Agenda item

To receive the Shared Anti-Fraud Services (SAFS) Progress Report on Anti Fraud Plan 2023/2024

The Committee received the SAFS progress report, presented by N. Jennings, on Anti-Fraud Plan 2023/2024.

As Council joined the partnership in April 2023 the report would not review previous years. The report looked at progress with delivery of the anti-fraud plan reviewed and approved by Committee in March 2023.

Report details how SAFS have been embedding into WHBC to ensure officer and staff awareness of the service and how it works, ensuring SAFS can access systems needed and data required to conduct work.

The plan was agreed with the relevant officers and brought to the Committee for noting.

The report discusses what SAFS are doing,  how SAFS are introducing the service to the council and outcomes from some of the work.In particular, allegations of fraud reported, and the types of fraud that a local authority could see. Allegations could be received from the public and staff. Some work being done with the Comms team is ensuring public are aware of how to report suspicions of fraud to council, as well as officers.

Since the report was produced, the number of allegations increased to 25.

Work is being done by SAFS with the housing team looking at the right-to-buy scheme and how it is administered by WHBC, to identify or prevent any money laundering occurring.New processes were introduced and SAFS officers had undertaken an additional review once applications accepted by WHBC. No money laundering had been identified, nor suspicions of money laundering or fraud regarding this year’s applications. Some historic applications have also been reviewed.

SAFS are working with officers to review output from national fraud initiative (NFI). In March, Members were given an overview of what NFI is and how it works. The NFI produced 1294 matches for WHBC. Officers review matches to identify whether it is fraud, an error, an administrative change, or no action is required.

361 matches have been reviewed, identifying £47,000 of savings or potential revenue for WHBC. The savings or potential revenue came from 26 of what are presently classified errors, no actual fraud identified at moment. 17 further matters presently under review with SAFS.

The Council joined the Hertfordshire FraudHub this year, which works the same as the NFI, but work on a quarterly cycle rather than a 2-year cycle. Every 3 months, the Council's data is taken, reviewed and matched. Data analytics are then used to identify whether any fraud had occurred in the previous three months from the data. SAFS are currently reviewing over 4,000 matches from the activity and taken data from areas such as:

• Payroll,
• Housing
• Housing waiting list
• Council tax
• Housing benefit
• Electoral roll

Large amounts of data are being reviewed which will produce a large number of false positives.Therefore, the volume of data needs reviewing to identify any fraud and fix any errors in data.Next quarter, SAFS would then expect a lower volume of output from that to be undertaken. Work is also being done with the Revenues Team.Analyse Local software assists SAFS and WHBC in identifying potential fraud in council data for small business rate relief. So far, 4 cases where small business rate relief was in payment that should not have been were identified. This will raise around £31,000 in additional business rates for authority for collection.

SAFS are working closely with officers. Currently going through the cycle where data is being reviewed, improving relationships with officers and training has started. This training has increased both SAFS and fraud awareness for  WHBC officers. It is expected that there will be an increase in allegations or suspicions of fraud reported by officers in next 2 quarters.

An update was provided on SAFS KPI’s at present. Concerning KPI2, SAFS had just moved to new case management system from April 2023. The time recording process had been slightly problematic for SAFS, so not absolutely confident they recorded all time undertaken for the authority. Since the report was  produced, the time recording has improved.

KPI 3, inability at the moment to report on 3A, which is dealing with urgent cases within 24 hours. However, assessment of all of the allegations received so far shows that they are all being dealt with within one day, so still meeting second standard.

KPI 5  is now on target for delivery early in the year.

The following points were raised and discussed:

• Chair queried historic cases, how far back do SAFS go for cases. N. Jennings stated that it depends on the statute of limitations around offences that may have occurred and data retention limits how far back they can conduct an investigation. If an allegation were received, the intelligence team would review all allegations to determine whether it falls within their remit and something they can investigate. It would depend on the age of the case. The Chair queried if reviewing could potentially go back 10 years if they have all facts and evidence. N. Jennings confirmed that would be possible.
• It was noted that there were 23 posts working within SAFS currently.
• It was queried whether any league tables exist within Hertfordshire for fraud, and such data. N. Jennings stated data is held by SAFS and shared at board meetings with partners, authorities within SAFS. Data is provided to WHBC members who attend board meetings. However, there are no league tables. The SAFS want to provide best possible service and learn from each other through partnership.
• KPI 3 was queried regarding SAFS currently being unable to record case response time information but are achieving responses within 24 hours. A Member asked are WHBC required to be able to provide this information within a day and are there mechanisms in place to ensure WHBC will not struggle to meet this. N. Jennings states it is not WHBC, but SAFS that would be responsible as it is their KPI requirements. When SAFS changed case management system, the new system did not allow the separation expected to enable a prioritisation of cases. If contacted about matter, SAFS believe they do respond within 24 hours, however the new system does not currently confirm that.Presently, for WHBC, SAFS are achieving this target. However, SAFS would like the case management system to separate more important cases.
• It was queried how had SAFS implementation within WHBC compared to other local authorities where systems have been implemented. N. Jennings stated it had gone well, with several authorities already on board, clear desire from the authority to join, good levels of support from all across authority.
• Member queried about recovery of small business rate relief. When claims are made, when does it become fraud or something mistaken. How is a fraud case treated in comparison to other cases. What is the subsequent action, does the case get passed to a fraud team, the police, or does it get sorted before this level. N. Jennings stated that SAFS data analytics team’s priority is to identify where a problem, which arises from the data, is and to fix that. They then identify any system weaknesses that may need fixing to prevent problem re-occurring.Then, a review is conducted to identify if fraud has occurred and if there is a risk the fraud might have created that error within the data. There are grey areas, however individuals are dealing with complex legislation.Sometimes, people make mistakes or do not do right thing at right time, then there are opportunities for fraud to occur. SAFS are keen on first ensuring any issues are corrected. After this, if there is evidence of fraud, then the case will be investigated and go to an investigation team. They will work with officers to review processes and see whether process exacerbated that failure.An executive report may then be produced and provided to appropriate WHBC officers, which would outline where any weaknesses occurred, similar to an audit report. SAFS then provide recommendations to help improve weaknesses or fix any gaps.Any fraud investigation is very resource intensive and is done only when necessary, so a triage system is in place.SAFS priority is to fix issue, then ensure does not happen in future. If there is evidence of fraud in the process, then it goes to a fraud team and they will see whether there is capacity and need to investigate. This fraud team will talk to senior council officers. If issue is taken forward and becomes a criminal investigation, SAFS will interview individuals and collect evidence.The process of criminal investigation is expensive and time-consuming; therefore SAFS need to ensure they are investigating the necessary cases.
• The member followed up, querying if the fraud and problems identified end up paying for SAFS services.If the values of time and fraud that are found become a return on the investment that WHBC makes to SAFS. N. Jennings states this is the aim, SAFS want to show to authorities that there is a return on their investment.If there is not, SAFS need to review what is the added value of the service, what is being done to protect the authority and is there an estimate of value on that. The work undertaken by SAFS concerns where is the value, where can something be given back to the authority, such as through additional revenue, savings or fraud prevention; to pay for the service provided by SAFS.
• The Chair queried whether information sharing is done countywide and across country for information and evidence gathering when needed for investigations. N. Jennings stated for individual investigations, officers can travel everywhere to gather and review evidence for investigations, including abroad. SAFS have financial investigators with vast amount of powers to obtain information to assist investigations. SAFS can access large amounts of data to assist in identifying a crime. However, they have to make sure they investigate the right cases. Once investigating a crime, then there is an opportunity to access data and legally use that data for investigations, this is not limited.
• The Chair asked whether multiple agencies are used. It was confirmed many are used, including the following: National Anti-Fraud Network, HMRC, Cabinet Office, Police, Home Office.This is an extensive network, both for sharing best practice and alerts, which are shared with officers from various sources.Then reviewed by officers for relevance to their service.

RESOLVED:

(unanimous)

Members note the progress by officers and the Shared Anti-Fraud Service to deliver the 2023/2024 Anti-Fraud Plan for the Council.