Part 3: Systems and Processes for Ensuring Benefit Accuracy

Introduction

3.1
In this part we describe the Ministry’s benefit processing system and the processes for dealing with an application for benefit. We look at the circumstances that can lead to an inaccurate benefit payment.

The Benefit Processing System (SWIFTT)

3.2
The computer system that processes the benefit information entered by case managers is known as SWIFTT (Social Welfare Information for Tomorrow Today). It was introduced in 1990. It is a screen-based system – it does not use stacked ‘windows’ that most computer users are familiar with today. SWIFTT is the biggest payments system in New Zealand, handling more than 2.5 million payment transactions a fortnight.

3.3
There is no evidence of SWIFTT directly causing benefits to be paid inaccurately. However, SWIFTT has some constraints that limit its use to identify inaccuracy, including:

• Automatic checks to assist fraud detection are an important way to reduce the number of inaccurate payments as a result of fraud, but have only recently been devised as part of entitlement checks. For example, through an application that has allowed the format of address data to be standardised, it is now possible to identify whether any other benefits are being paid into the bank account number supplied by a new applicant.
• Alerts to case managers when they enter certain information in a way that has previously led to complications – SWIFTT will not alert them to check certain details or direct them to input additional information.
• Compulsory fields to explain decisions – SWIFTT contains only voluntary fields in which case managers can note the reasons for making a decision. This can lead to “unverifiable” items (see paragraphs 5.18-5.23 on pages 61-63). A case manager’s decisionmaking would be easier to follow if SWIFTT contained compulsory fields for reasons for decisions on selected critical aspects of an assessment.
• Management information available from SWIFTT is limited. It provides information on over-payments and debt balances by individual client, but not the extent and causes of under- and over-payments. However, data from the SWIFTT, UCVII and TRACE systems is consolidated in the Ministry’s Information Analysis Platform (IAP) and is used by the Ministry’s Business Units to provide management information.

Conclusions

3.4
SWIFTT, while old, is sound in terms of accurately processing benefits. It has some constraints that limit its use to identify accuracy. The Ministry has developed some new functions, and is currently formulating an Information Technology Strategy relating to the overall future development of the system.

Applying for a Benefit and Supplying Information

Contact With the Ministry

3.5
People often contact the Ministry to enquire about benefits before making formal application. Often, the enquiry is by telephone to a Ministry Contact Centre. Such contact does not constitute a claim or application for a benefit.

Application and Assessment

3.6
What constitutes an “application” for a benefit is not defined in law or elsewhere. An applicant has to … furnish in such form as the [Social Security] Commission may require such personal and other particulars and (where applicable) such particulars of income and property as the Commission may require…⁸

3.7
However, arising from the judgment in the Scoble case⁹ a number of key expectations can be established:

• The Ministry should regard the Social Security Act as a “working document” so as to give it a “reasonable and practical application”. The Ministry should not, by being overly technical, deny an eligible person assistance, but at the same time it should operate in a way which is administratively efficient and does not waste public money.
• The Ministry should make an intelligent appraisal of a person’s circumstances as presented to it; and, as necessary, enquire further to determine whether the person is eligible for a benefit appropriate to the circumstances and, if so, which benefit(s).
• An application is a “claim for assistance to meet an identified need”, for a “particular purpose”. A request by a person for information is not enough to constitute an application.
• The Ministry can treat an application for one benefit as an application for another benefit, so long as the applicant has sought assistance for a “particular purpose”; and the Ministry can do so either at the time of application or later.
• The Ministry is required to inform a claimant of benefits relevant to the circumstances the claimant discloses or which the Ministry knows about.

3.8
When interviewing applicants, case managers seek further information. Scoble has reinforced the importance of this information-gathering process in order to assess eligibility for assistance. In addition, the Ministry periodically requires beneficiaries to provide updated information on their circumstances in the course of standard reviews of their benefits.

How Can a Benefit Be Inaccurate?

3.9
In Figure 5 on page 29 we identified the accuracy risk areas in the benefit system. There are five main circumstances that can cause a benefit to be paid inaccurately:

• An applicant or beneficiary unwittingly provides incorrect information or unwittingly fails to provide complete information about their circumstances. For example, an applicant might omit to provide information about the number of people sharing the rental of a dwelling, thereby causing the wrong level of Accommodation Supplement to be paid. ¹⁰
• An applicant or beneficiary intentionally provides false information to the Ministry, thereby obtaining an amount of benefit to which they are not entitled. In such circumstances, the applicant may be guilty of fraud. ¹¹
• A member of the Ministry’s staff (usually a case manager) makes an incorrect decision about one or more of –
  • the person’s eligibility;
  • their entitlement; and
  • the amount of benefit that is payable.
• A member of the Ministry’s staff makes a clerical error.
• The failure of the Ministry’s payment system causes an error.

3.10
Any of these circumstances – including fraud – can lead to the Ministry making an under-payment or an over-payment, or a payment that should not be made at all.

3.11
When receiving a benefit, there is a legal duty on the beneficiary to update the Ministry as soon as possible of any changes in their circumstances that are likely to affect their benefit entitlement. These can include changes in:

• with whom the beneficiary is living;
• the beneficiary’s level of earnings;
• the number of dependants the beneficiary supports; or
• what the beneficiary is paying for accommodation.

3.12
The Ministry has the discretion under law to review benefits at any time. In practice, standard review intervals are set – 26 weeks or 52 weeks – but it might be more cost-effective to match review intervals to the average period over which beneficiaries’ circumstances undergo some material change. The Ministry does not collect information that would help it to determine such intervals.

People Who Do Not Supply Complete and Correct Information

3.13
When a person does not supply complete or correct information, and subject to the expectations listed in paragraph 3.7, the person may not be entitled to any payment or may be entitled to payment of an amount different to that actually paid. Because the Ministry measures accuracy in terms of its own actions (consistent with the Purchase Agreement), it does not regard these incorrect payments as “inaccuracies” for the purposes of its Accuracy Reporting Programme, which we describe in Part Five.

3.14
As noted in paragraph 3.3, there are difficulties in extracting and analysing for management purposes SWIFTT data about the extent and causes of under- and over-payments. We consider that reliable information on cases where the information provided by an applicant was incomplete or incorrect could enable the Ministry to devise corrective actions. For example, if it were found that applicants often misunderstand a particular question or obligation, steps could be taken to clarify the instructions. This kind of information could prove to be particularly useful in helping to simplify the benefit process.

Conclusions

3.15
In summary, the Ministry’s obligation is to pay benefits correctly on the basis of the information available to it (whether the information was provided by or obtained from the applicant/beneficiary, or was otherwise known to it). It measures accuracy in terms of this obligation.

3.16
Under- or over-payments that arise other than from a Ministry error (for example, because the applicant provides incorrect or incomplete information) can still have consequences for the Ministry or the beneficiary, or both, of the kind described in paragraphs 1.6-1.9. For example, where incomplete information leads to the beneficiary not getting a second-tier benefit. There are likely to be benefits in learning more about why under- or over-payments happen, with a view to devising ways to avoid them, or to identify them as soon as possible. In this respect, the Ministry has implemented a range of early intervention strategies.

8: Regulation 7(1), Social Security (Monetary Benefit) Regulations 1971 (SR 1971/167).

9: Chief Executive of the Department of Work and Income v Scoble [2001] NZAR 1011.

10: The Ministry classifies these situations as “innocent over-payments”.

11: It is important that the term “fraud” is used accurately. There are some complex legal considerations to take into account in determining whether or not a benefit has been obtained “fraudulently” within the meaning of the Crimes Act 1961 and/or the Social Security Act 1964. In general terms, it is insufficient simply to establish that incorrect information was supplied to the Ministry, or even that the information was supplied in circumstances where the beneficiary knew that it was wrong.