Chapter 6 - Provider Assurance · Chapter 6 - Provider Assurance TABLE OF CONTENTS ... internal control are such that payments made to CHESD providers are in accordance with DWP and

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Chapter 6 - Provider Assurance TABLE OF CONTENTS

Introduction and Background ....................................................................... 1 How we Operate ........................................................................................... 2 How We Plan................................................................................................ 3 The Review Process .................................................................................... 3 Planning Research and Initial Evaluation ..................................................... 4

Field Work at Providers ................................................................................ 5 Final Evaluation ............................................................................................ 5 Review Outputs ............................................................................................ 6 Follow Up of Action Plan .............................................................................. 7

Other Potential Actions ................................................................................. 7 Provider Assurance Team Reporting ........................................................... 8 Contact details.............................................................................................. 8 Annex 1: Provider Systems Questionnaire………………………………… 10

Introduction and Background

1. The Provider Assurance Team (PAT) is part of DWP Finance Group in

the Contracted Health & Employment Services Directorate (CHES) and

has been in operation since October 2009.

2. The primary purpose of the Provider Assurance Team is to provide the DWP CHES Director with an assurance that provider systems of internal control are such that payments made to CHESD providers are in accordance with DWP and Treasury requirements.

3. PAT reviews and tests providers’ systems of internal control to establish how effective they are at managing risk to DWP in relation to health and employment provision expenditure and service delivery, including the arrangements they have in place for their supply chain.

4. This work is carried out by PAT by reviewing providers’ internal control systems to assess their ability to manage risk across three key areas:

Governance Arrangements – covering the provider’s governance arrangements, systems for tracking and reporting performance and their anti-fraud measures;

Service Delivery – includes the provider’s systems for starting, ending and moving participants through provision and generally looks to ensure that DWP is getting the service it is paying for. This section also covers management of the supply chain;


Claim Procedures and Payments – looks to ensure that providers have in place effective systems to support their claims for payment, including appropriate segregation of duties.

How we Operate

5. The Provider Assurance Team operates at a national level enabling it to present CHES provision providers operating across regions with a single view of the effectiveness of their systems. Each provider is allocated a nominated Senior Provider Assurance Manager as a single point of contact within DWP for management of assurance related issues / concerns. Contact details for the team can be found at paragraph 37.

6. On completion of each review providers are awarded a PAT assurance rating in one of the following four categories – (i) weak; (ii) limited; (iii) reasonable; or (iv) strong. The provider is sent a formal report which details the review findings including key strengths and areas for improvement, and where weaknesses have been identified. Providers are required to complete an action plan setting out appropriate steps for improvement. Action plans are followed up until PAT is satisfied that all required actions have been undertaken.

7. The description of the four assurance levels are as follows:

Strong Assurance – governance, risk management and control arrangements operated provide strong assurance that material risks are identified and managed efficiently and effectively, although improvements may be recommended;

Reasonable Assurance – governance, risk management and control arrangements operated provide reasonable assurance that material risks are identified and managed efficiently and effectively. Remedial action is required to improve the control environment;

Limited Assurance – governance, risk management and control arrangements operated provide limited assurance that material risks are identified and managed efficiently and effectively. Corrective action is required to resolve control weaknesses; and

Weak Assurance – governance, risk management and control arrangements operated provide weak assurance that material risks are identified and managed effectively. Urgent and significant corrective action is required to resolve significant control weaknesses.


How We Plan

8. In order to manage review activity and direct our resources in the most

effective way, PAT operates a national plan covering all employment provision providers in scope for PAT reviews. Provider reviews are allocated in priority order according to risk. This is determined by a number of factors including the current assurance rating, length of time since the previous review, and DWP stakeholder intelligence.

The Review Process

9. PAT look for evidence that systems are in place across provider

organisations to manage key risks to DWP expenditure. To facilitate this process the key risks have been broken down across the three scope areas (see paragraph 4) and PAT will examine the controls in place within your organisation to look at how effective they are in managing the risks identified.

10. There are five stages to the review process which can take up to 23 weeks to complete, depending on the complexity of your organisation and the extent of your employment provision contracts. The bulk of provider facing activity takes place within field testing which generally lasts no longer than five weeks.


Planning Research and Initial Evaluation

11. The purpose of this stage is to pull together all relevant information about you, form a paper-based opinion about your systems and develop the testing strategy to be used at your premises.

12. During this period you will be sent two documents:

a Provider Systems Questionnaire (PSQ) which asks a series of questions about your systems across each of the 3 scope areas – see Annex 1 for the PSQ;

a site information stencil to confirm information about the delivery sites for the programmes; and

Planning Research & Initial Evaluation

Provider Review process

Field Work

Final Evaluation

Reporting

Follow up of action plan

National PAT Plan


13. PAT also take account of feedback from other Departmental colleagues who work closely with you. Intelligence is gathered from these sources during the planning process and used alongside the PSQ response from you when forming an initial view of your risk and development of the test strategy. See paragraph 30 for the stakeholders consulted during this period.

Field Work at Providers

14. Commencement of the field work is signalled by a formal start-up meeting between yourselves and PAT. The purpose of this meeting is to brief you on the forthcoming review and agree the terms of engagement throughout including timescales for final feedback and the timeframe for providing all evidence by.

15. Based on the planning, research and initial evaluation, visits are arranged at your premises to carry out any testing deemed necessary to form a judgement as to the effectiveness of the systems under review.

16. The fieldwork can be conducted at any of your premises across the country and choosing which premises to visit will be determined by a number of factors, e.g. the provisions and activities delivered at individual sites, any intelligence gathered during the planning stage which may indicate weaknesses in certain areas, or the availability of PAT resource.

17. The tests will typically include reviewing key policy documents, examining participant files, interviewing staff, and performing checks in sufficient quantities to allow the team to form an opinion across your systems as a whole. This may mean that testing has to be extended in some circumstances or that it may be cut short in others.

18. During the testing period PAT provides a written summary of the key points found at that point in time. This allows the provider to understand and discuss the findings to date.

19. Throughout the testing period you will be given the opportunity to provide any supporting documentation and/or missing evidence that has been requested by PAT but all evidence must be provided by the date agreed at the start up meeting.

Final Evaluation

20. Evaluation of your systems is continuous throughout the end-to-end

PAT process. Once testing is complete all the findings are considered


and an overall assurance level is awarded covering the three scope areas of Governance Arrangements, Service Delivery and Claims Procedures & Payments based on the assessment of the adequacy and effectiveness of your systems across all aspects of the provision delivered under your employment provision contracts.

21. The final evaluation and assurance level will be formally presented to the provider at a final feedback meeting at a time agreed in advance. At this meeting PAT will discuss what actions are going to be taken to address any issues raised and timescales for satisfactory completion of those actions.

Review Outputs

22. Following the final feedback, a report is produced by PAT and sent to you. The report will contain details of our findings and opinion against all key risk areas across the three scope areas and an overall assurance level assessment for the PAT report.

23. There will be an action plan at the back of the report covering all the issues raised at the feedback meeting. You are expected to return the action plan within 10 working days of receipt. Your response should contain any timescales for implementing any necessary improvements.

24. You are also asked to complete and return a feedback stencil to the Senior Assurance Manager. DWP is committed to providing an effective Provider Assurance function and in order to meet this commitment PAT need to constantly review the way in which they operate and their supporting policies and procedures. As a major stakeholder in this process, obtaining feedback from the provider is critical.

25. If there are any issues or causes for concern that cannot be addressed

throughout the course of the review, then you should in the first instance put your complaint in writing to the Head of Provider Assurance Team. (contact details at paragraph 37).

26. There is no formal appeals process to allow you to challenge the level of assurance awarded. PAT undertake a period of extensive evaluation to ensure that we have a good understanding of your systems and processes and we gain sufficient evidence through testing to reach a sound conclusion regarding the adequacy and effectiveness of the controls within your organisation.

27. The final feedback meeting allows you ample opportunity to discuss the findings and assurance level, before the final report is issued.

28. If you are unhappy with the outcome there will be the opportunity to

discuss your concerns with the Senior Assurance Manager (SAM) and/or Head of PAT but unless the findings are factually incorrect PAT


will not review the assurance rating once awarded.

29. The main focus of any meeting or correspondence after an assurance rating has been given will concentrate on the implementation of the areas for improvement as detailed in the action plan to strengthen your controls/maintain a strong level of control in preparation for your next review.

30. The report is also sent to DWP stakeholders, these typically include

(but not exclusively):

Performance Managers;

PRaP Operational Support Team (POST);

Commercial Directorate;

Security Risk Advice Team

Employment Accounts Division or Team PIP;

Counter Fraud & Investigation.

Follow Up of Action Plan

31. Confirmation is sought by Performance Managers on behalf of PAT that all actions have been implemented. This follow up will take place within the timescales agreed with PAT.

Other Potential Actions

32. There may be other actions required depending on the findings of the review. These could involve the following:

Overpayment recovery – if overpayments are identified and evidence could not be produced during the review then you will be asked to sign overpayment recovery stencils which will be given to the appropriate Payment Teams including POST to make the necessary adjustments to the Payment Systems and reclaim the monies; and

Backtracking – if any overpayments or errors identified during the review indicate they are as a result of systematic weaknesses then you may be asked to ‘back track’. In such cases you will be required to provide the applicable evidence for the relevant contracts/provision over a specified period of time and in doing so identify for yourselves any overpayments. The results of the backtracking will be verified by PAT before


recovery action is taken.

33. For payments where an error rate has already been extrapolated backtracking and recovery action will not be applicable.

Provider Assurance Team Reporting

34. DWP may periodically publish assurance levels by Provider (note - this will not include reports or supporting information).

35. All PAT provider assurance reports are shared with the CHES Director and other senior managers within DWP.

36. DWP may take remedial actions in the following circumstances:

If following a Weak or Limited Assurance level from PAT your subsequent assurance level is the same or worse for the same reasons, or you are awarded a consecutive third weak or limited assurance, regardless of the reasons;

following a review, if the provider fails to submit and/or implement the Action Plan within agreed timescale;

where there are suspicions that a provider may be acting inappropriately the team will refer to Counter Fraud & Investigations as the experts trained in the legalities and techniques required to carry out formal investigations; or

where there are serious concerns around data security these are reported through the respective channels to colleagues in the DWP Security Risk Advice Team.

Contact details

37. The contact details for the Provider Assurance Team are listed below and enquiries can be submitted to the PAT central inbox [email protected]

Senior Assurance Manager Contact Details

Heather Rawcliffe Chesham Jobcentre 31 Red Lion Street Chesham Buckinghamshire HP5 1BR

mailto:[email protected]


Telephone: 01494 654704 Mobile: 07920 784378 E-mail: [email protected]

Julie England Scunthorpe Jobcentre Crown Buildings Laneham Street Scunthorpe DN15 5JT Telephone: 01724 274455 Mobile: 07500 765853 E-mail: [email protected]

Carmen Jennings Leominster Jobcentre Lion Court Leominster HR6 8JE Telephone: 01568 686904 Mobile: 07920 783505 E-mail: [email protected]

Head of Provider Assurance Team - Jane Mcluckie-Townsend located in Harlow. Tel 01279 693140 E-mail: [email protected] Operational Policy Lead - Alison Best located in Preston. Tel: 01772 899986 E-mail: [email protected]

Provider Systems Questionnaire

Section A

Governance Arrangements


Name of Provider:

Staff Member Completing Stencil:

Date:

PURPOSE: To ensure the Provider’s processes, systems and controls foster and embed a robust approach to the achievement, management and reporting of performance.

A1 Please describe the roles, responsibilities and accountabilities of the Executive Team, Senior Management and their subsequent reporting lines

A2 Please give an overview of the Board structures operating within your organisation, which relate to DWP programme delivery and how these are managed .This should include details of frequency, supporting MI, minutes etc.


Section A



for e.g. Executive Boards, Management/operational Boards, Audit Committees, Risk Review Groups

A3 Describe your operational structure from board to programme delivery for DWP CEP contracts, including roles, responsibilities, accountabilities and management reporting lines

A4 Please provide a copy of your organisation chart if you have not already done so, from board to programme delivery for DWP CEP contracts.

A5 If applicable describe the organisational structure and working relationships involved with managing your supply chain, including any accompanying framework.


Section A



A6 How are strategic objectives and resulting organisational objectives for the organisation set and communicated?

A7 Does your organisation have a Company Mission and Values statement? If so please provide details of how these steer your business.

A8 Please provide an overview of the operational policies and procedures operating within your organisation and those of your supply chain for e.g. Standard Operating Procedures, Operating Frameworks, Process Manuals or Guidance relevant to DWP CEP contracts.

A9 Please describe the personnel policies and procedures for e.g. Code of Conduct, Standards of Behaviour, Reward and Recognition, Disciplinary Procedures, Data Security, etc.


Section A



relevant to DWP CEP contracts for your organisation and your supply chain.

A10 What steps are taken if your staff, or staff within your supply chain, does not comply with your organisation’s expected standards of behaviour?

A11 How does your organisation ensure all staff have the correct skills and knowledge to deliver your business effectively, including those in your supply chain?

A12 Please provide details of how your organisation gathers staff feedback and monitors staff satisfaction, including whether or not it extends into your supply chain?

A13 What are the controls in place to limit users to only those functions


Section A



they need to perform their business? What user access controls and procedures are in place to control and monitor access to participant data? Are these controls mirrored within your supply chain and how do you monitor compliance?

A14 Give an overview of the management checking regime operating within your organisation and that of your supply chain.

A15 Describe your performance management and reporting system including performance targets, performance drivers and measures taken to improve performance, including those within your supply chain.


Section A



A16 Describe the line management reporting lines between those staff responsible for achieving performance and those claiming and reporting performance and that of your supply chain.

A17 Please give an overview of the organisation’s arrangements to identify, manage, report and review risk including those within your supply chain.

A18 Describe the remit of any Internal Audit function your organisation has or the internal audit activities undertaken on behalf of the organisation. Please supply any recent reports from the last 12 months.

A19 How does your organisation and your supply chain ensure business continuity in the event of disaster or sudden loss of staff etc?


Section A



A20 Describe the arrangements in place to pay your supply chain for the services delivered and how is this controlled.

A21 Describe the systems in place to identify, report and prevent fraud within you organisation and your supply chain.

A22 What arrangements are in place for staff or staff within your supply chain to report unacceptable behaviour or working practices? How are these communicated?

A23 How does your organisation and your supply chain deal with customer feedback and customer complaints, including any escalation route? Does it result in any analysis?

A24 How are any performance incentive schemes for both your staff and customers operated within your


Section A



organisation and within your supply chain?

A25 Please describe the quality and continuous improvement process operating within your organisation and your supply chain, including the self-assessment process, and how this reports its findings.

A26 What arrangements are in place to ensure improvements plans falling out of self-assessments are implemented and reviewed?


Section B

Service Delivery


PURPOSE: To ensure the provider supplies a service which constitutes Value for Money and that customers receive a service that is specific to their individual needs.

B1 How does your organisation and your supply chain ensure staff are aware of any programme eligibility criteria and ensure customers meet this for specific provision, including direct referrals?

B2 Describe the processes in place and those within your supply chain to record eligibility checks.

B3 What action is taken if customers are found to be ineligible? Are these instances recorded?

B4 Describe how your organisation and your supply chain ensure that staff are aware of the minimum delivery standards for each contract delivered.


Section B

Service Delivery


B5 How do you receive DWP referral data and how is this data then used within your organisation and to your suppliers/supply chain for both electronic and paper documents?

B6 Describe how DWP referral data, both paper and electronic is recorded and stored by you and your sub-contractors?

B7 How do you and your subcontractors ensure and verify that you are communicating with the correct customer, i.e. what identity checks are conducted?

B8 Describe the Induction & Initial Assessment process for each DWP Programme you deliver, including how customers are made aware of any contracted minimum delivery standards within your organisation and your supply chain.


Section B

Service Delivery


B9 Describe the systems in place within your organisation and your supply chain to ensure customers’ provision is targeted and appropriate to their individual needs.

B10 How do your organisation and your supply chain ensure customers understand their responsibilities, including expected behaviours, whilst on the programme?

B11 What action is taken if customers do not comply with your organisations expected behaviours?

B12 How do you ensure that customers within your organisation and your supply chain are made aware of the availability of childcare, travel and additional support whilst on provision, and


Section B

Service Delivery


how do you establish entitlement to that support?

B13 How do you ensure that the childcare providers used by your organisation and your supply chain are appropriately qualified, registered and regulated?

B14 How do you ensure that customers within your organisation and your supply chain are made aware of their responsibilities in respect of tax and NIC implications if receiving payments, financial support or 'benefits in kind' from you to get back into work and how is it recorded?

B15 Describe the criteria and process your organisation uses and those operating within your supply chain to allocate customers to individual ‘advisers’.


Section B

Service Delivery


B16 Describe the systems in place to identify customers referred to your organisation to start on provision and how you and your supply chain ensure they start within the specified timescales?

B17 What procedures are in place in within your organisation and your supply chain to ensure all participant starts are recorded and processed appropriately?

B18 Describe the processes in place to identify customers and action re-referrals to provision

B19 How are customers who fail to start provision identified and what action does this prompt?

B20 Describe the systems in place within your organisation and your supply chain to ensure customers’ progress is monitored


Section B

Service Delivery


appropriately and activities are tailored to their individual needs?

B21 Describe the process within your organisation and your supply chain to ensure customers have regular and frequent access to the advice ,guidance, support and resources.

B22 Describe the process within your organisation and your supply chain to review, update and assess customer’s Action Plans.

B23 What arrangements are within your organisation and your supply chain for customers to raise concerns regarding progress towards work or any aspect of their experience on provision?

B24 Describe how your organisation and your supply chain ensure that you have all the necessary resources available to provide an


Section B

Service Delivery


effective service and to meet customers’ needs?

B25 How do you ensure the provision your organisation and your supply chain deliver is focused on the requirements of the labour market and how is this reviewed as the labour market changes?

B26 How do your organisation and your supply chain ensure that the minimum delivery standards as defined in the delivery model for each contract are applied consistently and appropriately for each customer?

B27 Describe the processes in place within your organisation and your supply chain to raise participant compliance doubts when they fail to comply with a mandated activity, including fail to attend requirements, to ensure the


Section B

Service Delivery


appropriate sanction action is taken at each and every occasion.

B28 How do you ensure that staff within your organisation and your supply chain are aware of any contractual attendance requirements?

B29 Describe the processes in place within your organisation and your supply chain to record and monitor participant attendance / activities.

B30 Describe how your organisation and your supply chain ensure that work placement / work experience requirements are identified appropriately and subsequently meet customers’ needs.

B31 What marketing and network activity and planning does your organisation and your supply


Section B

Service Delivery


chain have/conduct to maximise opportunities for customers.

B32 Describe the process your organisation and your supply chain operates to ensure employment opportunities are identified, marketed and linked to customers appropriately.

B33 Describe the process in place within your organisation and your supply chain to ensure customers who are due to leave provision are identified appropriately.

B34 Describe how your organisation and your supply chain manage the exit process for customers who either complete or leave provision?

B35 How is information regarding completers and leavers recorded and reported within your

.


Section B

Service Delivery


organisation and your supply chain?

B36 How do you ensure customers within your organisation and your supply chain are made aware of the post-provision support available to them?

B37 How are customers’ post-provision support needs identified, agreed, recorded and monitored?

B38 How is post-provision support delivered and managed by you and your supply chain?

B39 Describe the process within your organisation and your supply chain to ensure customers are aware of their responsibilities during this period.


Section C

Claim Procedures and Payments


PURPOSE: To ensure claims for payment are valid and are submitted within agreed timescales.

C1 Describe the systems within your organisation and your supply chain to obtain the required signed Customer Consent stencil.

C2 How do your organisation and your supply chain ensure staff are aware of the criteria to be met for individual programme specific outcomes?

C3 Describe the entire claim process for each DWP programme delivered, including job roles any segregation of duties. It may help to provide flow charts detailing specific handoffs.

C4 Describe the systems within your organisation and your supply chain to ensure all outcomes claimed are supported by the required information, documents,


Section C



records and evidence (if applicable) as detailed in Jobcentre Plus Provider Guidance (or any other guidance as specified within the contract).

C5 Describe the process within your organisation and your supply chain for checking the validity and accuracy of claims prior to submission for payment.

C6 Describe the process within your organisation and your supply chain for authorising and submitting claims for payment including non PRaP claims (if applicable).

C7 Describe any remedial action taken by your organisation and your supply chain if outcome or evidence criteria has not been met.

C8 Describe the process operating within your organisation and your supply chain to action outcomes


Section C



that fail validation after being claimed

C9 What information is captured within your organisation and your supply chain to enable trend analysis, remedial action and lessons learned in respect to claim procedures?

C10 Describe the process for paying travel and childcare payments for customers who are eligible and how you are assured in respect of systems in place within your supply chain.

C11 Describe the process to acquire additional support for those customers who are entitled to this support and how you are assured in respect of systems in place within your supply chain.

C12 Describe the systems in place within your organisation and your supply chain to ensure that any possible tax and NIC is accounted for if you make


Section C



payments, provide financial support or offer 'benefits in kind' to your customers after they have started work?

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Chapter 6 - Provider Assurance · Chapter 6 - Provider Assurance TABLE OF CONTENTS ... internal control are such that payments made to CHESD providers are in accordance with DWP and