| 1. | We welcome the Revenue's willingness to look at the Ombudsman's recommendation to introduce a pause before starting recovery of overpayments. However, we are concerned that, not for the first time, a government department, is presuming to define what constitutes maladministration. Moreover the Revenue seems to suggest that protection of the public purse overrides other considerations, including fairness. Public services cannot be designed or delivered without regard to costs but an unfair system, while it may well be cost-effective, cannot be said to constitute good public administration. (Paragraph 19)
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| 2. | We are concerned that the IT system which is supposed to enable an efficient delivery of the scheme has in fact been a root cause, first of creating some of the problems which have led to the criticism and complaints about the scheme and then of acting as a barrier to resolving them quickly. Careful consideration needs to be given to the design of future government IT-enabled schemes so that it is the needs of the customer rather than the limitations of the technology which are paramount. (Paragraph 22)
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| 3. | We are concerned that the consolidation of the tax and benefits systems represented by the tax credit scheme and the consequent transfer of functions from DWP does not appear to have resulted in any assessment on the part of the Revenue about the nature, and the needs, of this particularly vulnerable group among tax credit recipients for whom regular and reliable payment is not a desirable budgeting convenience but a real necessity. (Paragraph 27)
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| 4. | It is deeply worrying that a scheme such as this one has such unsophisticated means for reconstructing individuals' records. It is essential that any public service scheme which involves a history of transactions between individuals and a department should have at its base adequate case-handling capacity, whatever technology it uses. (Paragraph 30)
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| 5. | We welcome the Revenue's review of the reasonableness test and support the need for a solution modelled on the well-established social security benefits. (Paragraph 34)
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