Saturday, 14 March 2009

Discretionary Housing Payments - Still Not Enough Answers

For those of you who haven't been paying attention *tsk* or are new, Discretionary Housing Payments are system by which Local Authority Housing Benefits offices can make extra top up payments to recipients of mainstream Housing and Council Tax Benefits if they accept that they are in need of extra help with their housing costs. The government sets an overall limit for how much can be spent on DHPs each year and provides a central grant towards the cost, normally providing 40% of the overall limit. Other than that councils are pretty much free to decide how they award these payments subject to the normal rules of rationality and not fettering discretion.

While councils are not obliged to spend up to the overall limit, there is clearly nothing for them to lose by spending at least the whole amount of the government grant although they are not obliged to do that either. Councils are expected to make their own decisions as to whether they wish to spend any higher than the central grant bearing in mind their stated priorities.

The catch - if you don't spend the whole of the grant next year's grant is reduced. So, not only is there nothing to lose, there is a clear incentive to manage decision making so that all of the central grant is spent, also meaning that there is more money coming into the local economy.

That's the background. Unfortunately I have found out via Freedom of Information Act requests that NCC has been consistently and significantly spending less that the central grant for each year the DHP scheme has been in operation and as a result, each year the central grant has been reduced. NCC gave me the numbers of successful applications to the scheme, the figures for grants and overall spending limits as well as the amounts awarded but claimed that they couldn't provide the total number of applications because doing so would cost too much. Strangely, they could provide the figures for 18 months or so when asked by a relatively minor councillors committee and these figures suggested that nearly 60% of applications were refused. Because of this refusal I couldn't calculate the refusal rates for all the other years. Funny that.

I've just had my appeal back over the refusal to provide the total numbers of applications to the scheme and its still a no-no. They say

"I have raised your concerns about the information you require seeming to be readily available in previous years as evidenced by the Debt Collection report and have had the following reply; “ The figures were generated in that particular year as part of a business need and a manual monitoring exercise had to be carried out”. Unfortunately this means we are in the same position as stated in this office’s previous reply in that figures can only be obtained by significant manual work being conducted."

So, if this is to be believed, having reported to a committee that there are concerns about high levels of refusals, NCC still has no mechanism for collecting routine information allowing it to monitor the refusal rate. And the extra information they would need would be fantastically easy to collect, you just count the number of applications that land on the doormat, divide the number of successful applications (which they do monitor) by this number and you have the success rate. That such a lack of simple performance management could be allowed to continue beggars belief.

The alternative of course is that they are lying through their teeth and are using the excuse of expense to get out of releasing embarrassing information, a common tactic in the public sector I'm led to believe by my reading of Private Eye. Its the Information Commissioner's Office for this one I'm afraid.

Oh and they were very pleased to make the following claim;

"I can also advise that the level of Discretionary Housing Payments made has steadily increased and current forecasting of awards through to the end of the financial year for 2008/09 shows that expenditure will closely match the DHP grant."

Ok, the first bit I like but they've left a vital factor out of the second bit. The reason why expenditure is now forecasted to closely match the central grant is not just because expenditure is increased, its also because the central grant has reduced year on year. Expenditure has only increased by £19.5k between 2002 ( the first full year of operation) and 2007 (the last year I've got figures for), whereas the central grant has dropped by £37.3k and has carried on dropping since. That's nothing to be proud of and I did make a snide remark in one of my previous posts that I hoped the proportion of grant spent wouldn't be taken as a performance indicator. Little did I know that they actually would see it as something to be proud of...

Other questions I asked them were whether they'd taken any initiatives to increase take up of DHPs and they told me they had done the following;

- awareness training for frontline staff so they could advise callers of potential entitlement. They sent me their training notes and presentation which, in all honesty looked fine and dandy for non specialist staff

- two leaflets, one aimed at claimants, the other at advisers. However, they just seemed to have packed a supply off to local advice agencies and housing offices rather than do anything active like targeting potential client groups*

- giving advice agencies "an input" into evidence requirements for claims. However, this seems to have been merely to use budgeting guidance from National Debtline. This is probably the best guidance there is I should say but kind of lacks a local element. I wonder if that was really all the advice agencies suggested?

- a dedicated team of staff to make decisions. This won't really increase take up per se but is good for consistency so we'll not knock it

The final question I asked was whether NCC had set up guidance for decision makers. The answer was that they use the Department for Work and Pensions best practise guidance and the above mentioned Debtline budgeting guidance. So the answer really then is 'no, they haven't' in terms of whether there is any local guidance on what factors inform decisions to award or refuse a payment, how the budget should be managed throughout the year etc. I'm sure the DWP guidance is very good but it is national and the whole point of asking councils to administer DHPs is that they can take local factors into account. What works in Bognor may not be appropriate for Bulwell is what I'm saying here.

They sent me copies of this national guidance (not a lot of work as its available on the DWP website) and of the Debtline info.

Call me impatient but there's not a lot there that would take much effort to get together to tell the truth. Its all stuff that, if they were actually using it as they claim, would be lying about the place on a shared network drive. So why did it take them 2 months to get it to me?

One last thing. A small part of me has been worrying that I'm the only person who seems bothered about this. Maybe its all a fuss about nothing? So I did a 'back of a fag packet' calculation to get some idea of how much Nottingham has missed out on in lost central grant due to failure to manage the scheme properly.

I decided to work out how much the central grant would have been each year if the budget had been managed so that the grant remained the same in real terms each year i.e. an inflationary increase. I used an average inflation figure of 3% to make it a bit easier cos its not far out and I'm just trying to find out what order of magnitude we're talking about here. I added all this up and compared it with actual expenditure.

You want to know the difference? Over half a million quid lost, or about 3 former Chief Executive's leaving presents worth if I'm being cheeky. That's money that, at no cost to the council itself, could have been brought into Nottingham's economy, helping to reduce poverty and homelessness.

And of course that's only the half of it. If NCC had decided that preventing poverty and homelessness was a priority they could have allocated some funding to enable a spending level over and above the level of government grant each year. This would in all probability have demonstrated a greater need and resulted in a higher level of central grant.

Like I said, the issue of not telling me the total number of applications is going to the Information Commissioner in due course and I'll write up what happens when they adjudicate. In the meantime we can say quite safely that NCC refuses nearly 60% of DHPs while money is going begging. NCC are of course free to rebut this claim with figures should they chose to do so.
My first post on DHPs

My second post on DHPs

My post on my adventures with the Freedom of Information Act

*see my first post linked to above and my experience suggesting a targeted distribution of leaflets

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