Home Access – Anti-fraud measures

National Rollout Customer Journey

Becta Board

20 May 2009

Objectives

•To set out the customer journey from awareness of HA to acquisition of a Home Access Package

•Identify the points within the journey where fraud is possible

•Provide a summary of risks, controls and mitigations

•Set out where suspected fraud has been detected in the pilots.

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Summary of Fraud ActivitiesKey Developments

• Proactive approach - importance recognised from outset

• Importance of risk has been reflected in team structure

• Overall approach reflects experience from ILAs

• Appointment of dedicated fraud audit officer (Richard Forrow)

• Commissioning Bentley Jennison to review and audit processes

• Consultation and liaison with DCSF Internal Audit – represented on Board

• Consultation with LSC about the EMA programme approach

• Separate Fraud Risk Register – based on LSC template

• Business processes reflect anti-fraud activities

• Development of corporate anti fraud strategy2

Four key phases of the Home Access Customer Journey for grant recipients

1 Become aware of and learn about Home Access

2 Request or receive an application pack, and read and understand the material

During this phase customers:3 Complete printed

application form, append documentation, choose password and return

4 Are notified of submission receipt, and sensitive documents returned

5 Customers receive confirmation of approval, details of eligibility, approved supplier info, card details

6 Receive card explanation letter and PIN number from card provider

7 Receive payment card and activation notice from card provider

8 Consult approved supplier register, and identify an appropriate supplier

9 Visit approved supplier outlet or website and select appropriate product

10 Present card and identification. Payment is made, or a further ID check is required

11 Customers collect goods in-store or Packages are delivered to their home address by the Supplier

12 Customers receive Home Access guidance and information pack from the supplier, with training materials and links to support

13 Customers may have to register product online

14 Engage with Local Authority, School and Community resources to enhance learner support

15 (If necessary) seek technical support in case of product failure / defect

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During this phase customers:During this phase customers: During this phase customers:

This Presentation covers Phases A to C only

Customer Journey

Overview of fraud risks against the customer journey stages in National Rollout

• The risks featured have been chosen to represent many risks that have been identified along the course of the Home Access operation

• Fraud risks have been identified throughout the operation

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To reduce the complexity of showing fraud risks in this manner, the following processes have been omitted:

• Assistive Technology (SEN)• Aggregation • Targeted Funding• Fraud committed against the Customer

after they have received their HA Package

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Customer Journey

Home Access customer journey for grant recipients

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Fraud Related Issues

Phase A – Discovery (1)Phishing

Prospective HA applicants could be targeted to divulge personal information that would enable criminals to impersonate them using stolen/forged HA application forms

How will it happen?

• Helpline employees could obtain information and pass it on for gain• Criminals could impersonate MSP employees over the telephone to obtain personal

information• Criminals target vulnerable groups and provide inducements to collude in application • Parents or anyone gaining access to school or LA Meetings could gather personal

information• Blank HA Application Forms could be intercepted in the Postal System

Risks – monetary and reputational

• Potential Applicants for HA could be impersonated by fraudsters to obtain grants• Personal information, gained as a result of the HA scheme, could lead to unrelated fraud

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Fraud Related IssuesPhase A – Discovery (2)

Mitigating policies

• Warnings provided openly to those invited to attend School and LA Meetings

• Applicants will be alerted to the MSP call-back policy for limited telephone communication

• MSP staff will be CRB certificated and reference checked

• MSP postal services will be audited and plain envelopes will be used

• HA Application Forms will carry a reference number to identify their source

• Application Forms only available via the MSP and delivery address recorded

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Home Access customer journey for grant recipients

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Fraud Related IssuesPhase B – Application Checking (1)

Fraudulent Applications going undetected

• Ineligible HA applicants could make applications that include incorrect information that is intended to deceive the MSP for the purpose of receiving an HA Grant

How will it happen?

• Criminals may attempt to make false applications when ineligible under HA Grant rules• Applicants could provide out-of-date or marginally incorrect information• Existing benefit fraudsters could apply in the knowledge that MSP checking will not reject

them• MSP staff could collude with criminals or friends and relatives to defeat checking protocols• MSP operations could become inefficient for many reasons – e.g. backlogs, poor discipline

etc.• Criminals infiltrating the Postal Service may intercept and alter application information

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Fraud Related IssuesPhase B – Application Checking (2)

Risks – monetary and reputational

• Ineligible Applicants could obtain HA grants• Successful methods used to obtain HA grants by fraudulent means could be passed on

Mitigating policies

• Use of data originated by the DCSF to check applications for matching information• Use of a clear definition of eligibility based on nationwide Free Schools Meals regulations• MSP staff will be CRB and reference checked and performance monitored• MSP operations will work to the very highest professional standards • Service quality and anti-fraud audits will be carried out by experts with experience of Home

Access• Grants will only enable the recipient to obtain a computer – never cash

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Home Access customer journey for grant recipients

Step 6:Customers

receive card explanation letter and PIN number

from card provider

Step 7:Customers

receive payment card and

activation notice from card provider

Step 8:

Customers consult approved supplier register, and identify an

appropriate supplier

Step 9:

Customers visit approved supplier outlet or website

and select appropriate

product

Step 10:

Customers present NOE, payment card

and identification. Payment is completed.

Postal Provider

Phase C: Purchasing

Step 11:Customers collect goods in-store or

Packages are delivered to their home address by

Supplier

Card providers

Postal Provider

Card providers

Suppliers Suppliers Suppliers

Card providers

Suppliers

3

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Fraud Related IssuesPhase C – Purchasing

Poor Quality Goods are sold by Suppliers• Suppliers offer and sell goods that are below the standards laid down by the Home

Access Supplier Accreditation Agreement

How will it happen?• Suppliers attempting to increase their profit, offer goods that are below standard• Product Manufacturers reduce the quality of equipment that has been approved for HA

Risks – monetary and reputational• HA Grants are redeemed against products that do not fulfil Home Access requirements

Mitigating policies• Mystery shopping will be used to establish whether this is occurring• Grant funding will be clawed back if mis-selling is detected• Suppliers will be removed from the Approved Supplier Register• Adopting a robust complaints process will provide evidence of dissatisfaction

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Home Access Incidents

Ref.No Incident Source Issue Ongoing action(s) needed 1 MRS G SUF-935-00169/00168

(Ipswich) - C HA purchases in Suffolk + non HA purchase in Oldham(own funds)

None as no fraud found/suspected

2 MR M OLD-353-89192/353-89193 (Oldham) - C

HA Grant cards returned as Mr M confirmed he did not want them

None as no fraud found/suspected

3 MK’s Mobile Phone theft from Oldham HA Unit C

Mobile phone stolen from secure interview room

None as theft not fraud but security issues re corridor access & archive doc safe

4 Additional sales of non-HA kit by Comet Suffolk C

Comet confirmed sale of Sony laptops

No fraud found as such but issues with Comet approach

5 RE: Computers for Pupils (CfP) - B

HA kit given to learners in family with CfP computer already to brother/sister in the same family.

RF to vet cases on next Audit of Oldham but will be hard to tell intentional/accidental fraud re human error by the applicants

6 Is Home Access Pilot ‘kit’ being sold on EBay? C

Since inception of HA Pilot a concern if nature of programme would see HA ‘kit’ sold on EBay

Audit of EBay shows no definite evidence of fraudulent sales of HA ‘kit’ in area around the HA Pilots

7 Home Access Non-Accredited Package Sale C

As at 25/3 found 1 instance of non-HA kit sold with grant card.

None as no fraud found/suspected on this case

8 Home Access TV Sale (Ipswich) - C

Rumour of a Comet Store had sold TV via HA Programme

Treat as anecdotal at present & not as Fraud

9 Out of area schools 8/4/2009 - B/C

Reported potential 14 instances of successful applications via Oldham for Rochdale schools

Currently the resolution of these cases is not known to RF who is still awaiting advice from Oldham

10 Oldham call centre - B Claim for child not living with father Fraud suspected – no proof after detection.

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