House of Commons - Work and Pensions Committee

Management and Administration of Contracted Employment Programmes - Work and Pensions Committee Contents

Memorandum submitted by the Wise Group (EP 02)

1. The Wise Group welcomes the opportunity to comment on the management and administration of contracted employment programmes. We are a social enterprise that has worked to support disadvantaged unemployed people to access and sustain opportunities in the labour market since 1983. In 2008 we were named Charity of the Year by the Scottish Council of Voluntary Organisations and were winners at the Social Enterprise Coalition's Enterprising Solutions National Social Enterprise Awards. In June 2009 we were the only Third Sector organisation to be awarded Prime Contractor status through the Department of Work and Pensions' commissioning process for Flexible New Deal phase 1.

2. The Wise Group has a track record of developing a wide range of successful welfare to work projects, such as the Intermediate Labour Market (ILM) model and Routes out of Prison. Since 2002, we have delivered part of the Government's New Deal programmes and are the main provider of New Deal for Young People, Lone Parents and Disabled People and Employment Zone programmes in West Central Scotland and North East England.

3. Our response to specific questions set out by the Work and Pensions Committee is preceded by some general comments and a summary of our main points. We hope the Committee finds our response useful. We would be happy to expand on any of the points raised in person. Contact details are provided at the end of our response.

SUMMARY OF MAIN POINTS

4. As a large social enterprise that derives all its income from tradable activities, we have developed robust business systems in managing diverse projects for a range of funders. We believe that our systems of quality assurance and accountability are exemplary, and would willingly share our expertise with other providers.

5. Having a dedicated Contract Manager ensures consistent standards across providers. Contract Managers have proved themselves to be simultaneously supportive, rigorous and instrumental in helping organisations to improve their delivery of employment contracts. The process of auditing enables us to benchmark our performance, and ensure quality and consistency.

6. Evaluation of the Flexible New Deal (FND) encompasses monitoring of subgroups of customers and examining how the FND serves their specific needs is vital in ensuring that the needs of those customers who are most difficult to reach and those facing greatest challenges are taken into account and proactively addressed.

7. Sporadic conversations with clients (beyond exit interviews, inevitably capturing only the views of those who "stay the course") are problematic. Greater use of customer satisfaction surveys and mystery shopping results could be useful mechanisms to benchmark performance, and reduce tendencies to "cream".[1]

8. Dialogue needs to be maintained to offset any risk that DWP will become too remote and lack understanding of local needs and contexts.

9. Respective information technology (IT) systems could be integrated in order to streamline claims and to audit the performance of providers. This would not only make dealing with changes in circumstances easier, but would make the verification of results claimed by respective employment providers relatively easily.

10. A Customer Charter would be useful and should stipulate what customers can expect and set out the responsibilities of respective entities, highlighting what government and the provider are doing to help each customer into work and what is expected of the customer.

11. The Wise Group's Code of Conduct mirrors the DWP Code of Conduct Values and Principles, and governs our subcontracting approach. Treating partners with fairness and integrity is at the heart of our business policies and practices.

12. We welcome the efforts of DWP to embed localism into its commissioning practices.[2] We welcome the prime contractor model as useful in not only reinforcing localism, but also building capacity amongst smaller organizations in the Third Sector.

GENERAL COMMENTS

13. As a large social enterprise that derives all its income from tradable activities, we have developed robust business systems in managing diverse projects for a range of funders. In our experience of managing employment contracts, there are rising standards across the board. We would be happy to work with and to promote further improvement in quality and performance with Third Sector organisations. We believe that our systems of quality assurance and accountability are exemplary, and would willingly share our expertise with other providers: we are often cited as an example of good practice by DWP and requested to speak with other providers (for instance, our Progress to Work Link Up contract for the Forth Valley).

14. Our response to this inquiry is based on many years experience delivering employment contracts for DWP and other agencies. We appreciate open communication about any problems that might arise, and welcome the manner in which DWP has worked with us to find and implement solutions. Having a dedicated Contract Manager, for example, ensures consistent standards across providers. Contract Managers have proved themselves to be simultaneously supportive, rigorous and instrumental in helping organisations to improve their delivery of employment contracts.

15. In the competitive market for employment service contracts, it is worth recognising that Third Sector organisations such as the Wise Group often engage with the most disadvantaged groups warranting a more integrated and individualised approach. As Scotland's Enterprise Minister has observed, the Third Sector in Scotland "connects with some of the most vulnerable people in society".[3]

16. We believe that a commitment to the most disadvantaged characterises Third Sector organizations such as the Wise Group and is reflected in our value base. Our value base in turn shapes the way in which we undertake all our operations, including our rigor in accountability, transparency and the manner in which we manage our supply-chains.

ANSWERS TO SPECIFIC QUESTIONS

Are there sufficient safeguards in place to prevent providers from making fraudulent claims for outcomes they have not achieved?

17. In our experience, some employment programmes incorporate more rigorous safe-guards than others. The DWP, for example, conducts regular performance reviews, but the regularity and extent of these depend on the trust an organisation has earned with DWP. This means that the rating of respective providers impacts on how often they are audited (the Wise Group has built up a positive and open relationship with DWP, and has been given full assurance in the majority of the programmes we deliver).

18. Despite this inconsistency in safeguards and processes, the Wise Group has proactively developed processes that are aimed at preventing fraudulent claims. Wise Group staff are not driven by the "carrot" of individual bonuses and we do not operate a financial incentives system. Our management of employment contracts is premised on a high degree of corporate governance and is based on our values. The Wise Group has a strong ethical code and zero-tolerance approach to fraud. We expect our staff to act with honesty and integrity at all times to create a safe environment for staff and customers.

19. The Board of Directors and Senior Management Team maintain an anti-fraud culture and fraud prevention is incorporated into strategic plans, company values and behaviours. This is communicated to staff in the staff handbook; and is reflected in all our agreements with subcontractors, partners and suppliers.

20. The Wise Group policies and practices demonstrate that we have the utmost commitment to safeguarding public funds against misleading claims for payment and have systems in place to notify DWP immediately if we have reason to suspect that any serious irregularity or fraud has occurred or is occurring. Our Fraud Prevention Policy and Whistle Blowing Policy (see below, question 2) outlines staff responsibilities on how to deter fraud, procedures on raising suspicions and actions to be taken if fraud is suspected.

21. The Wise Group's Corporate Quality and Compliance Unit (QCU) that reports to the Director of Strategic Planning, is responsible for auditing all aspects of our provision (both our direct and indirect delivery). This is an in-house quality assurance team, independent of specific projects, that centrally manages our Internal Audit service. It is responsible for a continuous review of internal control systems. The QCU works with the Programme Manager to conduct quality assessment and production of Quality Development Plans.

22. Further elements of our programme management processes worth highlighting are:

— The QCU undertakes an independent assessment of the integrity of all evidence to support delivery and achievements. For example, our internal architecture means that we do not submit claims until we receive the "hard evidence" of a client's outcome in the form of an employer declaration or a copy of a permanent contract. Spot checks are carried out with employers, signatures are verified and evidence is cross-checked.

— Remote audits are undertaken on a monthly basis by randomly selecting customers. The QCU has access to real-time customer data and conducts remote audits on customer information via the Customer Record Management (CRM) system.

— All provision is managed using identical systems (regardless of prime or subcontractor status), creating a fair, accurate and consistent assessment of provision.

— Performance information, quality assessment and customer feedback is collected and analysed on a monthly basis by the Programme Manager which allows immediate response to performance or quality issues.

— Any non-compliance is reported directly to the Programme Manager for further action.

— The QCU conducts a bi-annual quality assessment using the Common Inspection Framework to generate a Quality Development Plan detailing actions to address areas of improvement and build on strengths. This forms part of the annual self-assessment process and Contract Management Review.

— The QCU undertakes internal audits to generate a risk rating for the Wise Group and our subcontractors, informing the frequency of future audits. Internal audits ensure DWP Contract Terms and Conditions are met in relation to delivery, reporting and record keeping, financial claims and evidence requirements.

— Internal audits are followed by an Action Plan confirming good practice, highlighting areas for improvement, risk ratings and necessary actions. Both the Wise Group and our subcontractors are required to respond to action plans to confirm compliance and timescales for completion.

— The responsible person then has two weeks to rectify and address recommendations made by QCU. The report is then returned to QCU detailing the completed actions and remedial actions required, and timescales for undertaking them. All remedial actions are inspected during the follow-up visit to ensure they have been carried out. Service Level Agreements (SLA) specify procedures for contract compliance, audit and monitoring arrangements.

Is there sufficient protection for employees who raise concerns about their employers' delivery of a contracted employment programme?

23. The Wise Group believes that its own internal systems provide sufficient protection for employees if they felt the need to raise concerns about delivery of an employment programme. For example, the Whistle Blowing Policy (found in the staff handbook) outlines the protection for staff and customers who raise allegations. Section 4.2.2 of the Wise Group's Whistleblowing Policy states that:

Where possible the concern should be raised in writing, but a face to face meeting or telephone discussion may be requested to raise the concern in the first instance [...]. All relevant details of the incident, names and dates etc., should be specified and any other evidence to support the concern should be presented in full.

24. Section 5.1 subsequently states that:

The relevant Head of Division and HIA will carry out an investigation into the concern. This will include compiling full written records and evidence, carrying out interviews and reporting.

25. Allegations are then investigated in line with our Fraud Prevention Policy.

26. If the Wise Group was to become aware of a problem involving other contractors we would approach DWP directly, via the Contract Managers.

27. We do note, however, that within the market for employment contracts there is no clearly defined formalised system, and perhaps an Ombudsman (a new role, or incorporated into existing Ombudsman schemes) would be a useful independent mechanism for concerned employees of providers to utilise, anonymously if necessary, outside their own organisation. Given the existence of the Parliamentary and Health Service Ombudsman, perhaps a simple dedicated email address or hotline might suffice.

28. We feel that providers that operate with integrity and the appropriate incentive systems for staff in place will welcome steps taken to facilitate reporting of irregularities.

Does DWP's contract management approach ensure the quality of service received by customers is commensurate with the level required under the contract terms?

29. The Wise Group recognises that contract management of complex services such as employment support is challenging and entails inherent trade-offs. Navigation between competing objectives required by commissioning agencies (such as DWP) was highlighted by recent research into contracted out welfare to work provision in the US. This research reveals a "tension between regulation, transparency and flexibility".[4] There seems to be balance to be struck between flexibility and control, with increased oversight leading to reduced flexibility.

30. It is therefore not surprising that there are certain aspects of the contract management approach that we welcome as they will ensure quality of service to customers as required in contracts, but that there are also areas where we have reservations.

31. DWP has said that its evaluation of the Flexible New Deal (FND) will encompass monitoring subgroups of customers and how the FND serves their specific needs.[5] This is vital in ensuring that the needs of those customers who are most difficult to reach and those with greatest challenges are taken into account and proactively addressed. As highlighted above, the Wise Group has 26 years of experience in working with people facing multiple barriers to employment and we provide tailored support that takes into account the complexity of their circumstances and helps them move forward constructively.

32. The research just cited underscores the importance of skilled contract managers.[6] This is an area where we feel that DWP's contract management approach is entirely appropriate, efficient and positive. We have developed good relations with DWP Contract Managers, which allows constructive criticism and dialogue, rather than adversarial surveillance which would generate secrecy and suspicion.

33. Similarly, we support the requirement for Contract Managers to agree and review areas that respective providers need to focus on for improvement (as highlighted through self-assessment and external inspection).[7] Annual Self-Assessment Reviews will incorporate description of the context in which the provider is operating, and providers will grade themselves in relation to the questions set by Ofsted and Estyn's Common Inspection Frameworks.[8] Self-Assessment Reports will be accompanied by a Development Plan that demonstrates how action will be taken in terms of improvements, and will be monitored by DWP's Contract Management processes.[9] If a provider is deemed to have inadequate performance, they will be re-inspected in 12-18 months and offered tailored support prior to this.[10] DWP Contract Managers will also validate the veracity of provider annual reports. These various provisions seem to incorporate sufficient constructive engagement that will foster continuous improvement, while delivering rigorous scrutiny of performance.

34. We have reservations, however, that while the Star Rating system is vital for increasing the performance of providers and helping customers select amongst providers, the emphasis on voluntary disclosure undermines the system's effectiveness. Essentially, Star Ratings are four-measure scales encompassing performance outcomes (including job outcomes, 70% of the rating), quality of provision (20%) and compliance and contractor issues (10%).[11] Inspection results will be incorporated into Star Ratings—this will go some way to enhancing the dependability of the Star Ratings. Further, as discussed above, the Wise Group has implemented a structure of checks in order to ensure our results and reports are accurate, and again we would be willing to inform other providers about these systems to ensure their own self-reporting is reliable.

35. Given our reservations about the extent of reliance on self-assessment, we are pleased that the DWP has said it will work with HMIe in Scotland (Ofsted in England and Estyn in Wales) to construct a model of inspection, with inspections starting in April 2010.[12] All inspection reports will be published on the external websites of respective inspectorates. This is a positive move, enhancing transparency.

36. Moreover, while customer feedback is provided to DWP (except for the Employment Zone), the current system encompasses only sporadic conversations with clients (beyond exit interviews, inevitably capturing only the views of those who "stay the course"). Perhaps more revealing would be conversations with those who leave their programme early, particularly if their reason for doing so was related to quality of the provider. We feel that greater use of customer satisfaction surveys and mystery shopping results could be useful mechanisms to benchmark performance, and reduce tendencies to "cream".[13] Skills Development Scotland, for example, asks to meet with our clients on relevant programmes.

Do DWP and the National Audit Office effectively monitor the accuracy of providers' management information systems, provider performance against targets, and the evidence on which provider payments are claimed?

37. The Wise Group has a long experience of being audited by various public sector funding bodies, including the European Commission and European Court of Auditors. Our reflection on the DWP and National Audit Office monitoring systems is based on this background.

38. We welcome the process of auditing—it enables us to benchmark our performance, and ensure quality and consistency. In general, we have not found this process to be overly onerous. Instead, we appreciate that an audit can be a helpful undertaking that assists us to refine internal systems, effectively monitor provider performance in relation to targets and ensure the veracity of evidence for claims. In particular, DWP undertakes a "walk through" of our processes, talking to Wise Group operations staff and undertaking quality assessments. In our experience, these activities have become increasingly thorough. For example, they are undertaken on-site at our offices—rather than simply via consideration of paperwork submitted by a provider. DWP also selects a random sample to undertake a quality assessment (an "ICQ").

39. The Wise Group is, however, aware that problems can arise whereby case loads are kept "live" by other providers with the intent of excluding their competitors from serving a customer and claiming a result. In theory, providers share information about case loads, but we feel this intention is overwhelmed by the realities of competition in the welfare-to-work marketplace. This highlights an area where thorough monitoring and scrutiny of each provider's customer records should reduce any capacity for providers to act counter to the objectives of the contract (which would be ultimately detrimental to customers).

How has the centralisation of contract management in DWP impacted upon the role of Jobcentre Plus and both provider and customer experience of outsourced employment programmes?

40. We feel that centralizing contract management with DWP, rather than JCP, makes sense. Employment service providers are required to be active partners with JCP, a relationship which is enhanced by removal of any sanctioning of employment service providers requirement that JCP may have previously been tasked with.

41. Dialogue needs to be maintained with local JCP offices to offset any risk that DWP will become too remote and lack understanding of local needs and contexts. DWP staff need to know what is happening locally, the configuration of the local labour market and how local conditions impact performance. The Wise Group now deals with a DWP team based in Edinburgh, which demonstrates that the Department has addressed previous concerns surrounding a lack of local understanding. Moreover, the location in Edinburgh means our DWP team is close at hand, and can visit the Wise Group at any time they desire.

42. There is a risk, however, that the DWP and JCP have become too isolated from each other. We can identify scope for better liaison between the two agencies, for example, providers need to know who to speak to, and this also applies to internal inter-departmental communications. In order for the customer experience of outsourced programmes to be as effective and valuable as possible, the Wise Group recommends tripartite meetings between respective providers, DWP and JCP.

43. Finally, respective information technology (IT) systems could be integrated in order to streamline claims and to audit the performance of providers. We highlight research into the propensity for customers to report their change of circumstances to necessary agencies. Recent research has found that customers experience confusion regarding what they need to report and to whom: 40% of respondents to a recent large scale survey had "very little or no knowledge of what were the reporting requirements [and] nearly 50% of claimants believe that if they inform one agency of a change in circumstance that agency will inform the others".[14] While we are cognisant of the significant resource implications entailed in integrating IT systems, these findings highlight scope for a reliable system of IT whereby benefit administering agencies are able to link to each other's systems. This would not only make dealing with changes in circumstances easier, but would enable verifying results claimed by respective employment providers to be conducted relatively easily.

Will the customer charter proposed by DWP ensure that customers, Jobcentre Plus and contractors know what they can expect of employment programmes?

44. The Wise Group feels that a Customer Charter would be useful, particularly as part of a welcome pack supplied to customers when they first engage with a provider. It should stipulate what customers can expect and set out the responsibilities of respective entities, highlighting what government and the provider are doing to help each customer into work and what is expected of the customer. We recommend the JCP Customer Charter as a good model of this.

45. Any such document needs to be in an accessible format, avoiding jargon and intimidating language. As with any additional paperwork, there is a risk of over-burdening a customer, even alienating them by providing an overwhelming quantity of documentation. This, of course, is a consideration that needs to be taken into account by all providers in preparation of welcome packs and other forms and information.

46. As part of our delivery of Flexible New Deal Phase 1, we have prepared our own Customer Charter. This is attached as an Appendix for information.

47. An associated issue is that of customer grievances. All organizations who bid for the FND had to demonstrate that they had robust systems of solving customer grievances and complaints. DWP will monitor these processes (via Ofsted and Estyn in England and Wales respectively). The Wise Group welcomes the fact that customers have the scope to raise any complaint with DWP's independent complaints reviewer (the Independent Case Examiner), and, ultimately will be able to take their issue to the Parliamentary and Health Service Ombudsman.

48. The Wise Group is committed to dealing responsibly, openly and professionally with all complaints regarding the service received from Wise Group or from our subcontractors. We operate a four stage complaints procedure ensuring that we take customer needs seriously and provide a fair and effective service at all times:

— All customers are issued with our grievance procedure when they start on programmes.

— The Wise Group seeks to resolve any customer issues in an informal manner in the first instance, through discussion with the individual and a named project representative.

— If unresolved, the grievance is then escalated and the Programme Manager responds to the customer with a proposed solution.

— The customer's JCP Personal Advisor is advised of any difficulties, with all complaints recorded and made available to DWP through Supplier Performance Reviews.

49. The existence and utility of such systems are integral to the rationale of a Customer Charter, and we welcome the latter as a means to reassure customers of their rights and of the existence of systems in place to support them in any circumstance.

50. Customer entitlements need to be monitored through DWP's systems of contract management. This is discussed in the answer to the next question.

Will contract management in the prime contractor model be transparent and effective in monitoring quality throughout the supply chain, and in maintaining a role for sub-contractors?

51. Prime contractors are responsible for the performance of subcontractors, and will consequently need to take responsibility for addressing poor performance and managing any issues as they arise.[15] The Wise Group is a prime contractor for the FND Phase 1 in the South of Scotland. We are responsible for the performance of our sub contractors, and as such they are subject to monitoring and auditing of their performance.

52. As a prime contractor, we are able to contact a single manager at DWP. This is very useful, and conducive to collaborative positive relations in which problems are dealt with quickly and constructively. We also welcome the provision of timetables of inspection now provided by DWP (previously it was ad hoc). This means a prime contractor can notify their subcontractors.

53. The Social Market Foundation has warned of the risk that prime contractors will become single customer buyers of the subcontractor provision, undermining the market's operation.[16] This risk, while valid, will partly be offset by DWP's expectation that prime contractors will provide advance payment to subcontractors.[17] Further, DWP has said that it has incorporated measures into the contracting process that prevent unreasonable transfer of risk to subcontractors. These include requiring that tenders from prime contractors demonstrate funding agreements and outcomes, and a signed letter of intent that subcontractors understand the terms of delivery.[18]

54. DWP's system of contract management is logical: contracts will be managed by DWP's National Supplier Relationship Management Teams and Third Party Provision Managers at district level.[19] Providers will submit monthly performance reports and will be reviewed formally on a quarterly basis on both performance and quality.[20] The DWP's Code of Conduct aims to ensure that supply chains perform well. DWP is the steward of the Code of Conduct and thus will monitor and enforce its terms. If this is rigorous and quality can be enforced, we expect that this Code of Conduct will be a useful mechanism of stipulating that subcontractors undertake what they say they will do.

55. The Wise Group's Code of Conduct mirrors the DWP Code of Conduct Values and Principles, and governs our subcontracting approach. Treating partners with fairness and integrity is at the heart of our business policies and practices, and we ensure adherence to these principles through the following key processes:

— Open Recruitment process, using an open process to recruit subcontractors by advertising on Wise Group website.

— Ensuring Expressions of Interest are fairly scored and short-listed.

— Entering into negotiations with preferred suppliers and notifying those not short-listed within 14 days.

— Service Level Agreements (SLAs), to be finalised upon award of contract (with performance targets; legislative and policy standards; contract compliance; funding and payment mechanisms).

— Each subcontractor/supplier will receive a Guidance Pack containing Quality Calendar; Code of Conduct; Performance Management Procedures; Staff Learning and Development Planner; our Prime Contractor policies and practices; and DWP supporting information (for example, Terms and Conditions, DWP Code of Conduct, JCP Customer Charter and legislative requirements).

— Performance will be monitored and managed across the supply chain using a web-based performance management tool, and in open dialogue with subcontractors (such as monthly planned performance meetings between the Contract Manager and subcontractors).

— Scheduled Quality Assurance activities will be agreed annually and reviewed at monthly meetings, with Wise Group audits to ensure contract compliance, identify and mitigate risks of under-achieving, and highlight quality or capacity issues.

— Risk ratings will inform the frequency of monitoring support.

— We will establish clear lines of communication with subcontractors/suppliers managed by the Provision Manager. We will seek written feedback from subcontractors on our role as Prime Contractor and meeting their needs in terms of support, financial reward and parity.

56. The Contract Manager will ensure any issues are resolved as quickly as possible. If a dispute arises between the Wise Group and a subcontractor that cannot be resolved through the normal complaints process, we will instigate through our Dispute Resolution procedure, outlined in the Service Level Agreement. This involves a number of stages within set timescales: information exchange, meetings, mediation and, if no resolution is agreed, then ultimately litigation. In addition, as discussed earlier in our response to question 1, the Wise Group's internal Quality and Compliance Unit (QCU), independent from delivery operations, will measure compliance with DWP's Code of Conduct on a bi-annual basis.

57. Finally, we welcome the efforts of DWP to embed localism into its commissioning practices.[21] We welcome the prime contractor model as useful in not only reinforcing localism, but also building capacity amongst smaller organizations in the Third Sector. We welcome DWP's work with the Office of the Third Sector as a means to help Third Sector organisations (such as ourselves and those in other providers' supply chain) capitalise on the opportunity presented by contracting out of employment contracts. Third Sector organisations are, as discussed above, adept at supporting clients with individualised assistance.

October 2009

REFERENCES

Fimister, Geoff, John Harvey, William Lovell, David Sands, Ryszard Zaluski-Zaluczkowski and Figen Deviren (2009) Reporting Changes in Circumstances: Factors Affecting the Behaviours of Benefit Claimants Research Report 544, Department of Work and Pensions. London.

//research.dwp.gov.uk/asp/asd5rportsd2009-2010/rports544.pdf (downloaded 21 August 2009)

Finn, Dan (2007) Contracting Out Welfare to Work in the USA: Delivery Lessons, in Research Report, Centre for Economic and Social Inclusion, University of Portsmouth, Department for Work and Pensions: London.

//research.dwp.gov.uk/asd/asd5/rports2007-2008/rrep466.pdf (downloaded 21 August 2009)

House of Commons Work and Pensions Committee (2009a) DWP's Commissioning Strategy and the Flexible New Deal House of Commons: London

www.publications.parliament.uk/pa/cm200809/cmselect/cmWorpen/59/9780215526656.pdf (downloaded 2 September 2009)

House of Commons Work and Pensions Committee. (2009b) DWP's Commissioning Strategy and the Flexible New Deal: Government Response to the Committee's Second Report of Session 2008-09. House of Commons: London

www.publications.parliament.uk/pa/cm200809/cmselect/cmworpen/526/526.pdf (downloaded 2 September 2009)

Mulheirn, Ian and Menne, Verena, (2008) The Flexible New Deal—Making it Work Social Market Foundation: London.www.smf.co.uk/assets/files/publications/SMF_Flexible_New_Deal.pdf (downloaded, 10 October 2008)

Scottish Government (2008) "Third Sector Enterprise Fund" In Media Release. Edinburgh.

www.scotland.gov.uk/News/Releases/2008/12/09101508 (downloaded, 10 December 2008)

1 Finn, 2007: 3 Back

2 House of Commons Work and Pensions Committee. 2009: 4 Back

3 Cited in Scottish Government, 2008 Back

4 Finn, 2007: 3 Back

5 House of Commons Work and Pensions Committee. 2009b: 10 Back

6 Finn, 2007: 3 Back

7 House of Commons Work and Pensions Committee, 2009b: 11 Back

8 DWP quoted in House of Commons Work and Pensions Committee, 2009a: 38 Back

9 DWP quoted in House of Commons Work and Pensions Committee, 2009b: 38 Back

10 House of Commons Work and Pensions Committee. 2009b: 11 Back