Our Mandatory Work Activity providers are contractually obliged to protect DWP from exposure to over-claiming payments and fraud, and to notify the DWP immediately if it has reason to suspect that any fraud or irregularity has occurred or is occurring or is likely to occur. Specifically, they are required to have an established system that enables staff to report inappropriate behaviour by colleagues in respect of any claims for payment; ensure that the performance management systems do not encourage individual staff to make false claims for payment under the contract; ensure a segregation of duties between those staff directly involved in delivering the services and those making claims for payment; and establish an audit system to provide periodic checks, at a minimum of six (6) monthly intervals, to ensure effective and accurate recording and reporting of performance.
Additionally, providers are required to have systems in place to: detect and prevent duplicate claims; prepare and submit accurate, valid, supported, timely claims; monitor, record and manage lateness and all absences; support claims for payments through an effective customer attendance recording procedure; ensure that all the required evidence is collected (and submitted, where appropriate) to support the claim; identify customers who have left placement early, to prevent over claiming; carry out effective monitoring of sub-contractors; and respond to provider assurance reports with an appropriate action plan.
We routinely inspect providers' systems to ensure they are adequate and effective and are continually reviewing whether there are additional checks that we should perform to minimise the risk of fraud and error.
In the case of Mandatory Work Activity, there is an opportunity to further enhance the control environment and, in line with the recent NAO recommendation, we will introduce proportionate checks at placement hosts to validate that clients placed under the Mandatory Work Activity scheme receive their placement.