Select Committee on Work and Pensions Seventh Report

5  Future simplification: incremental change

263. During our inquiry, we examined the progress that the DWP has made towards simplifying the benefits system and we welcome the Minister's assurances that further changes are planned in the coming years. He noted:

"You will know that in 2008 there is a big reform of Housing Benefit coming, in respect of tenants in the private sector, with the introduction of Local Housing Allowance. I think that also contributes towards […] simplification […] When we do that we are making the change to the disregard for income from sub-tenancy; that is happening. I have mentioned already the Employment and Support Allowance coming in, in 2008. I have mentioned already, in 2009, the alignment of payment periods. As further work goes forward in other areas of benefit, as we proceed with reform, we will also be able to contribute further towards simplification, in the way that those reforms already announced have done."[309]

264. The DWP Report Getting Welfare Right stated "some benefits can have different rules for similar events; for example, the day on which benefit is paid can differ between benefits. We will try to align these rules, paying careful attention to the balance between the need for simplicity and a reduced level of error and the impact further legislative change may have on our customers and the benefits system."[310]

265. In light of the persistent obstacles that complexity can generate, we examined what further incremental changes the Government can make in order to achieve gradual simplification of the benefits system.

Alignment of rules and time periods


266. In April 2006, capital limits for means-tested benefits went up, the first increase for most people since 1990:Table 2:
Capital limits (as of April 2006)
BenefitLower Limit Upper LimitTariff or deemed income
Income Support (IS), income based Jobseekers Allowance (JSA) £6,000£16,000 £1 per £250 or part thereof between amount of capital upper limit
Housing Benefit (HB), Council Tax Benefit (CTB) (no upper limit for those getting Pension Credit guarantee credit) £6,000£16,000 £1 per £250 or part thereof between amount of capital disregard and capital upper limit Claimant or partner aged 60 or over: £1 per £500 between lower and upper limit
Pension Credit (PC) £6,000No upper limit £1 per £250 between lower and upper limit
Living in a care home
IS, income based JSA £10,000£16,000 £1 per £250 between lower and upper limit
HB (no upper limit for those getting PC guarantee credit) £10,000£16,000 £1 per £250 between lower and upper limit Claimant or partner aged 60 or over: £1 per £500 between lower and upper limit
PC£10,000 No upper limit£1 per £500 above lower limit

Source: Table compiled using information from Child Poverty Action Group's Welfare benefits and tax credits handbook 2007/2008

267. The table illustrates the alignment of capital limits for means-tested benefits. The upper limit for Income Support and income-based Jobseeker's Allowance went up from £8,000 (£12,000 for those aged 60 or over) to £16,000, bringing it in line with Housing Benefit and Council Tax Benefit. The lower limit went up from £3,000 to £6,000 for claimants aged under 60, bringing it up to the same level as those aged 60 or over. The limits for people living permanently in a care home remained the same.

268. Sue Royston, as we noted earlier in this Report, welcomed the changes to capital rules.[311] However, she also suggested that the Department had a considerable distance to travel if it was to address the inherent complexity of existing benefit rules and time periods.[312]

269. The need to align rules and time periods in order to reduce complexity in the benefits system is not a new concept. The NAO report into benefits complexity suggested that "horizontal interfaces"[313] give rise to complexity when different benefits addressing the same client group are administered in different ways, either by the same or different agencies. For example, complexity manifests itself in different paydays for different benefits, the calculation of entitlement to benefits over different periods, the different frequencies of payment, and through the requirement to report changes of circumstances at different times for benefits and Tax Credits, reflecting the different periods for which payment is assessed.


270. Despite the historic nature of this debate, witnesses to this inquiry frequently proposed that further alignment of rules, including definitions of work, would represent a significant move towards simplification. Disability Alliance highlighted the particular anomalies that exist in the rules for students who claim benefits. Paul Treloar suggested to us:

"there are opportunities to go back to first principles and align some of the certain, basic definitions, and how they work around work and students' earnings, some of these kind of things, because there are variations across benefits which we struggle to understand, let alone the staff who are working there and let alone the people who are actually trying to claim the benefits. Students is a good one: the miasma of rules around support for a part-time student across the benefits system is staggering really. If people are going to be encouraged to go and study, it would make much more sense if there were certain basic definitions. We do not understand exactly why there are such wide differences across benefits. It would make sense, we think, if discrete areas were addressed in some of those issues."[314]


271. Paul Dornan from the Child Poverty Action Group highlighted the different rules for backdating:

"As a very quick example, I am told that there are four different rules for backdating. Four different rules sounds a bit excessive to me, particularly given the difficulty of interpreting those different rules in different cases."[315]

272. John Wheatley of Citizens Advice told us:

"moving towards two weeks and getting rid of the double-dating rule on forms whereby the claim will start from the date the Disability and Carers Service receive it back, which might seem simpler but it is going to have unintended consequences for claimants who will not be able to get advice, for example, before putting their claim in so easily. Other things, like common paydays, might move in the right direction.[316]

273. Sue Royston's report noted that this was a problem:

"There are many different rules governing backdating. Generally in order to claim backdating of a means tested benefit (apart from PC and TCs) the customer needs to show good cause why the claim could not have been made at an earlier stage.

What counts as good cause is different for different benefits. Finding a way through the complexities of what will count as good cause in the various benefits is difficult and time consuming for customers and the staff administering the benefits. It makes a particularly complex situation when entitlement to one benefit follows the award of a qualifying benefit."[317]


274. There are various different rules which determine how much income a person can earn whilst they claim benefits:Table 3:
Earnings disregards in income related benefits - current rates
Standard earnings (single) 5.00
Couples earnings10.00
Disabled, or carer 20.00
Lone parent (not HB/CTB) 20.00
Lone parent (HB/CTB only) 25.00
HB/CTB 16 to 30 hour disregard 15.45
HB/CTB childcare disregard one child 175.00
HB/CTB childcare disregard two+ children 300.00

Notes: 1. The first three disregards apply to all income related benefits; 2. There are different lone parent rates for housing benefit (HB) and council Tax Benefit (CTB); and 3. The last four disregards apply to HB and CTB only.

275. The impact of earnings disregards on different groups was brought to our attention during our inquiry into Incapacity Benefits and Pathways to Work.[318] As the table above shows, for people on Income Support and/or disability benefits, there is a maximum weekly earnings disregard of £20. On the current minimum wage, this equates to less than four hours a week.

276. During the inquiry, Disability Alliance told us:

"It is incongruous if one year someone can do a certain number of hours a week and keep a certain level of earnings but be unable to do the same the following year. This is exactly the position disabled people have found themselves in with the recent increase in the minimum wage."[319]

277. Submissions questioning the complexity of disregards arrangements were also received from Judy Scott and Community Links.[320]

278. In its 2006 annual report, SSAC concluded that complex earning disregards, particularly for Housing Benefit "must be worth consideration in any radical reform of the benefit, and when looking at ways to ease the 'benefits trap' in the short-term."[321]

279. In a research report for DWP, Jane Millar concluded that the rules for part-time work and for the earnings disregards increased complexity because "the rules vary for different groups of claimants and for different benefits".[322] The research concluded:

"Working part-time while receiving means-tested benefits is possible but in practice is restricted by the level of earnings disregards (the amount that is ignored when benefit entitlement is calculated) and by rules which limit the number of hours that claimants and their partners can work. The level of earnings disregards has not been increased by much in recent years. The hours rules for claimants of the major means-tested benefits restrict them to work of less than 16 hours per week and their partners to less than 24 hours per week."[323]

280. In addition to earnings disregards, there are rules that apply specifically to people who are defined as incapable to work, which allow permitted work providing it falls within certain parameters.

281. Permitted work is any kind of work which a claimant who is assessed as incapable of work can do:

  • As part of a treatment programme done under medical supervision whilst a claimant is in hospital or regularly attending hospital as an outpatient, as long as they do not earn more than £86 a week
  • For an unlimited period, as long as the claimant does not earn more than £20 a week (known as the permitted work lower limit)
  • For an unlimited period, as long as the claimant does not earn more than £86 a week and they are in 'supported work' (known as supported permitted work)
  • For up to 52 weeks (or indefinitely in some circumstances, such as if the claimant is exempt from the personal capability assessment) as long as they work an average for less than 16 hours a week and do not earn more than £86 a week (known as the permitted work higher limit)[324]

282. We welcome the changes to rules and time periods the Government has made so far, but during our inquiry we have received evidence to suggest that amendments have not gone far enough. In order to achieve simplification priority should be given to alignment of rules for different benefits, including means-tested benefits. We recommend that the Government recognises this and outlines its intentions on alignment over the next five years, together with reasons for areas of inaction.

Rules for reporting changes of circumstances

283. In order to ensure that the full value of means-tested benefits is realised, it is important that the Government is able to target its financial assistance as accurately as possible. It must aim to strike a fine balance between sensitivity to need and unobtrusiveness. When circumstances change but go unreported this can negatively impact levels of customer error. DWP recently acknowledged this:

"At the moment it can be difficult for customers to find clear and concise information about what, when and how to report changes in their circumstances. This causes unnecessary confusion and results in customers not providing important information to the Department."[325]

284. The rules for changes of circumstances are not the same for all benefits and from a claimant's perspective, understanding what and when you should report changes can be difficult, as we show below.


285. When an Income Support or Jobseeker's Allowance claimant's circumstances change - for example their average weekly working hours change or they are now getting regular overtime - this must be reported immediately to DWP.

286. Incapacity Benefit (IB) is normally awarded for an indefinite period, unless a claimant's circumstances are likely to change shortly after the award. In order for payment of IB to be stopped or adjusted, the decision on entitlement must first be revised or superseded and there a number of rules governing such decisions.


287. Claimants of Housing Benefit must report any change in circumstances that might affect their claim promptly in writing to the office handling their claim (unless an individual's circumstances exempt them from this requirement). In the rules for Council Tax benefit, the reporting structure is the same, although claimants can report changes over the telephone if their local office provides a telephone claim line.

288. For the purposes of Council Tax benefits claims, individuals do not need to notify any changes in rent or tell the local authority the amount of council tax they pay. However, if a claimant receives a second adult Council Tax rebate, they must give written notice of any changes in the number of adults living in their home and any changes to their gross income.

289. If a claimant is also in receipt of Pension Credit, they must report: any change to their tenancy, apart from changes in their rent if they are a local authority tenant; any changes affecting a non-dependent normally living with them or with whom they normally live; any absence from their home which is, or is likely to be, for more than 13 weeks.


290. Although Tax Credits are part of HMRC's remit, it is worth noting that the reporting structure for changes of circumstances is different again. Tax credit awards are initially calculated with respect to the previous tax year's annual gross income. The award runs for up to the next 12 months, with an annual renewal at the end of the tax year. Recipients are required to report certain specified changes in circumstances to HMRC - in which adults head the family, in discontinuing or significantly reducing the cost of childcare - during the period of an award. Families can choose to report other changes (e.g. children leaving home, change in usual hours of work) but they are not required to do so until the end of the tax year. However, changes increasing entitlement must normally be reported during the year, because any associated adjustment to the award will only be backdated for up to three months before the date the change is notified, and many problems have been associated with delayed reporting of changes decreasing entitlement, with a large number of families later struggling to repay overpayments.

291. The consequences of the retrospective annual reporting structure was examined as part of the Public Accounts Committee's recent inquiry into Tax Credits and has not been considered in this report. The Public Accounts Committee concluded that "a system of annual awards based on circumstances which often change inevitably results in a substantial amount of overpayments."[329]

Fixed awards?

292. A number of witnesses to this inquiry commented on the frequency with which claimants are required to report changes in circumstances. Janet Allbeson from One Parent Families suggested that the system which administers Housing Benefit did not have the capacity to manage the sheer number of times that a claimant's circumstances may change:

"If I can make one extra point on change of circumstances, for policy design, frequently they have a model person who is fairly static. The models do not take on board how swiftly people's circumstances change, particularly those of working age. Tax Credits made that mistake, Child Support has made that mistake. The systems just cannot cope with it. Housing Benefit cannot cope with it. In a sense, it is modelling systems around real live claimants. It may be one method would be more fixed awards to give some stability, but certainly a customer-focused, client-centred view has to recognise how complex people's lives are and how they change."[330]

As a solution she proposed:

"more consideration of fixed awards as a quick hit [for simplification], Housing Benefit, say, six-monthly […]I think these fixed awards are worth considering, because it is not just about income; it is also about security of income; that is something that people worry about."[331]

293. The DWP Report Getting Welfare Right stated that the Department was looking at making it easier for claimants to report changes of circumstances, as we have already noted in the section on the claimant experience, but its strategy was clearly focussed on publicising the procedures and administrative arrangements rather than changing the rules.

294. Recent performance in Housing Benefit has been particularly poor, with indicators of official error rates increasing by 40% between the 2002-03 baseline and 2005-06, and customer error increasing by 79%. In a note to the Committee the Department explained that "the vast majority [of customer error] is attributable to a failure to declare changes at all or to declare them too late to prevent an overpayment occurring.[332]

295. We agree that claimants should expect to report changes in their circumstances to the relevant agency. However, witnesses have made a strong case for the Government to examine the frequency with which claimants must fulfil this expectation. We therefore recommend that the Government undertakes a systematic review of the rules for reporting changes of circumstances and the impact of existing reporting periods, particularly for Housing Benefit.

The impact on claimants of different uprating measures and the consequences for poverty eradication

296. The Joseph Rowntree Foundation (JRF) argued that the various measures used to uprate different benefits are themselves significant causes of complexity:

"Regimes for different benefits and Tax Credits vary from increasing in line with earnings to not increasing at all, with at least five variants, as shown in the following table: Table 4:
Current uprating "default" basis At least in line with average earnings Inflation or £2 a week, whichever is higher RPI inflation RPI excluding housing costs No increase
ExamplesPension Credit guarantee element and Child Tax Credit child element State Retirement Pension All contributory benefits and some non-contributory ones including Child Benefit Income Support, Jobseekers Allowance, Housing Benefit, Council Tax Benefit Child Tax Credit family element, income disregard for Working Tax Credit

Source: Joseph Rowntree Foundation memorandum (Ev 157)

297. JRF suggested that the use of different measures to uprate benefits can mask income inequalities of benefit claimants, particularly where the benefit they claim rises in line with prices as opposed to earnings, noting:

" Where benefits are uprated in line with prices rather than earnings, this may mean only foregoing a 2% rise in a single year, but potentially a 50% rise in a generation. Indeed, over the past 25 years, relative poverty has deepened in large part because basic benefits (e.g. the single rate of Income Support/Supplementary Benefit) were as much as 40% lower, relative to earnings in 2006 than in 1981.

"A simplified benefits system may potentially reduce these anomalies. A current JRF project based at the University of Essex is looking into the implications of different systems of benefit uprating, modelling various options and making international comparisons. To a large extent, differential uprating policies may be seen as a method of gradually restructuring entitlements over time without creating too much disruption to the system, but if so there is a case for making these decisions and the rationale for taking them more explicitly."[333]

298. We recommend that, following the publication of the Joseph Rowntree Foundation's research into different systems of uprating, the Government undertakes an assessment of the impact on claimants of different uprating measures and the consequences for poverty eradication.

Automatic payment of benefits

299. The onus to register entitlement currently rests with the claimant; there are complex rules governing the point at which a claim is deemed to be made and the subsequent periods in which claims can be backdated. Help the Aged suggested that radical reform of the payment process for benefits could overcome the costly impact of error and encourage more individuals who are eligible to claim benefits they are entitled to. It argued that a system of automatic benefits payments:

"would simplify the front end of benefits delivery effectively meaning that claimants would be shielded from much of the complexity. Only radical change like this will ensure that complexity in the system does not mean people missing out on the help they need."[334]

And added:

"The system would take the onus off the individual to behave as an active citizen when claiming benefits. Instead people would be proactively informed of their entitlements without having to lift a finger. This would reach people who hadn't heard about benefits, those who hadn't got around to making an application and even those who had thought benefits weren't for them. For people who are very hard to reach because they are particularly isolated or perhaps face language or cultural barriers in accessing benefits this service could have a huge impact."[335]

300. The Pension Service Solution Centre in Glasgow has looked at the feasibility of automated payment of Council Tax Benefit, with positive results. Help the Aged suggested that this could be extended to cover the benefits system more widely. It said:

"Central to the solution of paying people Council Tax Benefit automatically would be the use of predictive analytics. To begin with, data on individuals' incomes would need to be compiled from data Government already holds. Then, for those who fell into the bracket of being potentially eligible for benefits, data would need to be compiled on their savings. HMRC and the Treasury receive year end returns from banks and building societies on the amounts of interest paid on individual's accounts. It would be necessary to use these returns in order to reverse generate a savings figure for each person based on a standard rate of interest. The savings figure could then be matched to the income allowing an assessment to be made of whether the person would be eligible for Council Tax Benefit. This profile could then be passed to local authorities to process. There are a number of ways the application could then be taken forward ranging from light touch to asking people for a full range of proof to back up the data profile. The approach taken would depend on how Government and local authorities wish to handle risk. [336]

301. Alexis Cleveland, Chief Executive of the Pension Service, told us that more could be done to improve the system of payments being used in the Pension Service:

"What we are working on - and this has not yet been finalised - is that there is no reason, once we have that information, if we can do the same for Housing Benefit and Council Tax Benefit as we have done for State Pension and Pension Credit, and change the legislation so that you no longer need a signature - because we will have that call recorded, we will have the information for that - we could then send the information direct to the local authority. The evidence we have so far is that, even when we send out all the data to the customer and all they have to do is sign it and put it in the envelope and post it off, up to 50 per cent of people do not."[337]

302. We recommend that the Government publishes the findings of the Pension Service Solution Centre project into automatic benefits payments and examines the feasibility of introducing automatic claims and payments to other parts of the benefits system.

Introduction of the Employment and Support Allowance (ESA): Implications for the Customer Account Management System (CAM) and the Customer Management System (CMS) IT systems


303. We examined the contribution that IT systems have made to benefits complexity in terms of system design and administration, and we heard evidence from witnesses who were concerned that the Pension Service's CAM system, which is the model on which the new Employment and Support Allowance system will be based, may be unsuitable.

304. In his Draft Report seeking authorisation for spending on the Employment and Support Allowance IT system before Royal Assent to the Welfare Reform Bill, the then Secretary of State for Work and Pensions, the Rt Hon John Hutton MP, said:

"Jobcentre Plus, in consultation with the Department's Director General for Information Technology, has considered options for developing the IT system to support ESA. As a result, and subject to a more detailed design review, Jobcentre Plus recommends basing the system on The Pension Service's Customer Account Management System (CAM) (which is based on Siebel, the Department's preferred product for handling customer contact) and linking this to a modified Jobseeker's Allowance Payment System (JSAPS). This would mean that the development will be similar to the one used to deliver Pension Credit successfully in 16 months from Royal Assent to A-Day (the day from which the Department will start to deliver ESA to new customers)."[338]

305. However, Tom Penn from the Public and Commercial Services Union (PCS) was not optimistic about the chances of successful roll-out of the Customer Account Management System to accommodate Employment and Support Allowance. He pointed to the current underperformance of the Customer Account Management system:

"If there is any variation, for example, a mortgage or an occupational pension, then the CAM cannot deal with that and the claim has to be taken off and built on the legacy systems. The details that have been reported to me today were that up to 80% of claims are not doable end to end on CAM. Those are the figures that are given to me. If that is the case I am less than optimistic of it being rolled out across Jobcentre Plus where there is perhaps not as much variation but there is still a lot of variation. From a PCS perspective we are doubtful that the system as it stands could be rolled out without severe damage to the payments system."[339]

306. We were disappointed to learn of the problems being experienced in the operation of the Customer Account Management System. We are particularly concerned about the implications this may have for the introduction of Employment and Support Allowance, which will operate using this model. We recommend that the Government urgently investigates these issues in order to avoid the IT problems that have been associated with DWP systems in the past.


307. Release 3 of the Customer Management System went live on 31 October 2005 and so far it appears that the replacement system has overcome the problems of its predecessor models. In answer to a House of Commons written question, Jobcentre Plus Chief Executive, Lesley Strathie, explained that CMS 3:

"ha[d] been driven by user feedback and introduced a number of enhancements that make the process easier to follow and reduces the opportunity for error and the subsequent need for re-work. The enhancements to CMS Release 3 have been well received by staff."[340]

308. The Committee was told by Tom Penn from PCS that the Union had not received any significant complaints from its members about the system's operation. [341]

309. We commented on the failure of previous CMS models during our inquiry into the Efficiency Savings Programme in Jobcentre Plus in 2005. We concluded that there had been a significant amount of wasted spending on CMS given that the system very quickly required redevelopment following its introduction.[342]

310. During our evidence session with the Minister and the Divisional Manager for Benefit Reform, Brendan O'Gorman, we learned that once ESA has been introduced, it is likely that the DWP will replace CMS:

"My understanding is that ESA will use a system for gathering information from the customer which is used already in the Pension Service. It is a rather better system than CMS, it is more intelligent, it helps our operative to know what we know already about the customer from system records which we possess already, and ultimately we would be using that along with the other benefits administered by Jobcentre Plus. It will take time to introduce, and perhaps what the Committee was hearing was that there will be a period of incompatibility, but ultimately we are looking towards an improved system of gathering information from the customer which will be compatible across the piece [...] CMS will be replaced, as I understand it."[343]

311. The Committee asks that the Government provide a clear rationale to explain its future plans for the Customer Management System and considers the impact of the serial introduction of short-lived IT systems on the administrative complexity of the benefits system.

Can incremental change increase complexity?

312. We noted in an earlier section of this report that there appears to be a lack of overarching strategy in DWP for simplification. Paul Treloar from Disability Alliance made the point that there were real risks to a piecemeal approach:

"We do think there is an absence of any high-level strategy co-ordinating this, and I think the piecemeal approach increases complexity each time. Sometimes, for example, the Benefit Simplification Unit will make changes to one particular aspect of the benefits system which can have unintended consequences on other parts. John mentioned the linking rules earlier on, where the linking rules have been extended for Incapacity Benefits to 104 weeks now, but there is a remaining Housing Benefit linking rule which does not fit the same model. Each time one change is made, it seems to pick up another one that needs to be made."[344]

313. As part of its report, NAO examined incremental changes to the benefits system and concluded that:

"the incremental addition of regulations and their interaction with current ones can add to the complexity. Individually, they may make sense, but the cumulative effect can be to create overlaps and ultimately confusion for some."[345]

314. We recommend that the Government do more to ensure that incremental simplification measures do not have unintended consequences for different parts of the benefits system. Just as policy proposals for benefits are now channelled through the Benefit Simplification Unit to assess their impact on complexity, the Committee recommends that proposals for simplification undergo a similarly vigorous impact assessment process.

309   Q 369 Back

310   DWP, Getting Welfare Right: Tackling error in the benefits system, January 2007 Back

311   Q 9 Back

312   Q 17 Back

313   National Audit Office, Department for Work and Pensions: Dealing with the complexity of the benefits system, HC (2005-06) 592 Back

314   Q 90 Back

315   Q 136 Back

316   Q 108 Back

317   DWP, Benefits Simplification and the Customer, Sue Royston, February 2007, p 97 Back

318   Third Report of Session 2005-06, Incapacity Benefit and Pathways to Work, HC 616 Back

319   Third Report of Session 2005-06, Incapacity Benefit and Pathways to Work, HC 616 Back

320   Ev 98 and Ev 203 Back

321   Social Security Advisory Committee, Nineteenth Report, August 2005 - July 2006 Back

322   DWP Research Report No. 351, Part-time work and social security: increasing the options, 2006 Back

323   As above Back

324   Adapted from Welfare benefits and tax credits handbook 2007/2008, Child Poverty Action Group Back

325   DWP, Getting Welfare Right: Tackling error in the benefits system, January 2007 Back

326   Based on information given in Child Poverty Action Group's Welfare benefits and Tax Credits handbook, 2007/2008 Back

327   As above Back

328   As above Back

329   Committee of Public Accounts, Twenty-second Report of Session 2006-07, Tax Credits, HC 487, May 2007, para 2 Back

330   Q 138 Back

331   Q 146 Back

332   DWP, Departmental Annual Report 2007, para 167 Back

333   Ev 157, para 16-17 Back

334   Ev 174, para 34 Back

335   As above Back

336   Ev 174, para 34 Back

337   Uncorrected transcript of oral evidence taken before the Work and Pensions Committee on 27 June 2007, HC (2006-07) 799, Q 44 Back

338   Welfare Reform - To make provisions about social security; to amend the Vaccine Damage Payments Act 1979; and for connected purposes. Report by the Secretary of State for Work and Pensions Under section 82 of the Welfare Reform and Pensions Act 1999. DWP, November 2006 Back

339   Q 272 Back

340   HC Deb, 21 November 2005, col 1674W  Back

341   Q 227 Back

342   Work and Pensions Committee, Second Report of Session 2005-2006, The Efficiency Savings Programme in Jobcentre Plus, HC 834, para 172 Back

343   Qq 342-343 Back

344   Q 107 Back

345   National Audit Office, DWP: Dealing with the complexity of the benefits system, HC (2005-06) 592, p 8 Back

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