Memorandum submitted by The Department
for Work and Pensions (DWP) (EP 14)
SUMMARY
This memorandum is provided by the Department
for Work and Pensions (DWP or "the Department") as a
contribution to the Work and Pensions Select Committee's inquiry
into the management and administration of contracted employment
programmes.
DWP spends around £1 billion
a year on Contracted Employment Programmes. The Department manages
the performance of providers and their contracts to ensure that
public money is safeguarded and payments are only made for legitimate
outcomes. Allegations of fraud or wrongdoing by providers are
always investigated.
The Department is undertaking a major
programme of work to strengthen its approach to performance management
and provider assurance. Against a backdrop of significant rises
in the number of people using Contracted Employment Programmes,
enhanced measures, processes and systems are being introduced
into all Contracted Employment Programme contracts over time through
a revised contractual model, starting with Flexible New Deal in
October 2009.
The Department is re-organising its contract
management as part of a wider review of the way DWP commissions,
sources, awards and monitors contracts. Its Commissioning Strategy,
published in February 2008 sets out the Department's ambition
to develop more strategic relationships with providers and to
operate fewer, larger and longer contracts.
In September 2009 there were 374 providers
running 849 contracts. This was down from 438 providers
running 1,153 contracts in March 2009 and 2,058 contracts
in January 2007.
1. INTRODUCTION
1.1 DWP spends around £1 billion
a year on Contracted Employment Programmes (CEPs). Ensuring that
this money is being spent effectively and appropriately to reduce
costs and achieve value for money is at the heart of DWP's strategy
for managing its providers and assuring payments made to them.
1.2 The Department has always insisted on
the highest standards of probity in relation to claims and payments
for providers' activities and always investigates any allegation
of fraud and wrongdoing.
1.3 The Department is engaged in a major
programme of change across all aspects of the CEP system which
has required a strengthening of its approach to performance management
and provider assurance.
1.4 In 2007 the Department centralised
the management and development of CEPs which had previously been
operated as an adjunct to Jobcentre Plus' local activities. This
structural move was made to create the conditions to drive through
a more strategic and integrated approach to commissioning contracted
employment provision.
1.5 DWP published its Commissioning Strategy
in February 20085.[52]
It sets out how DWP plans to develop more strategic relationships
with providers. As a result of this rationalisation and strengthening
of the system DWP has streamlined the number of contracts it has,
and the number of providers the Department contracts with at the
top tier level. The Department is shifting from paying for inputs
and process steps to paying for outcomes wherever appropriate,
to achieve a step change in performance and quality.
1.6 DWP's system for managing the performance
of providers and their contracts to ensure that public money is
safeguarded and payments are only made for legitimate outcomes
has the following key features:
Contracting, to set performance targets
and establish the framework of requirements on providers;
Controls and assurance, to check that
providers are accurately recording and claiming for legitimate
outcomes and that payments are being made accurately, and to assess
the continued operation of controls;
Contract management; to keep providers
to the highest standards of performance, quality and compliance,
and to secure improvements where shortfalls are identified; and
Investigation of alleged or identified
irregularities, in which the Department's Risk Assurance Division
is a key player.
1.7 DWP is strengthening its fraud prevention
measures and its controls against fraud and error. This enhanced
approach includes embedding the four key principles that DWP is
in the process of applying to all its providers delivering CEPs:
There must be a "whistleblowers
charter" in place, enabling supplier staff to report inappropriate
behaviour by colleagues in respect of performance claims.
Performance management systems within
the organisation must not generate perverse incentives among individual
employees to falsely claim performance achievement.
There must be segregation of duties within
the supplier's operations between those achieving performance
and those reporting it to DWP: between claim and validation.
An internal audit regime must be in place
which provides for periodic checks of the performance reporting
regime.
1.8 DWP is currently in a transitional period
as it implements its programme of change. The Department expects
the changes that it is making will enhance the way it manages
its contracts to prevent fraud and error, ensure the highest levels
of customer service, help more people into sustained jobs and
safeguard public money.
2. SAFEGUARDING
AGAINST FRAUDULENT
CLAIMS
2.1 The Department has robust control and
assurance arrangements in place to guard against fraudulent claims
being made by providers. These include processes to validate payments,
the assurance regime over providers' systems of internal control,
and the wider control environment.
2.2 Over the past year the Department has
reviewed its strategy for preventing fraud, and the controls it
has in place to protect against fraudulent claims. This is in
response to the new challenges of assuring outcomes and payments
in a changing environment. Providers are delivering higher value,
longer contracts with less prescription. They are under increasing
pressure to deliver performance against a backdrop of significant
rises in the number of people using Contracted Employment Programmes
(CEPs).
2.3 DWP is in a transitional phase as it
implements a programme of work to strengthen its fraud prevention
measures and controls. Payment and performance policy and processes
are being standardised and streamlined, more stringent fraud prevention
measures are being introduced into CEP contracts, and the focus
and remit of the assurance regime over providers is being broadened
and strengthened.
2.4 Many of the enhanced measures will be
introduced through Flexible New Deal contracts, starting in October
2009. The Department is planning to apply the strengthened measures
to all its CEP contracts with a value of £3,000 or more
over time.
Checking and validation of payments
2.5 Providers are required to submit claims
for payment which are subject to validation by the Department.
The claim form includes a declaration from the provider confirming
that they are only claiming for payments to which they are entitled.
2.6 CEPs have grown up over time, each successive
programme having its own model for making payments and its own
definitions of performance. DWP applies the same validation principles
across all its provision, but the validation measures vary according
to the type of provision and the funding model used.
2.7 DWP has standardised the way it funds
provision and the outcomes it pays for. The new standard funding
model and outcome definitions are being applied to Flexible New
Deal, and will be applied to new programmes going forward. There
will however continue to be a range of different contract outcomes
paid for across CEP contracts for the foreseeable future.
2.8 The principle that DWP applies to validate
payments is that the evidence must support the definition of the
outcome being claimed. In some cases that means that job outcomes
may be evidenced by way of a check (using our IT systems) to establish
if the person for whom the outcome has been claimed has stopped
claiming benefitan off-benefit check. In other cases providers
are required to supply the supporting evidence, either from the
employer or the individual.
2.9 If either the "off benefit"
check fails or the evidence supplied by the provider is not satisfactory
then the provider is asked to provide further evidence within
a specified timescale. If further evidence cannot be provided
the claim will not be paid or monies will be recovered as appropriate.
2.10 The sample of outcome claims that are
validated can range between 10% (where the provider supplies evidence
from the employer/individual) up to 100% (where an off-benefit
check is used as the supporting evidence).
2.11 The Department recognises that improvements
can always be made in its methods for providing evidence for outcomes.
A review of its current arrangements is planned to start in late
autumn 2009.
Assurance regime
2.12 DWP has a robust system of controls
and assurance in place to deter, prevent and detect fraud. These
are in the process of being reviewed and strengthened as the Department
responds to changes in its organisational structure and in the
way it conducts business with providers.
2.13 When the Department is letting contracts
it seeks assurance from providers that they have policies and
procedures in place to act as a deterrent to fraud across their
organisation and sub-contractors.
2.14 All CEP contracts have historically
contained clauses requiring the provider to use their best endeavours
to "safeguard the Authority's funding of the Programme(s)
against fraud generally and, in particular, fraud on the part
of the Provider's directors, employees or sub-contractors".
CEP contracts also require providers to safeguard their systems
against misleading claims for payment, and the provider is also
required to notify DWP if they have reason to suspect that any
serious irregularity or fraud has occurred or is occurring.
2.15 DWP CEP contracts also contain a clause
entitling the Department to terminate the contract in the event
of any act of fraud committed by the provider.
2.16 DWP has been reviewing its processes
to prevent CEP provider fraud and is currently introducing more
stringent and specific requirements for providers to demonstrate
they have robust fraud prevention measures in place.
2.17 From September 2009, all new CEP contracts,
starting with Flexible New Deal Phase One, will specify that provider
fraud prevention policies and procedures must satisfy the requirements
of four key principles. DWP will also amend the bulk of its existing
contracts to include the principles by November 2009. The principles
are:
There must be a "whistleblowers"
charter in place, enabling supplier staff to report inappropriate
behaviour by colleagues in respect of performance claims.
Performance management systems within
the organisation must not generate perverse incentives among individual
employees to falsely claim performance achievement.
There must be segregation of duties within
the supplier's operations between those achieving performance
and those reporting it to DWP: between claim and validation.
An internal audit regime must be in place
which provides for periodic checks of the performance reporting
regime.
2.18 DWP incorporated the four principles
into the Flexible New Deal procurement undertaken earlier this
year. Bidders were required to commit to set out their plans and
systems for meeting DWP's fraud prevention principles. Any bidders
failing to meet a minimum standard when detailing their plans
were eliminated from the Flexible New Deal competition. These
requirements will be included in all new CEP contracts over £3,000,
starting with Flexible New Deal Phase One. DWP is amending its
existing CEP contracts over £50,000 to include the four
key principles from November 2009.
Assurance activity
2.19 DWP is on the point of transition from
old to new assurance arrangements.
2.20 Until summer 2009 financial monitoring
activity was undertaken through a risk-based regime of intelligence
gathering and visits to providers to review the systems of internal
control in place to manage the risks to DWP in relation to CEP
expenditure. This included, amongst other key risk areas, reviewing
the anti-fraud measures providers have in place and validation
of payments.
2.21 Based on their findings, the Financial
Appraisal and Monitoring (FAM) team provided an overall view of
the effectiveness of the provider's systems. Where perceived weaknesses
were identified, these have been discussed with the provider and
an action plan has been agreed to ensure that appropriate steps
are put in place to make improvements.
2.22 DWP has reviewed the role of FAM in
recognition of the structural, organisational and strategic changes
that have taken place since its inception 10 years ago. A Provider
Assurance Function will replace FAM from October 2009; the role
has been upgraded so that all team members will hold or be working
towards a professional qualification. The new Provider Assurance
Team will continue to review providers' systems through a programme
of risk-based visits but the focus of this team has been broadened
to include assuring value for moneynot just payments. The
Provider Assurance Team will therefore also assure the eligibility
of self referred customers. Where customers are referred by Jobcentre
Plus, their eligibility will be checked by Jobcentre Plus itself.
2.23 The Provider Assurance Team will provide
assurance that providers' fraud prevention systems adhere to the
four key principles DWP is introducing into CEP contracts. DWP
is also introducing a set of further checks into the payment and
security processes. These include checking direct with employers
and individuals in a significant sample of cases that job outcomes
being claimed by providers have actually occurred.
2.24 Risk Assurance Division undertakes
investigations in response to allegations arising from DWP staff
or third parties. It operates independently of those responsible
for commissioning, controlling and accounting for the CEPs. Risk
Assurance Division investigations staff are professionally qualified
investigators who assess the quality of evidence in the allegation
and investigate where there are sufficient grounds to proceed.
This typically involves site visits, interviewing people (sometimes
under caution) and examining evidence.
2.25 Minor irregularities and findings of
non-compliance are reported back to contract management and addressed
internally. Where investigators suspect reasonable grounds that
a serious criminal offence has been committed, Risk Assurance
Division will refer the matter to the police, where there is sufficient
evidence.
2.26 Where it identifies any significant
control issues relating to the Department's business and those
with whom DWP contracts, it reports these to the Permanent Secretary
and Departmental Audit Committee, a non-executive committee of
the Department.
2.27 During the period 1 April 2006 to
31 August 2009, 78 allegations have been subject to
investigation by the Department. Of the 72 investigations
that have completed:
in 14 cases the investigation discovered
evidence that documentation included, or might include, deliberate
false representations, typically in relation to client signatures
or details of the service provided; and
in another 16 cases, irregularities
were considered to be issues of contract compliance (eg invalid
documentation to support claim or full conditions not met to warrant
claim), with no clear intention of making an unwarranted gain
or causing a loss to DWP.
2.28 During the same period, five investigations
undertaken by Risk Assurance Division have resulted in a referral
to the police. In other cases where deliberate false representations
were suspected, police referral was not considered appropriate
because the amounts involved were low in value (ie typically less
than £2,000) or no clear culprit could be identified.
2.29 In the same period over 400,000 customers
were helped into work through CEPs. In none of the cases investigated
did the Department conclude that a provider was engaged in a systematic,
organised policy of seeking to obtain invalid payments through
fraud. Typically, in the few instances where it has been necessary
to hold an investigation, Risk Assurance Division found a combination
of illicit behaviour by individuals and inadequate management
oversight and controls on the part of providers.
Wider control and assurance arrangements
2.30 Other control mechanisms are in place
to guard against fraudulent claims.
2.31 The Department's pre-qualification
and evaluation process stringently tests the suitability of bidders:
The Department will treat a bidder as
ineligible to tender in cases where it becomes aware that they
or their directors (or other person who has power of control)
has been convicted of any of a range of specified offences including:
The Department treats a bidder as ineligible
to tender in cases where it is (or becomes) aware that any of
a number of specified circumstances apply to the bidder, including:
criminal conviction relating to business
conduct; and
grave misconduct in the course of his
business.
2.32 Contractual arrangements require the
provider to have monitoring procedures in place to track the progress
of participants. This tells them when they have entered into employment
and if they have sustained this employment for the required period.
2.33 Where DWP, either through the new spot
checks, routine assurance visits or day to day contract management
activities, suspect irregularities within the delivery of the
contract it can use the expertise of Risk Assurance Division who
are permitted immediate access to all records to undertake the
necessary investigation.
2.34 All cases of improper or fraudulent
practice are taken seriously even if they only involve a single
individual. In cases of organised fraud the Department would terminate
a contract; however, DWP is committed to underlining with providers
the seriousness of any instance of fraud. These include commitments
to ask for a Board level response from the company, detailing
the actions that they have taken, before considering the next
steps.
2.35 If DWP is misled and suffers loss,
it will recover any amounts paid in respect of invalid claims
made by the provider as well as damages that are appropriate.
The Department will also seek clarification and assurances from
the provider in respect of any disciplinary matters or procedural
changes it deems appropriate. If the Department discovered that
a provider was deliberately seeking to submit false claims with
the knowledge and/or collusion of senior officers of the organisation
the contract would be terminated immediately.
Improving management information
2.36 The Department's approach toward monitoring
provider performance is undergoing a fundamental change. In the
past each programme has had its own definitions of performance
and processes for collecting management information. The measurement
of, and indeed the payment for, performance has rested on the
SL2 data collection form (a carbon paper form with a high
incidence of mis-recording).
2.37 From October this year DWP is introducing
a new Provider Referral and Payments system (PRaP), starting with
Flexible New Deal. PRaP is an electronic, web-based system which
will handle all transactions between Jobcentre Plus, providers
and DWP to do with the referral and progression of customers and
the payments providers receive for getting and keeping them in
jobs.
2.38 PRaP will provide the Department with
fully up to date performance information across providers and
programmes based on standard definitions of what is meant by "job
outcome" and "sustained job outcome". PRaP is also
key to embedding the highest standards of data security in our
providers. PRaP will roll out to all DWP provision over time.
3. WHISTLEBLOWERS:
PROTECTING THE
EMPLOYEES OF
PROVIDERS
3.1 DWP requires all Contracted Employment
Programme (CEP) providers to demonstrate their commitment to prevent
fraudulent activity and ensure integrity throughout the supply
chain as a whole. These requirements are set out in DWP's four
key principles, which will be included in all new CEP contracts
over £3,000, starting with Flexible New Deal Phase One. DWP
is amending its existing CEP contracts over £50,000 to
include the four key principles from November 2009.
3.2 The principles include a requirement
for providers to have a "whistleblower" system in place
to enable delivery staff to report inappropriate behaviour in
respect of performance claims.
3.3 The Department Provider Assurance Team
will check for compliance with these requirements by asking the
providers to complete a Provider Systems Questionnaire, and by
gathering intelligence and findings from Departmental colleagues
who have day to day dealings with providers. This will be followed
up by a visit to the provider to confirm what they are telling
DWP is right. During the visit the Provider Assurance Team look
for evidence that the "whistleblower" system is in place,
that staff know it exists and what to do in the event that they
have concerns. Evidence is gathered through detailed process walkthroughs
and testing. This can include talking to employees to establish
their level of knowledge of relevant systems.
4. DWP APPROACH
TO CONTRACT
MANAGEMENT
4.1 DWP is engaged in a major programme
of change across all aspects of the Contracted Employment Programme
(CEP) system which has required a strengthening of its approach
to performance management and provider assurance. The key principles
of this programme are set out in the DWP Commissioning Strategy.
4.2 DWP has re-organised its contract management
structure and process. The re-organisation of DWP's contract management
was part of a wider review of the way in which DWP commissions,
sources, awards and monitor contracts. This review culminated
in the publication of the Commissioning Strategy in February 2008.
This strategy includes the ambition to operate fewer, larger and
longer contracts. In September 2009 there were 374 providers
running 849 contracts. This was down from 438 providers
running 1,153 contracts in March 2009 and 2,058 contracts
in January 2007.
The impact of the centralisation of contract management
4.3 Central to the Commissioning Strategy
is the ambition to develop more strategic relationships with providers.
The Department will move away from a basic contract compliance
model and into an approach where future thinking and insights
from other delivery/management experience will be shared, with
the aim of identifying opportunities for efficiency gains or better
outcomes. DWP will be looking to providers to signal changes they
are experiencing in customer characteristics so that the Department
can factor that into policy development.
4.4 It is that Commissioning Strategy vision
that the Department has pursued through the centralisation of
contract management and the strengthening of performance management
and controls systems. Moving to having fewer, longer and larger
contracts requires further shifts and a move to Supplier Relationship
Management structures, with senior managers responsible for working
with larger suppliers across a strategic and operational agenda,
but backed up by close contract management at the point of delivery.
4.5 In order to ensure that Jobcentre Plus
was fully integrated into the new approach, during 2008-09 a
New Ways of Working project, jointly led by Jobcentre Plus,
DWP Delivery Directorate and DWP Commercial Directorate defined
a standard operating model and clear roles and responsibilities
for Jobcentre Plus' engagement with providers at District level.
This work has now been handed over to Jobcentre Plus and local
Provider Engagement Meetings are taking place.
4.6 The main features of the Department's
current active contract management model are:
active management of relationships with
providers;
regular and frequent Provider Performance
Review process; and
a clear disciplinary procedure for handling
breaches of contract.
4.7 At the hub of the relationship with
providers are DWP Supplier Relationship Managers. They and their
teams meet with providers regularly and frequently to review performance,
contract by contract and the issues arising from that review process,
as well as to discuss the performance and position of the provider
as a whole.
4.8 Provider Performance Reviews enable
a comprehensive, formal on-site analysis of performance led by
the Supplier Relationship Managers. They are completed within
six months of the start of a new contract and, for existing contracts,
on the basis of a risk assessment but as a minimum annually.
4.9 Supplier Relationship Managers draw
on a range of information. to inform the Provider Performance
Review:
The achievement of key contractual performance
metrics (typically job outcomes and sustained job outcomes).
The quality of provision, as assessed
through inspection by Ofsted in England, Estyn in Wales and (from
January 2010) Her Majesty's Inspector of Education in Scotland,
and also through the DWP Quality Framework, which promotes the
commitment to quality improvement through continuous self-assessment
and development planning, culminating in an annual self-assessment
Report.
The standards of compliance as assessed
by the Financial Appraisal and Monitoring team (by the Provider
Assurance Team from October 2009).
Intelligence received from Jobcentre
Plus during regular Provider Engagement Meetings which bring together
providers, contract managers and Jobcentre Plus at a District
level.
4.10 Following the Provider Performance
Review the provider and Supplier Relationship Manager develop
and agree a Provider Development Plan based on continuous improvement.
The plan sets out next steps and review dates.
4.11 For providers who are found to be unsatisfactory
by Ofsted (or Estyn or HMIE) the Department contracts, via the
Department for Business Innovation and Skills through the Learning
and Skills Improvement Service, for support leading up to re-inspection.
The Department also provides support for providers who are not
unsatisfactory overall but who are found to have particular areas
of weakness.
4.12 DWP contracts include a "Provider
Default" clause, which details the Department's approach
to breach. Repeated or continual failure to meet performance target(s)
constitutes a serious breach. In this case the Supplier Relationship
Manager will serve a written termination notice on the provider
giving sufficient detail of the breach. The provider and Supplier
Relationship Manager will meet to agree how the breach will be
remedied and detail this action within a contingency plan. If
the provider fails to meet the action outlined within this plan
the Contract Manager may serve 28 calendar days notice to
terminate the programme/contract. During the course of the last
six months DWP has taken action to terminate the poor performing
elements of provision within CEP contracts in two instances.
4.13 The Department is developing a new
Star Ratings performance tool. Its purpose is to produce, for
each programme, a forced ranking of provider job entry, quality
and contract compliance performance every six months expressed
in terms of the number of stars achieved.
4.14 Star rating was developed with input
from providers and is currently used in Employment Zones. Employment
Zone Star Rating results are published every six months on the
DWP website.[53]
The Star Rating model will be applied in Flexible New Deal, where
it will be used every six months to adjust market share between
competing prime contractors. DWP expects Star Ratings to be a
powerful driver of continuous performance improvement. Flexible
New Deal Star Ratings will be in the public domain and published
on the DWP website.
Contract management in the prime contractor model
4.15 In the prime contractor model the Department
holds the prime contractor to account for the delivery of performance
and quality throughout its supply chain of partners and sub-contractors.
The contracting process for new programmes requires bidders to
provide detailed information about their delivery model and the
contribution that each of their sub-contractors will make. These
arrangements are transparent (details will be published on the
DWP web site) and will be reviewed regularly as part of contract
management, as described earlier.
4.16 At the same time the Commissioning
Strategy committed the Department to a market stewardship role:
playing an active and transparent role to ensure that smaller,
local providers, who have the capabilities needed and who perform
well, can flourish and develop. A central part of this role is
provided by the Code of Conduct which was published as part of
the Commissioning Strategy and which forms part of contracts for
new programmes starting with Flexible New Deal.
4.17 The Code of Conduct states that the
development of smaller sub contracted providers will be supported
and encouraged by prime contractors and that they should provide
a reasonable level of extra support for new entrants into the
market. It also states that funding should be on a basis that
is fair to the different organisations involved and reflect relative
ability to bear particular risks. It was developed in consultation
with officials from the Office for the Third Sector, and used
the principles of the Compact's Procurement code,[54]
and good practice from the Employment Related Services Association
code of conduct.
4.18 Prior to publication of the DWP Commissioning
Strategy, there was no specific Code of Conduct in place to underpin
and support sub contractors. Up until this point, supplier contract
management provided the only route for any advice and support.
Additionally, DWP is contracted directly with a significant number
of providers who are less likely to have lengthy supply chains.
4.19 Therefore as a consequence of the Commissioning
Strategy's prime contractor approach, supply chain management
and development has become more important, increasing the relevance
of, and strengthening, the Code of Conduct. As a direct response
to this, it was proposed that a two year pilot of a "Merlin
Standard" should be developed to produce an industry supported
accreditation process specifically designed to address the Code
of Conduct, taking into account and dovetailing with existing
standards and internal processes. In addition there should be
an arbitration and mediation function to consider grievances which
have failed to be resolved through normal dispute resolution processes.
4.20 DWP will fund this pilot in the early
days, moving towards an outcome of an independent and self-funding
industry led accreditation and information service being in place
by July 2011 (Merlin Standard).
4.21 The Code of Conduct itself spelt out
the key values and principles which DWP expects of providers and
responsibilities of prime contractors. The development of a bespoke
accreditation based standardthe Merlin Standardwill
help embed these principals whilst at the same time provide an
opportunity to drive innovation and best practice across the welfare
to work market. An industry led Merlin Advisory Group will take
responsibility for overseeing the development of the standard
which will draw on existing continuous improvement approaches,
standards and best practice used in the sector. In addition there
will be an arbitration and mediation function which will consider
grievances which have failed to be resolved through normal dispute
resolution processes.
Customer Experience
4.22 The Commissioning Strategy also sets
out how the Department plans to ensure that the customer experience
plays an increasingly important part in the commissioning of provision,
how it is delivered and how it is improved. Jobcentre Plus continues
to own the end-to-end journey for every customer throughout the
life of a benefit claim and has the central role in assuring the
quality of the customer experience. The Provider Engagement Meetings
provide the forum for providers and Jobcentre Plus staff and managers
locally to have regular dialogue at appropriate levels to ensure
that problems are identified and acted upon.
4.23 The DWP Customer Charter has been developed
based on what customers have told the Department is important
to them. It provides a high level commitment to the service standards
that all customers can expect in all their dealings with the Department.
Each area of the Department already has well documented service
standards and these are being aligned with the new DWP Customer
Charter headings of right treatment, right result, right time
and easy access.
4.24 In order to ensure that customers,
Jobcentre Plus and providers know about their rights and responsibilities
and what they can expect of employment programmes the Department
is currently examining the processes, guidance and information
issued when customers are referred to a provider.
4.25 DWP is working on a joint initiative
with the Employment Related Services Association to develop a
statement of rights and responsibilities specifically aimed at
customers using contracted employment provision. This will sit
underneath the wider DWP Customer Charter. It will include details
of the customer complaints procedure. DWP plans to launch this
addition to the DWP Customer Charter in October 2009.
September 2009
52 Cm7330 published February 2008 Back
53
Star rating system is described at http://www.dwp.gov.uk/supplying-dwp/what-we-buy/welfare-to-work-services/star-rating-system/ Back
54
Compact Procurement Code is at http://www.thecompact.org.uk/shared_asp_files/GFSR.asp?NodeID=100698 Back
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