be available to be visited.
62. If the claimant states they will be available, explain the reason for the visit
and tell the claimant what information / evidence they must have available
for the visit. They must have available:
Evidence of their identity
Passport,
driving licence,
any of the following, which must show their current name and address
utility bill,
rent
agreement
bank
statement.
Other documents
Bank Statements; for any current accounts, deposit accounts, or any
bank/building society or Post Office accounts,
Occupational Pension(s); their most recent statement from the pension
provider or details of other money from a place where their or their
partner used to work,
Earnings, including their most recent wage slips,
Individual Savings Accounts (ISAs), Personal Equity Plans (PEPs)
statements,
Savings and Investments; such as National Savings Certificates,
Premium Bonds, Income Bonds, or Capital Bonds,
Details of any property or land, other than where they live,
Evidence of their Immigration Status and ‘Right to Remain’.
63. If the claimant states they will not be available for the visit, or they cannot
obtain the necessary documentation in time for the visit, tell the claimant
that an appointment letter will be issued to arrange a later visit date, and
warn the claimant that they must be available for this visit.
CC 03 – Initial Customer Compliance actions (09/13)
64. Record details of the telephone call and the visit arrangements on the
FRAIMS case.
65. If the claimant does not answer or is unavailable either to take the call or
for the visit, details of the call must still be recorded on FRAIMS.
Interview preparation
66. The CCO must preview the case prior to the interview. As a minimum,
check relevant IT systems and review the most up to date details
concerning the claimant held on the Departmental benefit systems, for
example:
whether the claimant still has conditions of entitlement,
who lives at the claimant’s address,
confirm no official errors have been made.
67. If the claimant is suspected of working whilst in receipt of benefit and we
know the name of the employer they cannot be contacted until we have
interviewed the claimant. This is because the enquiry is being made for
non-benefit offence purposes and Section 111 of the Social Security
Administration Act 1992 is not appropriate. See Contacting the employer.
68. Identify any sensitive material prior to the interview and remove it from the
file. Sensitive material must not be disclosed to the claimant. Complete the
Sensitive Information record sheet (RM7) confirming that the check has
been completed.
69. If a case has been notified for a Customer Compliance interview and is
subsequently chosen for a Performance Measurement visit, continue with
Customer Compliance activity and interview the claimant. The
Performance Measurement team will identify this activity when they
preview the case and see the reference in ‘Notepad’ to Customer
Compliance action.
70. If the claimant has not been notified of a Customer Compliance interview
and is chosen for a Performance Measurement interview, Customer
Compliance activity must stop. Note FRAIMS accordingly by creating an
activity and then close the case when all details have been completed.
71. If the case notes suggest an interpreter is required, one should be
arranged.
Receipt pad
72. The CCO must have an FF300 receipt pad in the event that a bank book is
obtained from the claimant and a receipt is to be issued. This can be
obtained from the Finance Officer.
Identity card
73. The CCO must have a valid identity card EF283/EF283W, which must not
be a Fraud Investigation Service identity card. This must be shown to all
claimants who are being interviewed outside of the office. For office
interviews, an identity card, or Jobcentre Plus name badge can be used.
74. If the Customer Compliance Manager (CCM) or other authorised person
intends to accompany a CCO on a visit they must also have a valid identity
card to show to the claimant.
CC 03 – Initial Customer Compliance actions (09/13)
75. For more information, see the Finance Managers Guide.
Contact from the Claimant
Contact to cancel or re-arrange the appointment
76. The claimant may telephone the office on receipt of the appointment letter.
If the claimant cannot attend the arranged interview the CCO must re-
arrange the appointment at a convenient time and place for both parties.
77. If the appointment is re-arranged, the reason given for not attending must
be recorded on the existing FRAIMS interview/visit activity and a new
interview/visit activity created.
78. The existing FRAIMS activity details must not be over–written with the new
appointment time/date.
79. Ensure the SMS text message is updated to show the new appointment
details.
80. Where appropriate, revise LMS notes to add details of the change of
appointment date and/or time.
JSA Claimants
81. As a minimum, arrange to record the reason why the claimant cannot
attend the interview/visit in LMS conversations.
Contact to report a change of circumstances
82. In order for the CCO to claim a successful outcome the claimant must
contact the Department to report a pre-existing
change of circumstances,
preferably the Customer Compliance Team, although this is not essential,
to enable them to complete the required CC activity.
83. If the claimant reports the change to the CCO and the only way to resolve
the case is to discuss the circumstances over the telephone, for example:
if the claimant has started full-time employment and cannot attend a
customer compliance interview, a full review including the completion of a
MF47 must be carried out by the CCO in order to claim a Monetary Value
of Adjustment (MVA).
84. The change must have occurred on or before the day this review takes
place. See Interview conducted by telephone for guidance on how to
conduct Customer Compliance interviews over the telephone.
85. If the change is reported to someone other than the CCO, a MVA can only
be claimed if, following the issue of the letter from Customer Compliance
inviting the claimant for interview, they contact to report a change which
occurred on, or prior to the date the letter was issued.
86. If the claimant reports a future change, a successful outcome cannot be
claimed.
87. The contact from the claimant must be recorded on the FRAIMS case. At
this point the claimant can, if they choose to, waive the 3 day minimum
notification period, in order to have an earlier interview.
CC 03 – Initial Customer Compliance actions (09/13)
Safety of staff whilst visiting
88. The Customer Compliance Manager (CCM) must ensure that appropriate
health & safety guidance has been followed prior to the allocation of any
visits to claimants. Instructions can be found in the following guidance:
Keeping Safe – Travelling and Working Off-Site,
Working away from the office – a Health & Safety framework for
managers,
Risk Assessment for DWP persons involved with visiting customers in
their homes.
CC 03 – Initial Customer Compliance actions (09/13)