Control Savings - Guidelines on determining Control Savings


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What is a control review?
What is a control saving?
Activation and control:
When can a saving be claimed?
What is not to be counted as a control saving?
How are control savings calculated?
Reporting of Reviews and Savings
Employer Inspections:
Validation Exercises

APPENDIX 1 Examples of control reviews;
APPENDIX 2 Multipliers
APPENDIX 3 Data required to complete Stór Application

 


 

 

All staff of the Department involved in the administration of social welfare schemes and programmes need to be aware of the importance of implementing appropriate controls at every stage of the claim lifecycle process.

These guidelines outline:

  • what is a control review;
  • what is a control saving;
  • when can a saving be counted;
  • what is not to be counted;
  • how are control savings calculated;
  • how are control savings reported.

What is a control review?

A control review is a review of a claim in payment to examine and ensure:

  • continued compliance with all conditions for receipt of payment;
  • continued entitlement to all payment components e.g. personal rate, increase for qualified adult (IQA), and/or child dependent increase (CDI) or allowance

Reviews can be by home visit by an Inspector, or interview with an official in an office, or desk assessment based on review of the relevant file or papers, or mailshot review or medical review.
The review must be initiated by the Department and not as a result of information provided by the customer, unless the customer has provided only partial or misleading information and in this circumstance such a review can be counted as a control review.
A control review must be over and above the regular contact with customers e.g. in Intreo/Local Offices, the customer’s signing to certify continued unemployment is not a control review.  Similarly, those who come at regular intervals to provide documentation (e.g. rent receipts) to enable their claim to continue in payment would not usually be the subject of a control review at that time. However, a GSW review conducted additional to signing can be counted.

The outcome of a control review will be either no change, or an unreported change in circumstances resulting in a sign-off, partial sign-off, termination, reduction or increase in payment.  Arising from the control review an overpayment may be assessed where appropriate.

Appendix 1 contains some examples of control reviews.

What is a control saving?

A control saving is a reduction or termination of the rate in payment following a control review of a claim in payment.  The saving is the future amount of money estimated to be saved by the Department by reducing or terminating a claim in payment.

The saving must be as a result of fraud or customer error and not as a result of Departmental error.

Activation and control:

Activation of customers is also effective as a control measure, however it is very important that the Department records activation activity and control activity and is in a position to fully report on both.   Therefore, although the following are effective as part of the control of the Departments schemes they should not be recorded as control reviews:

  • Attendance at group engagement
  • Activation review meetings
  • Attendance at job fairs etc.

All of these activities should be recorded as part of the activation activity of the Department and reported on separately. It is important that engagement with customers in this manner is not double counted as both a control review and an activation review.

Penalty rates applied should not be counted as control savings, penalty rates are an activation sanction, they should be recorded and reported on but not as part of the control savings report.

When an activation activity results in a control follow up and there is a reduction in a rate of payment, a sign off or a termination of a claim this can be counted as a control review and the saving should be recorded, e.g. Customer’s jobseekers payment is disallowed because of “not genuinely seeking work” or/and “not available for full-time work” following an activation meeting.  Moving to another scheme, an education programme or employment programme like CE, TUS or Gateway is not to be counted as a control saving.

When can a saving be claimed?

Savings claimed must be linked to a control review.  Savings can be claimed as follows: 

Termination

The termination must be for at least 1 week in duration and must occur within 4 weeks of control review that specifically linked to the customer.

Reduction

Savings claimed which result from a reduction of payment e.g. from a loss of IQA and/or CDI, or from an increase in means must result from control review.  For Jobseekers schemes the average weekly reduction in payment over a four week period can be used for claiming the saving i.e. adding the 4 weeks together and divide by 4.  Odd days signed off where a pattern does not emerge are not to be claimed as savings.  Savings can be claimed on the value of the reduction of rate in payment from one scheme to another e.g. difference in rate where a customer as a result of a control review ceases OFP and is claimed as a qualified adult on her partners claim. The multiplier to be used is based on the scheme which reduces.

Overpayments

Overpayments can only be claimed as savings when the overpayment has been formally assessed and must be linked to a control review.  No multiplier should be used when claiming an overpayment for control savings purposes. The decision reason must be recorded as 302 (a) – suspected fraud or 302 (b) – customer error.

Increases should be recorded – where, as a result of a control review, a customer receives an increase in their payment, this must be recorded and reported with the terminations, reductions and overpayments on a monthly basis.  No multiplier should be applied. 
Savings should not be anticipated. Savings can only be claimed after the decision has been made by the Deciding Officer.  The relevant IT system should be checked after the case is reviewed to ensure that the payment has been stopped or reduced. Only then should savings be counted.
It is important to avoid double counting of any savings cases. Scheme Sections and Social Welfare Local Offices should only return savings from control reviews undertaken within their offices, i.e. savings and overpayments from cases which have been referred to Inspectors should NOT be included as these will be claimed by Inspectors.
Savings resulting from reviews by the Medical Referees are claimed by MRA section and should not be claimed by HQ buildings.

 What is not to be counted as a control saving?

Control savings should not be claimed in the following circumstances:

  • A claim which has not gone into payment.  It is acknowledged that all schemes apply control measures to ensure that only those who are entitled receive payment.  As a result many cases are disallowed at claim stage based on the conditions for the individual schemes.  As a saving is only made on a claim in payment, returns should not be made in respect of these cases.  A method to record the value of this activity is being developed.
  • Where the customer makes a full report of a change in their circumstances and the payment is amended (terminated or reduced) as a result. .Where the customer reports a change in their circumstances and a control review (e.g. referral to an Inspector) merely confirms this and there is no unreported change in circumstances.  However if the customer only partially discloses a change in circumstances some savings may be claimed, e.g. if a customer in receipt of Jobseekers Allowance signs off  because they have commenced employment and it is later discovered that they commenced employment earlier than they had declared, savings can be claimed for the period of the overpayment.
  • Penalty rates applied should not be counted as control savings.
  • 9 weeks disqualification should not be counted as control savings.
  • Savings should not be claimed where a payment stops due to the natural cessation date of the claim.
  • Savings should not be claimed on the recovery of overpayments. This is part of the debt management process.
  • Savings should not be claimed, on Basic Supplementary Welfare Allowance (BASI) payments where a saving has already been claimed on the primary payment (for which BASI was the interim payment).
  • Savings should not be claimed where there is a change in rate as a result of Departmental error.When a customer merely transfers from one of the Department's schemes or programmes to another e.g. JA to DA as a result of control review unless there is a reduction in entitlement e.g. OFP to QA .

How are control savings calculated?

Savings are calculated by applying multipliers to the difference in the rate of payment before and after the control review.
In cases where the payment ceases, the multiplier should be applied to the weekly amount being paid at the time of the cessation i.e. the termination value.
In cases where there is a reduction in rate, the multiplier should be applied to the weekly reduction value (i.e. the amount of reduction in payment - not the revised rate of payment or the revised means).
The relevant multipliers set out in Appendix 2 should be used.  For investigations which are included on the ERIN system, these multipliers will be automatically applied as appropriate.In cases where Free Fuel is in payment the saving must be claimed separately from the basic rate as different multipliers apply. The multipliers used are half of the scheme multiplier applicable.In the case of Household Benefits the saving should be claimed at the flat rate which will be set at the value of the benefits at the beginning of each year, see  Appendix 2.
The full value of the overpayment assessed can be claimed as a saving. Estimated overpayments should NOT be returned as savings. The overpayments amount recorded on DRAS should be the amount claimed.

Reporting of Reviews and Savings

It is important that all control reviews carried out are counted and reported to Control Division irrespective of whether or not savings were achieved in each case. Separate returns should be shown for each scheme. The amount of the control overpayment must also be shown separately.
ERIN
Savings should not be entered on the ERIN System until after a decision has been made by the Deciding Officer.

Intreo/Local Offices Savings:

Managers in Intreo/Local Offices are responsible for reporting non-Inspector control reviews and savings to their Divisional Offices for referral to Control Division. 

SWA Savings:
It is the responsibility of each Divisional Office to ensure that control reviews and savings from the SWA scheme are recorded and included in their monthly return to Control Division via the Stór App.

HQ Savings:
Managers from HQ scheme areas must ensure that their non-inspector returns are recorded and returned to Control Division via the Stór App.

Joint Investigations
In respect of joint investigations between Inspectors, SIU/JIU or CWS it should be decided locally who is to claim and return the savings but, in any event, there must be no dual return of the savings.

All control reviews and savings should be submitted to Control Division by the 8thof the following month.  Control Division then incorporates all stats/savings and on a monthly basis issues a national report.  See Appendix 3 for details captured on the Stór App in respect of each scheme.

Employer Inspections:

Savings resulting from an employer inspection can arise under one or more of the following:

  • PRSI arrears determined
  • Sign offs
  • Final Certs
  • Means reviews (all schemes)
  • Disallowances (all schemes)

All items are to be counted and returned so that the full effect of the inspection can be established.

PRSI Determined

Only PRSI or Tax arrears which are discovered as a direct result of reviews by staff of this Department should be counted as a saving. Care should be taken to ensure that all PRSI determined (irrespective of whether it is collected or not) is included.

PRSI which is already returned on a P35 or PRSI or Tax which is already known to Revenue cannot be counted as determined. Only newly discovered PRSI or Tax arrears should be counted.  Savings from PRSI arrears determined as a result of P35s completed and returned by employers on foot of an inspection by staff of this Department should be shown separately on returns. (P35s returned in the normal course by the employer should not be counted but only those cases where the officer considers that only for the inspection, the P35 would not have been returned by the employer).

Statistics should relate to completed inspections only i.e. where the PRSI position has been finalised.  Cases where there is concurrent working and claiming (CWC) etc. may take some time to finalise and additional savings arising from these can be added when the case is decided.

The statistics to be compiled and entered on ERIN are:

  • Whether employers were compliant;
  • Number of employees involved in completed inspections; and
  • Total PRSI arrears determined.

Inspectors should complete Form IN17 on each employer inspection. As well as making it easier to follow the details of the inspection, it will allow validation of the control savings from these inspections.

Sign Offs & Other  Savings from Inspection:

Many inspections now involve more than one officer where both the employer and the employees are interviewed.  Scheme sign-offs and other review savings, which are directly related to the inspection, should be counted as part of the savings from the inspection and recorded only once.

Self Employed:

The emphasis here should be on registration. As staff of this Department do not have powers to assess self employed PRSI arrears, the procedure is that any case where there are considered to be arrears, this should be discussed with the local tax office before finalising the inspection. If it is agreed with Revenue that arrears have been determined by this Department, these can then be counted as savings.

Validation of Savings

Control Division are required to carry out validation exercises on control reviews and savings claimed. This involves an examination to ensure that savings are being compiled and calculated in the correct manner. This is to ensure uniformity of application of the guidelines on control reviews and savings.
All Inspector savings entered on the ERIN system are retained and can be retrieved at any time in the future by an authorised user e.g., Control Division, Internal Audit, and C&AG.
The dates of interviews must be clearly stated on each file dealt with by Inspectors as this information is not available from the ERIN system.

Where savings are not recorded on ERIN sufficient records must be maintained for future validation exercises.

Queries:
Queries in relation to the Guidelines on Control Reviews and Control Savings will be dealt with by Ursula Brady or Grainne Cullen, Central Control Section at (071) 9672577 or extension 41577.
Any ERIN related queries should be directed to the ERIN Helpdesk at (01) 704 3283 or extension 43283.

Notification of Staf

Please ensure that the contents of this notice are brought to the attention of all relevant staff.
Deirdre Shanley PO
Control Division


APPENDIX 1 – examples of control reviews    (This list is not exhaustive)

  • review of all conditions for the schemes;
  • review of components e.g. qualified adult or child dependent entitlements;
  • review of a claim following an anonymous report;
  • reviews following data-matching with other Departments and external agencies;
  • review of means or income/earnings - casual, seasonal, self-employed etc.;
  • address or identity checks;
  • systematic reviews triggered by the Department’s IT systems for e.g. OFP 40s, Farm Assist annual reviews;
  • an interview with an officer to review whether the customer is still available for work and genuinely seeking work;
  • Where the DEASP has written to a customer inviting them to an activation meeting and the customer signs off prior to that date, the savings can be claimed in these cases where the date of the referral is within 4 weeks of the letter issuing from DEASP and there is no other apparent reason for the sign off.
  • Where intervention is required by DEASP with a customer who fails to attend the activation interview or refuses training and if this results in a sign-off then a control saving can be claimed.
  • review arising from Fraud and Error surveys on schemes;
  • medical reviews and assessments (MRAs);
  • reviews following failure to engage with activation/Intreo activity;
  • reviews following failure to participate in SAFE registration;
  • estates cases

APPENDIX 2 - Multipliers

The following are the multipliers that apply in savings cases, i.e. following a control review on a claim in payment, which results in a reduced rate or a termination of a claim as a result of unreported customer error or fraud.
Unless otherwise specified, in each case the weekly reduction/ termination value is multiplied by the relevant multiplier to give the total savings.


Multipliers

BACK TO EDUCATION ALLOWANCE

 

Termination

- X 32

BACK TO WORK ALLOWANCE

 

BTWA Terminations

- X 32

CARERS

 

* Carers Allowance

 

Termination

- X 136

Reduction in Payment

- X 52

Means Review

- X 52

* Carers Benefit

 

Termination

- X 36

Reduction in Payment

- X 52

CHILD BENEFIT
(applies to monthly rate of payment)

 

Termination

- X 34

Reduction in Payment

- X 12

FARM ASSIST

 

Termination

- X 52

Reduction in Payment

- X 52

Means Review

- X 52

FIS

 

Termination

- X 52

Reduction in Payment

- X 52

FREE SCHEMES

 

*Free Fuel Terminations  ( half the scheme multiplier )

 

Pensions

X 68

Short term schemes

X 16

Long term schemes

X 26

SWA Basic Payment (BASI)

X 16

Rent Supplement

X 26

All other supplements

X 26

* Household Benefits  

Flat Rate €560 (in 2014)

ILLNESS

 

* Disability Allowance

 

Termination

- X 136

Reduction in Payment

- X 52

Means Review

- X 52

* Disablement Benefit

 

Termination

- X 136

Reduction in Payment

- X 52

* Illness Benefit

 

IB Final Cert/Termination

- X 32

IB Suspensions (Factual)

See Note - X 9

Reduction in Payment

- X 52

* Invalidity

 

Termination

- X 136

Reduction in Payment

- X 52

* Occupational Injury Benefit

 

Termination

- X 32

Reduction in Payment

- X 52

*MR Capables

 

IB / US cases

See Note - X 24

DA / Invalidity

- X 136

LIVING ALONE ALLOWANCE

 

Termination

- X 136

MATERNITY BENEFIT

 

Termination / Disqualification

- X 4

ONE-PARENT FAMILY PAYMENT (incl. Widow/Widowers etc.)

 

Termination

- X 136

Reduction in Payment

- X 52

Means Review

- X 52

PART TIME JOB ALLOWANCE/INCENTIVE

 

Termination

X 52

Reduction in Payment

X 52

PENSIONS

 

* State Pension (Con and Non Con) Pension

 

* State transitional Pension

 

* Guardian’s Payment (Con and Non Con)

 

* Blind Pension

 

Termination

- X 136

Reduction in Payment

- X 52

Means Review

- X 52

PRETA

 

Termination

- X 136

Reduction in Payment

- X 52

Means Review

- X 52

RENT ALLOWANCE (De Controlled)

 

Termination

- X 32

Reduction in Payment

- X 52

SUPPLEMENTARY WELFARE ALLOWANCE

 

*SWA basic payments (BASI)

 - X32

*Rent Supplement

- X 52

*All other supplements

- X 52

JOBSEEKERS

 

*STJA/JB Sign Off/Partial Sign Off/Termination

- X 32

Reduction in Payment

- X 52

Means Review

- X 52

*LTJA Sign Off/Partial Sign Off/Termination

- X 52

Reduction in Payment

- X 52

Means Review

- X 52

 

 

Note:

It should be noted that in these cases, if the investigation is being entered on ERIN, the savings will have to be calculated and entered as a lump-sum, as ERIN will not automatically apply the multiplier.

APPENDIX 3  Data required to complete Stór Application:

Details required – Listed below
Division
Scheme
Month
Year
Type of Review           CWS Review
SWI Review
Desk Review Customer seen
Mailshot Review/Desk Review
Desk customer not seen
Medical Review – Desk
Medical Review – In Person
Number of Control Reviews
Number of Cases Reduced
Total value of Reductions
Number of Cases Terminated
Total value of Terminations
Number of Overpayments
Total value of Overpayments
Number of Increase
Total value of Increase (no multiplier)
Total value of Fuel terminations
Value of Decision under 302a
Value of Decision under 302b
Value of Decision under 302c
Annual Respite Care Grant
MRU direct payments
Number of Reviews with PRSI savings
PRSI Savings

Total (Figure will automatically populate).

Last modified:01/01/2015
 

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