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COUNTER FRAUD ANNUAL
REPORT TO AUDIT
COMMITTEE: 2023/24
1st April 2024
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 2.
Contents
The Counter Fraud key
contacts in connection with
this report are:
Alex Brown
Head of Counter Fraud
t: 01895 556811
e: abrown@hillingdon.gov.uk
Page
1. INTRODUCTION 3
2. EXECUTIVE SUMMARY 3
3. COUNTER FRAUD ACTIVITY 2023/24 6
4. COUNTER FRAUD PERFORMANCE 2023/24 12
5. FORWARD LOOK 2024/25 12
APPENDIX A - Loss Prevention Performance 2023/24 14
APPENDIX B - KPIs and Actual Performance 2023/24 15
APPENDIX C – Proactive CF Projects 2023/24 16
APPENDIX D - Counter Fraud Benchmarking 2022/23 18
APPENDIX E - Glossary of Terms 19
APPENDIX F - Social Media Campaigns 21
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 3.
1. INTRODUCTION
1.1 The Role of the Counter Fraud Team
1.1.1 The Counter Fraud Team (CFT) supports the Council in meeting its statutory responsibility
under section 151 of the Local Government Act 1972 for the prevention and detection of
fraud and corruption. The work of the CFT underpins the Council’s commitment to a zero
tolerance approach to fraud, bribery, corruption and other irregularities, including any money
laundering activity.
1.1.2 As well as counter fraud activity, the CFT also conduct a range of other types of investigative
work which do not necessarily have a criminal element to them i.e. revenue inspections,
disciplinary investigations, etc. There is also a range of preventative work that the team is
responsible for carrying out, such as fraud awareness training and ensuring the Council have
up-to-date and appropriate corporate investigation policies and procedures. The CFT also
leads on the Council's assessment of the risk of fraud and corrupti on across all council
services.
1.2 The Purpose of the Counter Fraud Annual Report
1.2.1 The Counter Fraud Annual Report 2023/24 provides the Council’s Corporate Management
Team (CMT) and the Audit Committee with information on the counter fraud work carried out
during 2023/24. It summarises for CMT and the Audit Committee the key findings from the
quarterly progress reports presented during the year . In addition, it provides an opportunity
for the Head of Counter Fraud (HCF) to highlight any significant issues arising from the
counter fraud work in 2023/24.
1.2.2 The Annual Report also highlights to CMT, the Audit Committee and other key stakeholders ,
the performance of the CFT in meeting its strategic and operational objectives (as set out in
the Counter Fraud Strategy 2022 to 2025 and The Annual Operational Plan), which provides
an opportunity for the HCF to be held to account in this respect.
2. EXECUTIVE SUMMARY
2.1 2023/24 has once again been a challenging year for the Council and its fight against fraud.
Front line services continuing to see s urges in demand and resources being under pressure
creates an environment for opportunistic fraud to thrive. The Council are not alone in this
scenario with all of the public sector seeing in creases in fraud due to the current economic
climate. However, with the CFT fully resourced and strategically placed across fraud
risks the team have achieved c£11.2m in savings during 23/24. This success can largely
be attributed to the work in Housing and Business rates.
2.2 2023/24 has been another successful year for the CFT , in particular with the team being
nationally recognised for its achievements and efforts combating fraud. Following on from the
CFT’s shortlisting for the Outstanding Fraud Prevention, Detection and Recovery award the
team attended the awards evening on 28 th November in London. Though facing a strong
shortlist of fraud teams, Hillingdon Councils Counter Fraud Team won the award for
best in class , alongside the prestigious Grand Prix award which was selected from all of
the category winners. The judging panel drawn from industry experts commented that the
Counter Fraud Team had “A very strong nomination that showed r esults over and above
target. The team took a holistic approach to audit, creating an organisation -wide counter
fraud culture led from the top down. ” The panel were also impressed by the creation of a
fraud risk register, which provides real -time reviews o n emerging risks and allows them to
deploy resources in an agile way, and the embedded mandatory verification processes
across social housing, right to buy and succession applications.
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2023/24 Counter Fraud Annual Report 4.
2.3 In the first quarter of 2 023/24 the CFT embarked on a small scale restructure to ensure the
service had the resources to combat fraud for the year ahead. The service reduced its junior
management and increased its operational staff to create capacity to undertake further
counter fraud activity. This structure chan ge supported the team in meeting its strategic
objectives and delivering the financial savings listed above.
2.4 Housing fraud, in particular tenancy fraud, has remained the highest fraud risk to the Council
and an area of focus for the CFT , with the team conducting civil and criminal investigations
into suspected cases of housing fraud, alongside proactive loss prevention projects. This has
achieved overall loss prevention savings of c£6.1m in 23/24. These savings included the
recovery of 103 Council properties due to tenancy fraud , this represents a 23% increase
on the previous year’s outcomes (22/23). The increase represents the highest property
recovery achieved in a single year.
2.5 With the cost of living crisis Housing services have seen a significant rise in those requiring
support due to homelessness over recent years. This has led to increased numbers currently
in emergency accommodation . This increased demand presents the Council with a higher
risk of fraud . The CFT currently have two secondees from Housing to residency check all
emergency accommodation to highlight any occurrences of non -occupation or subletting. In
total 42 cases of accommodation placements were cancelled saving c£ 353k. With
these additional resources demonstrating significant loss prevention savings, this work will
continue into 2024/25.
2.6 The CFT has focused its efforts into improving its coverage and activity with in Social Care in
2023/24. In total c£313k of financial savings have been identified, demonstrating an
increase of 33% on the previous year’s outcomes. Though this demonstrates a positive
move in the direction of travel in combating social care fraud, the HCF and the management
team are making arrangements to improve outcomes and risk coverage in this area.
2.7 In the area of Revenues, the team has delivered 6,829 inspection visits during 2023/24,
which is a 21% reduction from 2022/23. Though this represents a decrease in the number
of visits completed, the CFT has adapted its approach to improve efficiency using data and
intelligence to support decision making . This effective way of working has led to the CFT to
generating c£4.3m in additional business rates billings.
2.8 The Head of Internal Audit (HIA) and the HCF have continued to collaborate in their
approach to risk, governance and assurance. Following on from the success of 23/24 the
teams have worked in partnership on consultancy reviews in areas such as procurement ,
aligned approaches in risk management and supported each other in identifying fraud risks
and fraud controls.
2.9 The CFT has operated with a Home Office Onsite Immigration Official (OSIO) integrated
within the Counter Fraud Team since 2018. The OSIO supports the Council in decision
making for those that require assistance for Housing or Social Care by providing real-time
Home Office data. In 2023/24 the OSIO co ntributed savings of c£158k to the overall
counter fraud financial target.
2.10 The CFT ha s continued to carry out focused proactive projects as part of its strategic
approach to tackle fraud in the Council’s highest risk areas. These area s are considered to
be susceptible to fraud and financial loss. Per the table at Appendix C the CFT conducted
nine proactive projects in 202 3/24. The proactive drives provide assurance across the
Council and highlights, where needed, any further preventative measures.
2.11 Part of the CFT’s remit is to create awareness internally and externally of f raud including
promoting positive outcomes from its work. Across 23/24 the team has worked closely with
the Communications Team to educate on the risk of fraud, how to report fraud and share
some of the successes of the CFT. Appendix F showcases some of the media work
delivered in 23/24.
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 5.
2.12 Chart 1 below summarises the areas in which the CFT has achieved loss prevention savings
(cost reductions) in 2023/24 by each quarter. The majority of loss prevention savings have
been achieved by the CFT within Housing due to the team’s work in tenancy fraud. However,
Chart 1 also illustrates the consistent level of financial achievements in the area of Revenues
compared to previous years. A full breakdown of all CFT loss prevention savings can be
found at Appendix A.
Chart 1 - CFT Loss Prevention Savings Achieved in 2023/24
2.13 Chart 2 below summarises the allocation of CFT resource in 2023/24. Similar to previous
years, the team has spent the majority of its time working within the area of Housing . The
implementation of a new structure in 2023/24 which saw the CFT increase its operational
resources has delivered an additional 35% capacity. Due to this increase, it is difficult to
draw any correlation in time allocation against previous years.
Chart 2 - CFT Allocated Resource in 2023/24
2.14 In 2023/24 the CFT received a total of 638 referrals for investigation from both internal
and external sources (compared to 628 in 20 23/24). Chart 3 provides a summary of the
trend in referrals over the year. In Q1 the CFT received a sharp increase in external referrals
which remained consistent for the rest of the financial year , this can be attributed to the
external communications and media coverage of counter fraud activity and awareness.
£0
£500,000
£1,000,000
£1,500,000
£2,000,000
£2,500,000
£3,000,000
£3,500,000
£4,000,000
Quarter 1 Quarter 2 Quarter 3 Quarter 4
Housing
Social Care
Revenues
Immigration
51%
14%
28%
2% 5%
Housing
Social Care
Revenues
Internal Investigations &
Consultancy Reviews
Fraud Risk Assessment & Data
Matching
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 6.
2.15 The HCF notes that referrals in Q4 were in a slow decline from internal sources. To combat
this the CFT is preparing a new fraud awareness package to engage with staff in 2 4/25
which will be consistent throughout the financial year, with the anticipation of increased fraud
referrals from a variety of service areas across the Council.
Chart 3 - Number of 2023/24 Referrals by Quarter
*Referrals generated through CFT proactive projects or data matching exercises
3. ANALYSIS OF COUNTER FRAUD ACTIVITY IN 2023/24
3.1 This section provides a more detailed analysis of the activities of the CFT during 2023/24,
detailing specific work streams and the trends within each area for comparison and contrast.
The activities of the CFT were predominantly focused on three main fraud areas of work :
Housing, Social Care and Revenues. The CFT also conducted proactive Blue Badge
operations during the year as well as investigating allegations of Blue Badge misuse.
3.2 Housing Fraud
3.2.1 Throughout 2023/24 tenancy fraud investigations, housing verifications and proactive project
work in homelessness has continued to be the key areas of work for the CFT. By
undertaking verification checks in a variety of different areas , the applicants' eligibility for
housing services are properly verified prior to being off ered a tenancy and provides
assurance to key stakeholders that the risk of fraud in this area is being managed effectively.
The CFT continues to proactively identify and investigate instances of tenancy fraud. This
combined approach has enabled the team to deliver effective loss prevention savings and
recover a substantial amount of Council properties.
3.2.2 During the year the Counter Fraud Management Team worked closely with stakeholders in
Housing to improve the counter fraud culture and provide tailored support. Management
provided guidance on potential fraudulent cases and interviewed clients in conjunction with
housing staff to provide learning opportunities and demonstrate first hand interviewing
techniques. In addition, the CFT has trained over 90 staff in interview techniques to support
officers in their duties. This close support from the CFT has given housing staff the tools and
confidence to challenge suspected fraudulent applications with further training to be rolled
out in 24/25.
3.2.3 As per Chart 4 below, most of the counter fraud activity that was conducted within housing is
heavily focussed on tenancy fraud investigations which correlates to the increased outcomes
in this area.
0
10
20
30
40
50
60
70
80
Q1 Q2 Q3 Q4
External
Internal
CFT*
Average
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 7.
3.2.4 With additional resources available to combat tenancy fraud following a restructure in year,
the CFT has allocated an additional 10% of capacity compared to previous years. Following
an increase in risk relating to homelessness , resourcing capacity has also increased in B&B
fraud.
Chart 4 - CFT Work Within Housing Services in 2023/24
3.2.5 Per Table 1 below, in 2023/24 the CFT successfully recovered 103 Council properties. This
is a 23% increase on outcomes from 2022/23 and represents the highest property recovery
figure ever achieved by the CFT. The increased risk of tenancy fraud following the pandemic
and cost of living crisis , combined with the improvement in referral quality and the effective
processing of investigations by the CFT has contributed to this success.
Table 1 ~ Housing Tenancy Fraud Cases
Housing Tenancy
Fraud
2023/24 2022/23 2021/22
Cases £k/value* Cases £k/value Cases £k/value
Total number of
recovered properties
103 £5,768k 84 £4,704k 42 £756k
*Calculated using the new Tenancy Fraud Forum valuation.
3.2.6 Chart 5 (over the page) summarises the loss prevention outcomes of the team by area of
counter fraud activity within Housing. The team’s high levels of property recovery have
contributed to the majority of the savings. However , prevention of accomm odation savings
increased in Q 2 onwards due to the teams work in identifying tenancy fraud within
emergency accommodation. The CFT identified and closed 42 emergency
accommodation placements saving c£ 353k. With the success of uncovering fraud within
emergency accommodation the HC F expects further positive outcomes in this area during
24/25 following the introduction of a rolling programme of visits.
64%
2%
13%
16%
5%
0% Inv - Tenancy fraud
Inv - Right to Buy
Inv - B&B
Vfs - Allocations
Vfs - Right to Buy
Vfs - First Time Buyers, Mutual exchange
& Tenancy Succession
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 8.
Chart 5 - CFT Loss Prevention Outcomes in Housing 2023/24
3.2.7 In 2 023/24 the CFT continued to carry ou t verifications as part of the housing a llocations
process. As per Table 2 below, 997 housing cases were processed for verification These
enhanced checks give assurance to management that housing applicants are genuine ,
entitled to be housed prior to allocation and highlight potential fraud ulent applications for
further investigation.
3.2.8 Of the 997 housing verifications carried out in 2023/24, the CFT identified 20% for
rejection, including the closure of 29 applications. There are various reasons for a
verification to be rejected or closed, and these include significant rent or Council Tax arrears,
property ownership , no immigration status , or misrepresentation of circumstances . With a
high demand for social housing assistance these checks continue to demonstrate their
importance, as applicants may have been successful in obtaining a council property that they
were not entitled to.
Table 2 ~ Housing Tenancy Verification Cases 2023/24
Housing Tenancy
Verification Cases
Q1 Q2 Q3 Q4 Total
Total number of cases
reviewed
255 153 270 319 997
% Identified by CFT for
rejection
25% 17% 21% 16% 20%
Total number of
applications closed
12 7 7 3 29
3.3 Revenues
3.3.1 The CFT carries out inspections of businesses and domestic properties in the borough,
Council Tax exemptions and discounts (such as SPD) and data matching work through the
National Fraud Initiative (NFI) , as well as maximising revenue through the identification of
Beds in Sheds/Annexes. The work of the CFT aims to improve efficiency and increases
productivity by applying proven effective visiting processes and investigati ve techniques to
maximise revenue. This ensures that Business Rates and Council Tax are correctly applied
to all properties, including business premises and new-build properties.
£0
£200,000
£400,000
£600,000
£800,000
£1,000,000
£1,200,000
£1,400,000
£1,600,000
£1,800,000
£2,000,000
Quarter 1 Quarter 2 Quarter 3 Quarter 4
Prevention of
Accommodation Costs
Property recovery
Other savings/loss
prevention
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 9.
3.3.2 Table 3 below, outlines the performance of the Revenues Inspection function against the
previous year. The CFT has slightly improved its performance against its KP I in providing an
effective and efficient service. Though the volumes of inspections have decreased by 20%,
the team ha s remained focused in its approach prioritising income generation through the
Revenues Maximisation project.
Table 3 ~ Revenues Inspections Performance 2023/24
Revenues Inspections 2023/24 2022/23 Improvement
Total number of inspections completed 6,829 8,638 -1,809 / - 21%
Percentage within 10 day target 99% 99% N/A
3.3.3 The CFT continued to proactively identify Beds in Sheds within the borough and a total of 72
unregistered dwellings during the year have been added to the Council Tax list . These
previously unlisted properties resulted in loss prevention savings of c£84.5k. The
identification of Beds in Sheds will continue to be a priority for the CFT with further work
planned for 2024/25.
3.4 Revenue Maximisation
3.4.1 The continued focus on areas of loss prevention within NNDR has proven to be highly
successful. The team have maintained its activity in this area identifying unknown businesses
for ratings or those businesses that should have an increased RV through its own proactive
projects and working with suppliers . This has led to billings being issued to businesses
to the value of c£6m with the Council retaining 15% under the business rates retention
model. This area of work highlighted the benefits of utilising data and using investigative
practices to support inspections.
3.4.2 With positive financial outcomes across 2022/23 and 2023/24, the CFT has obtained Cabinet
Member approval to engage with suppliers for an additional year. The HCF believes this
partnership coupled with our own in -house work will lead to further positive outcomes in the
new financial year.
3.5 National Fraud Initiative
3.5.1 The National Fraud Initiative (NFI) is a bi -annual data matching exercise overseen by the
Cabinet Office. Data is to be provided at the end of Q2 with results from the 2024/25
exercise due at the start of Q4.
3.5.2 The NFI also produces an annual review of Council Tax Single Person Discount claims
which are matched against Electoral Roll records which identified savings of £79,545.30
during 2023/24. Matches for the new financial year were received during Q4 and are being
reviewed.
3.5.3 The CFT is recognised as a leading member of the NFI backed London Counter Fraud Hub
(LCFH) which aims to proactively identify instances of cross borough fraud and loss and to
provide access to regularly updated data from other public sector bodies.
3.5.4 During 2023/24 the LCFH has provided fortnightly data matching between council tenancy
records and death registration information. This has identified 17 properties where the
council was unaware of the death of the tenant and which has led to the properties being
recovered and returned to use earlier and more efficiently that would otherwise be the case.
This has provided a notional financial saving of £952,000.
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 10.
3.6 Blue Badge Fraud
3.6.1 Although the direct monetary value of Blue Badge fraud is relatively low, the reputational risk
to the Council is significant. The CFT’s commitment to protect some of the boroughs most
vulnerable residents and visitors to the area has been achieved by conducting both proactive
and reactive operations. These operations were established to identify instances of Blue
Badge misuse and for those found to be abusing the scheme to be held to account.
3.6.2 In 202 3/24 the CFT undertook a total of 3 Blue Badge operations. Two projects took
place in areas of risk based on intelligence gathered from referrals. The third operation was
an initiative involving 82 other Lo cal Authorities working collaboratively to participate in a
Nationwide Blue Badge Day of Action . This action enabled all participating Councils to
ensure that genuine badge holders were able to access the disabled parking facilities on
offer across England.
3.6.3 The results in this area of work for 2023/24 saw the CFT inspect 130 Blue Badges, seize
24 badges and prosecute 3 offenders for misuse who received substantial fines.
3.7 Social Care
3.7.1 Over the last two years the CFT has been embedding various counter fraud activities across
Social Care Fraud risks. The focus has been in areas of significant expenditure for the
Council such section 17 support and financial assessments (direct payments &
commissioned care).
3.7.2 Since the introduction of the Financial Assessment (FA) verification process which was
designed to highlight any instances of hidden capital or assets , the CFT has seen a 17%
increase in verification requests this financial year. In total 6 94 requests have been
received with the team investigating 19 of these cases achieving c£157k in loss
prevention savings.
3.7.3 During 2023/24 the CFT investigated its first cases relating to Special Guardianship Order s
(SGO). Two investigations commenced following concerns raised by the Kinship Team that
highlighted significant overpayments which had been made to two previous spec ial
guardians. An SGO is a formal arrangement through a legal order that appointments one or
more individuals to be a child’s special guardian. The order is intended in circumstances
where a child’s parents are unable to look after the child for either a short or long period of
time. Th ese highly sensitive investigation s identified that the special guardian had been
overpaid and was no longer entitled to financial support, this resulted in c£ 101k in
savings.
3.7.4 To maximise loss prevention through effective counter fraud activity, t he CFT has
undertaken a variety of approaches to combat fraud within Section 17 assistance. This
includes a yearly residen cy check project to identify non -occupation of council provided
accommodation and a verification process to ensure all approaches are eligible for support.
The team has investigated 5 cases leading to loss prevention savings of c£42k.
3.7.5 During 2023/24 the CFT ha s received a number of referrals regarding Direct Payments.
These referrals relate to misuse of funds or where the applicant had failed to declare savings
or assets. These investigations can be complex and lengthy by nature . In 2023/24 one
investigation has been completed with savings identified of c£13k.
3.7.6 Chart 6 over the page , summarises the loss prevention outcomes of the team for the work
carried out within Social Care. Over the course of 2023/24 the CFT has continued to raise its
profile within these services and engage positively with stakeholders, which has delivered
loss prevention savings of c£313k, with most of these savings delivered in Q2.
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 11.
Chart 6 - CFT Loss Prevention Outcomes in Social Care 2023/24
3.8 Onsite Immigration Officer (OSIO)
3.8.1 Chart 7 below, summarises the outcomes for the work of the OSIO within 2023/24. This is
based on prudent estimates of the costs of council services that are linked to immigration
issues where the OSIO has been able to directly assist by providing Home Office
information. The total value of the OSIO work for 2023/24 is estimated at c£157k.
Chart 7 - OSIO Loss Prevention Outcomes 2023/24
3.8.2 In January 2023 Hillingdon Council received a new OSIO from the Home Office. With the role
covering such a multitude of complex service areas, it has taken time to train the OSIO
across all areas. The OSIO is now fully up to speed and the HCF expects improved
outcomes in this area across 2024/2025.
3.9 Fraud Awareness Campaign
3.9.1 The CFT has continued to embed an effective counter fraud culture within the Council. A
total of 5 Fraud Awareness sessions were conducted both in person and virtually over the
course of the year. Each presentation was tailored to incorporate the different fraud risks
encountered by each service area. These sessions give officers the tools to spot and report
fraud, whilst encouraging them to champion a counter fraud culture organisation wide. In
addition to the awareness session s the management team ha s also rolled out training in
Housing services to support front line staff through the use of interview techniques. Over 6
sessions nearly 90 staff have been trained and given the tools to question applicants to help
support decision making.
£0
£20,000
£40,000
£60,000
£80,000
£100,000
£120,000
£140,000
Quarter 1 Quarter 2 Quarter 3 Quarter 4
Section 17
UASC
DFG
Financial Assessments
Direct Payments
SGO
£0
£10,000
£20,000
£30,000
£40,000
£50,000
£60,000
£70,000
£80,000
Quarter 1 Quarter 2 Quarter 3 Quarter 4
Social Care
Homeless application
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 12.
3.9.2 The Council s various social media platforms have been utilised by the CFT to raise
awareness of the different types of fraud and scams that had become prevalent over the
course of the year, as well as fraud risks and team outcomes . Tweets and online posts were
shared to encourage residents to report suspected instance s of fraud . Examples of the
CFT’s media campaign can be found in Appendix F. There has been a notable correlation
between the quality and quantity of referrals following on from the Fraud Awareness
campaign.
4. ANALYSIS OF THE COUNTER FRAUD TEAM PERFORMANCE 2023/24
4.1 The CFT introduced a suite of KPIs in 2018/19 which were agreed and implemented in
liaison with CMT and the Audit Committee. The KPIs allow effective measurement of
performance and enable the team and the HCF to be better held to account by CMT and
Audit Committee. The table at Appendix B sets out the performance by the CFT against the
KPIs throughout 2023/24 by quarter and previous years.
4.2 As illustrated in Appendix B, performance against KPIs has remained consistent throughout
the financial year . The team has also achieved 9 of the 9 KPI targets which is a
considerable achievement with 2 KPI targets increasing for 202 3/24. T he team’s overall
performance can be attributed to the management information available and t he
management team’s engagement with staff around performance.
4.3 The table at Appendix A provides a detailed breakdown of the loss prevention performance
of the Counter Fraud Team during 2023/24. The table highlights the significant increase in
Housing outcomes mainly around property recovery and emergency accommodation
closures.
4.4 During 2023/24 the CFT has actively sought to obtain data from each London Borough
relating to counter fraud activity and produced benchmarking i nformation which is set out at
Appendix D. This data relates to reported figures in counter fraud annual reports to
oversight committees for 2022/23. There is a significant inconsistency between authorities in
terms of what they each report to their oversight committees and the variation in values they
each place on individual activities. As a result, this makes comparison between authorities in
terms of individual counter fraud work areas difficult to quantify.
4.5 Nevertheless, there are several areas of general commonality (as set out in Appendix D),
including the performance on housing fraud and Blue B adge which are present across most
London Boroughs.
5. FORWARD LOOK 2024/25
5.1 Looking ahead to 2024/25, the CFT as part of the Council's Counter Fraud Strategy 2022-25
will continue to develop its risk-based approach, focusing on the areas of highest fraud risk
within services. Key to this is the continued engagement with service areas on fraud risk and
controls to support and un derpin the Council’s “Fraud Universe” which steers the CFT
Annual Operational Work Plan.
5.2 Moving ahead, there are a number of key priorities for the CFT. These include:
Implementation of the Counter Fraud Annual Operational Work Plan 2024/25, with a
full and ongoing reassessment of the fraud risk profile of the Council to ensure the CFT
adapts to any emerging risks;
To continue to embed a counter fraud culture across the Council through a successful
programme of Fraud Awareness , alongside engagement with key stakeholders
regarding fraud issues internally and externally;
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 13.
Maintain performance with suppliers to identify businesses that are not listed for ratings
through our Revenues Maximisation Project, to increase the NNDR collectable by the
Council, using open-source data and intelligence gathering;
Sustain the level of performance the team achieved in 2023/24 into 202 4/25, by
focusing on our strategic objectives , KPIs and the financial loss prevention target by
deploying a risk based approach to fraud;
Continue to work closely with Housing key stakeholders around the increased risk of
fraud, with the view to conduct further proactive and reactive counter fraud activity in this
area; and
Review and Update the Fraud Universe with a view to entering all fraud risks onto the
new Risk Management software JCAD. Once all fraud risks are entered into the system
services can take ownership and lead on fraud risk management with the CFT acting as
an enabling/support service.
5.3 The CFT would like to take this opportunity to formally record its thanks for the co -operation
and support it has received from the management and staff of the Council , CMT and the
Audit Committee during 2023/24.
Alex Brown APCIP
Head of Counter Fraud
1st April 2024
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 14.
APPENDIX A: CFT Loss Prevention Performance 2023/24
* Average weekly cost against average length of support. This figure fluctuates but has been provided by the Council's
Business Performance Team.
** NNDR operates under a business rates retention model with the Council keeping 15% of income.
Work Area Description Quarter 1 Quarter 2 Quarter 3 Quarter 4 2023/24
Housing
Right to Buy discounts £0 £0 £0 £0 £0
Property Recovery
(notional savings) £1,512,000 £1,176,000 £1,792,000 £1,288,000 £5,768,000
Other savings/loss
prevention £38,283 £134,596 £67,298 £147,008 £387,185
Social Care
Section 17 and UASC* £13,586 £0 £18,676 £9,388 £41,650
Financial Assessments £11,959 £115,511 £1,546 £28,866 £157,882
SGO £79,150 £0 £22,139 £0 £101,289
Direct Payments £0 £0 £108 £12,934 £13,041
Revenues
Single Person Discount £14,148 £75,001 £2,571 £6,610 £98,331
Council Tax Reduction &
arrears £12,070 £9,775 £893 £2,901 £25,640
Unlisted Buildings £18,740 £28,106 £18,380 £19,271 £84,498
Housing Benefit
Overpayments £985 £24,511 £1,850 £7,202 £34,550
NNDR** £44,661 £141,667 £3,629,335 £524,174 £4,339,838
Blue Badge Simple Caution &
Financial Penalty £2,958 £2,182 £1,690 £0 £6,830
Immigration
Officer
Housing Homelessness
Applications* £8,412 £0 £0 £8,412 £16,824
Social Care Savings £60,469 £28,477 £38,201 £14,024 £141,172
Totals
Loss Prevention Savings £207,226 £278,584 £147,968 £216,632 £850,412
Notional Savings £1,550,947 £1,320,929 £4,878,786 £1,740,750 £9,491,412
Cashable Savings £56,292 £134,133 £566,245 £111,408 £868,079
Costs awarded and
penalties £2,958 £2,182 £1,690 £0 £6,830
Total £1,817,423 £1,735,828 £5,594,689 £2,068,790 £11,216,735
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 15.
APPENDIX B: KPIs and Actual Performance 2023/24
CFT KPIs Target Q1 Q2 Q3 Q4 23/24 22/23
1. Percentage of fraud
referrals risk assessed
within 3 working days
95% 99% 100% 99% 100% 99% 99%
2. Verification work
timescales for
completion:
a. Housing Allocations
completion within the
target date set by
Housing
95% 99% 100% 100% 100% 99% 99%
b. Right to Buy case
completion within 28
working days
95% 100% 100% 100% 100% 100% 100%
c. Financial Assessments
completion within 7
working days
95% 100% 100% 100% 100% 100% 100%
d. Section 17 reviews
completion within 7
working days
95% 100% 100% 100% 100% 100% 100%
3. Investigation plan
completion within 5
working days of case
allocation
95% 99% 100% 95% 100% 98% 99%
4. Tenancy fraud referrals
received resulting in
property recovery
30% 42% 36% 58% 49% 46% 40%
5. Investigations resulting
in loss
prevention/financial
saving outcome
40% 42% 41% 58% 60% 48% 39%
6. Revenue inspections
completed within 10
working days of referral
date
95% 99% 98% 99% 99% 99% 99%
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 16.
APPENDIX C: Proactive Counter Fraud Projects 2023/24
Proactive Project & Rationale Project Outcomes
Gas & Electrical Checks Access - Q1
Working collaboratively with internal departments, the
CFT conducted unannounced visits to all social
housing properties that were overdue a gas safety or
electrical safety check for 12 months or longer.
The purpose of this project was to reduce the number
of properties that were overdue these inspections,
whilst also identifying potential cases of non -
occupation or subletting
Number of properties visited - 165
Properties Recovered - 8
Investigations continuing - 3
Financial Savings - £448,000
Section 17 Residency – Q2
The CFT carried out a project conducting residency
checks for all Section 17 Social Care service users.
The objective of this project was to verify that the
accommodation provided was being lawfully occupied
and identify any fraud being committed through
subletting, non -occupation, or not meeting the
eligibility criteria for funding and assistance.
Number of cases reviewed - 26
Number of cases validated - 25
Cases recommended to cease
funding - 1
Loss prevention through terminating
funding - £9,388
Blue Badge Q1, Q3
The CFT conducted a total of three proactive Blue
Badge operations in identified high risk areas.
Checks were carried out on all badges that were
displayed to ensure that the badges were being used
in accordance with the Blue Badge scheme . The
operations included seizing expired badges, wh ich
removes them out of circulation and prevents potential
misuse in the future.
Number of badges checked - 130
Number of badges seized - 24
Number of fraudulent uses of badges
– 4
Number of investigations continuing -
10
Total value of fines - £1,540
Total value of awarded prosecution
costs - £5,290
Beds in Sheds – Q1 and ongoing
'Beds in Sheds' is the term used to describe buildings
or annexes on private properties that have been
erected without the Valuation Office being made
aware and that can be considered habitable. This
means that the building or annexe should be charged
Council Tax. The CFT carried out unannounced visits
to properties that were highlighted via referrals and
intelligence checks.
Number identified for bringing into
Council Tax - 72
Investigations continuing - 5
Income generation - £84,498.56
Temporary Accommodation Residency – Q3
The CFT carried out unannounced residency checks
on all service users residing in Temporary
Accommodation properties.
The purpose of the project was to identify any sub -
letting of accommodation, instances of non -
occupation, as well as verifying those that had applied
for social housing and ensuring that they were still
eligible.
Number of properties visited - 225
Properties Recovered - 3
Investigations continuing - 8
Financial Savings - £176,412.25
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 17.
National Fraud Initiative (NFI) - Ongoing
The National Fraud Initiative (NFI) main exercise is a
bi-annual data match against numerous public and
private sector data sources.
The National Fraud Initiative (NFI) Recheck is an
annual data match where SPD data is matched
against the Electoral Roll.
£79,545.30 Savings from Single
Person Discount matching
London Counter Fraud Hub - Ongoing
The London Counter Fraud Hub is designed to bring
London Boroughs together, sharing data to identif y
cases of fraud, loss or error.
The first in house data matching exercise using the
LCFH, matched tenancy records against the death
register. This highlights any properties that the Council
are unaware that the tenant has passed away.
Number of properties returned - 17
Financial Savings - £952,000
Internal Revenues Maximisation - Ongoing
The Revenues Investigation Unit have carried out a
series of pro-active action days monitoring and
reviewing business rates listings in high -risk areas
which has identified new and improved premises to
increase business rates billing.
Additional business rates billing -
£3,722,946.60
B&B Emergency Accommodation - Ongoing
The CFT carried out a project conducting
unannounced residency checks for all clients residing
in Bed and Breakfast emergency accommodation.
The objective of this project was to verify that the
accommodation provided was being occupied and to
also identify cases of subletting, non -occupation, o r
misrepresentation of circumstances.
Number of clients visited – 738
Accommodation Closed – 42
Financial Savings - £353,314.50
Investigations continuing - 11
Council Tax Exemptions – Ongoing
The CFT carried out desk top checks of Class E & F
exemptions utilising data matching and in-house data.
This highlighted any properties that the Council were
unaware that the tenant ha d passed away or was
residing elsewhere due to care needs.
Number of properties returned - 15
Financial Savings - £840,000
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 18.
APPENDIX D: Counter Fraud Benchmarking 2022/23
London
Borough
Council
Properties
Returned
RTB
Cancelled
Housing
Applications
Closed
Council Tax
& CTRS
Blue Badge
Outcomes* Social Care
Barking &
Dagenham 11
Barnet 34 6 £50,011 13
Bexley 9 4 15
Brent 20 1 £72,325 23
Bromley 50
Camden 41 16 5
City of London 9 6 £6,771
Croydon 18 6 10 22
Ealing 4 20 £9,317
Enfield 8 9 £296,343 4
Greenwich 8
Hackney 49 11 2
Hammersmith &
Fulham 36 5 12 £4,430 £28,000
Haringey 41 115
Harrow 5 6 1 £317,792
Havering 10 5
Hillingdon 84 6 14 £66,813 6 £235,492
Hounslow 6 6 2 £263,415 1 £414,730
Islington 42 6
Kensington &
Chelsea 35 3 4 16 £22,000
Kingston 13 1 103 £21,371
Lambeth 77 1 £14,824 £79,931
Lewisham 5 7 £25,842 1 £23,000
Merton 1 1 81 £22,521
Newham 32 7 7
Redbridge 5 1 2
Richmond 11 2 93 £6,876
Southwark 5 30
Sutton 11 2 35
Tower Hamlets 34 7 6
Waltham Forest 40 17 2 £32,260 37 £27,293
Wandsworth 24 14 136 1
Westminster
(City of) 31 5 16 12
Where the cell is greyed out, the data was not available to us from the council in question.
* = Successful outcomes for Blue Badges are defined as fines and/or prosecutions but excludes seized badges.
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 19.
APPENDIX E: Glossary of Terms
Beds in Sheds
'Beds in Sheds' is the term used to describe habitable outbuildings, or annexes to private properties
being utilised without the awareness of the Council or the Valuation Office Agency (VOA).
Blue Badge
A Blue Badge provides parking concessions and helps people with non-visible and visible
disabilities or health conditions park closer to their destination. The Blue Badge enables holders
to park in designated disabled person’s parking bays either on the public highway or privately owned
car parks. In addition, badge holders can park on single or double yellow lines for up to 3 hours.
Direct Payments
The Council are responsible for administering direct payments to service users who have been
assessed as needing care and support services. The payments are made to allow applicants to
access care to meet their social care needs, such as support with living tasks and social activities.
Disabled Facility Grant
The council offers a range of financial support schemes for people with disabilities, such as the
Disabled Facilities Grant (DFG). The DFG is a means tested scheme that allo ws eligible applicants
to receive financial support to make adaptations to their home, if they, or someone living at the
property is disabled.
Financial Assessments
The Council is under a financial and legal obligation to carry out this means tested assessment for
each service user. The Financial Assessment (FA) identifies whether the applicant(s) is eligible to
receive funding towards their care costs.
Fraud Hub (LCFH)
Utilising the existing Cabinet Office infrastructure and systems, most London based local authorities
have agreed to upload internally held data sets for proactive data matching exercises. These
regularly agreed upon exercises will lead to the identification of possible fraud, loss or error.
National Fraud Initiative
The National Fraud Initiative (NFI) is a data matching exercise co -ordinated by the Government
Cabinet Office and conducted every 2 years. There is also an annual review of claimants in receipt
of Single Persons discount data that is matched against the Electoral Roll data. The NFI matches
data from over 1,200 organisations, including councils, the police, hospitals and almost 100 private
companies to identify potential fraud and error.
New Homes Bonus
The New Homes Bonus (NHB) is a grant that is paid by central government to incentivise local
housing growth.
Onsite Immigration Enforcement Official
The Onsite Immigration Enforcement Official (OSIO) provides enhanced access to Home Office data
for the purpose of assessing cases involving immigration issues and for assisting in a range of
counter fraud work.
Right to Buy
The Right to Buy (RTB) process is a statutory scheme whereby a tenant(s) can apply to purchase
their property at a significant discount from its market value. There are strict conditions that must be
met by the applicant(s) if they are to qualify for the discount.
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 20.
Revenues Maximisation
The use of internally held data and the utilisation of external data partners to identify previously
unlisted commercial and domestic properties, along with identifying commercial properties that have
undertaken modifications or improvements that would result in the revaluation of its Rateable Value
(RV). Commercial entities are under no obligation to inform Council Tax as to when they have
started trading or if their RV needs to be recalculated. The Council will only retain 15% of the
identified rates.
Section 17
The CFT provides assurance and mitigate s the risk of fraud within Chil dren’s Social Care, in
particular the allocation of emergency accommodation provided under Section 17 of the Children’s
Act 1989. The verification process seeks to validate a family’s reason for approach as well as their
financial circumstances, as applica nts claim to be destitute and requiring accommodation and or
financial support. The CFT conducts verification checks on all applicants approaching the Council.
Small business Rates Relief
The Small Business Rates Relief (SBRR) scheme is designed to reduce the amount of business
rates payable by small businesses. This reduction is available to ratepayers who occupy a property
with a rateable value of no more than £15,000.
Unaccompanied Asylum-Seeking Children
Unaccompanied Asylum-Seeking Children (UASC) are children and young people who are seeking
asylum in the UK but have been separated from their parents or carers. Whilst their asylum claim is
processed, they are cared for by the Council and provided with accommodation and or financial
support.
HILLINGDON COUNCIL COUNTER FRAUD ANNUAL REPORT
2023/24 Counter Fraud Annual Report 21.
APPENDIX F: Social Media Campaigns
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