Written submission from the Chartered
Institute of Housing (CIH)
1. INTRODUCTION AND EXECUTIVE SUMMARY
Introduction
1.1 CIH welcomes the opportunity to respond to
the Department for Communities and Local Government Select Committee
inquiry into the "localisation implications of welfare reform".
1.2 CIH is the professional body for people involved
in housing and communities, with over 22,000 members across the
UK and Asian Pacific. We are a registered charity and not-for-profit
organisation. Our mission is to maximise the contribution that
our members make to the well being of communities. Our vision
is to be the first point of contact for—and the credible
voice of—anyone involved or interested in housing.
General comments
1.3 The Select Committee has already received
written and oral evidence from a variety of organisations. We
have not repeated the comments or concerns of those organisations
due to the need for brevity. As such, our submission concentrates
on documenting lessons learned from previous reforms; and consideration
of how the proposed reforms to housing benefit could be modified
to retain local knowledge and expertise and to reduce the risk
of administrative failure.
1.4 CIH has been extremely active in drawing
attention to the likely impacts of the proposed welfare reforms
on claimants, and on tenants in particular. We are fortunate that
one of the country's leading experts on housing benefit is part
of the CIH team, and this has enabled us to generate credible
and detailed comments on the reforms, often backed up by detailed
modelling.
1.5 A significant part of our work has looked
at the impact of the reforms to housing benefit which are being
implemented from 2010-13, about which we have many concerns. These
reforms will affect many claimants in the next few years—and
they will have negative and damaging impacts for many households.
We will not restate our arguments in great detail here because
most are not localisation issues, but we would of course be very
pleased to make our expertise and modelling available to you if
that would help with your current or future work on this topic.
1.6 There is one particular issue created by
the 2010-13 reforms which we hope Committee members will consider
relevant to the terms of this inquiry. The 2010-13 reforms are
important for the new system of Universal Credit because they
set the baseline features of the housing costs element within
it. This means that some very problematic policies will be embedded
in the Universal Credit, and thus that it will not provide the
support needed by thousands of low income households. Therefore,
whilst Universal Credit will be a national system, there will
be some sizeable local consequences which local authorities and
communities will need to deal with. The method of setting and
uprating the housing element of universal credit; the caps on
the maximum amounts payable; and the restriction on the maximum
total benefit payable all mean that the proportion of the rental
housing market available to certain claimants will shrink. Consequently,
displacement of these households is likely and demand for practical
and financial support at local level will rise.
Executive summary
1.7 CIH has long argued for the introduction
of a universal credit as being the most effective means to eliminate
the deepest part of the poverty trap and to provide a more transparent
pathway for claimants through the complexities of the benefits
system.
1.8 There is a vast amount of administration
skill and knowledge within local authorities which should be of
great value as we design and implement Universal Credit and wider
welfare reforms.
1.9 A partnership model of joint central and
local administration based on existing administrative systems
that have proven to work has better prospects.
1.10 The importance of high quality administration
is a key aspect of ensuring welfare reform is a success and the
importance of consistency at which changes are applied and undertaken
should not be underestimated. CIH notes the limited time period
and we are very concerned about the pace of change.
1.11 Whilst the overall structure of benefits
will be greatly simplified by combining (nearly all) means tested
benefits into a single universal credit, the new benefit will
be necessarily highly complex with three main components, two
of which will be variable. CIH is extremely concerned that this
complexity puts the reforms at high risk of administrative failure
especially given the challenging timetable.
1.12 The relationship between administrative
structures and delivery is complex and the changes to that delivery
may not have the immediate positive impact that government requires.
1.13 There are structures and processes in place
which currently mean duplication of processing through multiple
assessments. Whilst this might be inefficient it does however
allow for claimants to progress from claim to payment with reasonable
speed. It also provides for checks and balances of personal data
to ensure accurate assessment, effective processing, and it also
allows for fraud to be detected.
1.14 Removing locally administered benefits removes
local knowledge on housing costs, housing availability and local
employment issues. CIH argues that this knowledge is vital to
ensure local authorities can deliver effective locally responsive
services for claimants and the wider community.
1.15 The transition period needs to be properly
managed and articulated to all concerned with the process including
claimants who must be protected from disruption throughout this
process.
1.16 Centralised administration is not a prerequisite
to obtain the outstanding feature of universal credit which is
improved work incentives from reduced marginal withdrawals and
is counter to wider government ambitions for "localism".
The failure to include council tax benefit also significantly
weakens the overall work incentive effect.
1.17 Local authority improvements in administration
over the past ten years have been outstanding and have been obtained
through a successful model of partnership working. This model
is being abandoned for an untested system to deliver a highly
complex, untested and at high risk of failure.
1.18 CIH recognises centralising administration
will offer opportunities to improve the current system of processing
claims but it will also create many more challenges throughout
the transitional period and beyond. We are concerned that local
knowledge on the housing and employment situation will be lost
and may lead to a loss of localised knowledge and detection of
fraud. Being responsive to local circumstances is one of the advantages
of the current system and fits with the government's overall localism
and decentralisation ethos. This responsiveness would be compromised.
We agree that universal credit should be a national credit, but
think that is must be delivered and administered locally.
2. LESSONS LEARNED ABOUT GOOD ADMINISTRATION
2.1 The various different systems and administration
arrangements used over the last 30 years to help households meet
their housing costs have taught us a great deal about administration
of benefits. We have learned what enables good and effective administration—delivering
best results for claimants and the tax payer. We have also learned
which approaches are ineffective and inefficient—leading
to waste and tardiness.
2.2 We are very keen that best possible administration
practices are embedded and enabled by the design of Universal
Credit. Lessons from benefit administration history include:
— Where
reforms require several different benefits to be joined together,
care must be taken that the joins are smooth and that cumbersome
procedures are not required behind the scenes to ensure claimants
get equal treatment and outcomes Allowing incremental development
of a benefit system, eg tweaking processes and eligibility to
deal with specific and emerging circumstances, is tempting but
leads to widespread complexity which can hinder both administration
and claimants' experiences of managing their claim.
— Staff
development and professionalization is effective in ensuring smooth,
fast and accurate administration of claims.
— Close
working and consultation with people involved with benefit administration,
and their representatives, gives access to a level of understanding
and experience which can in turn help improve administration speed
and processes.
— Where
assessments for different benefits use different methods of calculation,
people who claim both benefits are financially penalised—in
particular through the tapers which withdraw benefit in line with
increased income.
— Online
claims systems for new benefits can cause major problems for claimants
if they are not fully operational and accurate from the outset.
— The
need for annual review of claims awarded can be removed without
causing problems for claimants or administrators.
2.3 There is a vast amount of administration
skill and knowledge within local authorities which should be of
great value as we design and implement Universal Credit and wider
welfare reforms. The performance improvement achieved by local
authorities in the last 10 years has been so outstanding that
it is now widely accepted that housing benefit, despite being
the most complex of all benefits to administer is now consistently
the best performing service across the whole benefits system.
It would be unwise to loose these skills and knowledge as we embark
on the most radical restructuring of welfare for 60 years.
3. THE IMPORTANCE OF LOCALISM AND LOCAL ADMINISTRATION
3.1 In November 2010, following a public consultation
DWP announced its proposals for universal credit that, amongst
other things, would replace housing benefit with a new system
of help with housing costs that would combine all the other main
working age means tested benefits (JSA/ESA and tax credits) into
a single payment that would be administered centrally by the DWP.
For pension age claims, help with rent will be transferred to
pension credit (in effect a parallel universal credit scheme for
pensioners).
3.2 Although housing benefit will be replaced
(starting in 2013) the 2010 Budget and Spending Review reforms
are significant to the new regime because they set the baseline
features of the housing costs element within universal credit.
3.3 CIH supports the government's efforts to
streamline and simplify the benefits and welfare system having
advocated a system of universal credits for some time. However,
we are concerned that the universal credit as it is proposed to
be delivered and administered nationally, is liable to fail. We
agree that universal credit should be a national credit, but think
that is must be delivered and administered locally. This would
retain local authorities' localised knowledge on the circumstances
affecting their localities (employment and housing) and would
further enhance both the localism and decentralisation agenda.
3.4 This section sets out our reasoning and assumptions
for retaining local administration of the housing costs element
of universal credit and the resulting importance to the localism
agenda. In doing so, we will not set out a detailed case for the
localism agenda as this has been adequately covered elsewhere
in the submissions by other witnesses.
3.5 Housing is an area of competence for the
devolved administrations, although of course social security is
not. There is therefore a strong case for the existing administrative
arrangements to continue whereby a UK wide system of social security
is maintained but the administration is carried out locally.
3.6 In our view, there are numerous reasons why
local authorities are best placed to carry out the administration
of "help with housing costs" element of universal credit,
as follows:
— local
authorities are in the best position to provide a more customer
focussed approach that more effectively integrates housing cost
support with other services (eg Supporting People, social care);
— local
authorities are already delivering effective benefit services
in the most complex part of the social security system. Delivering
a complex new benefit to a tight timescale is a high risk strategy
therefore continuity in the administrative arrangements is a much
better guarantee of success (a point made elsewhere in this report);
— housing
costs vary widely across the country at the local level and therefore
in the interests of good administration it makes sense for this
function to be carried out by locally;
— a locally
administered service enables the authority to respond flexibly
to local economic conditions in way that a centrally administered
benefit never could for example, increased service provision in
response to a localised increase in unemployment (loss of a major
employer); and
— local
authorities are in a better position to be able to assess vulnerability
not least because local authorities already have duties in this
area and because an accurate assessment will require local knowledge
(eg contact with other local statutory and voluntary services).
This point has already largely been conceded by DWP with the decision
that responsibility for discretionary housing payments (DHPs)
will remain with local authorities.
3.7 At present housing benefit administration
is carried out by the same tier of authority responsible for housing
and homelessness. Housing benefit provides a valuable tool for
housing authorities in the performance of these duties for a number
of reasons:
— it
helps provide a source of valuable intelligence about the state
of the economy and the local housing market;
— it
can act as a gateway to other housing services for people in need
who might not otherwise approach the authority for help;
— it
assists local authorities in their engagement with key local partners
such as landlords (both social and private) and other independent
advice providers operating in their area;
— it
can be used as an incentive (albeit in a limited way) to help
reinforce local policy priorities (for example, through direct
payment decisions which can encourage a landlord to let to vulnerable
people);
— it
is impossible to completely isolate the issue of housing affordability
from other areas of local authority responsibility (eg economic
development, anti-poverty strategies, Supporting People, homelessness)
therefore a degree of local control needs to be maintained; and
— overall,
housing benefit is a means by which that local authorities can
offer a more integrated approach to service delivery.
3.8 A key objective of the Government's welfare
reforms is to help people back into work and especially the long-term
unemployed. Successful employment initiatives invariably have
a local element, and almost without exception, successful schemes
to tackle long-term unemployment will have a strong local element.
This is because success is dependent on personalised advice and
support which in turn can only be developed from a position of
trust (ideally therefore the support worker should be independent
of any decision maker that has the power to sanction their benefit).
Retaining local knowledge of localised circumstances will therefore
be vital in ensuring the capacity of agencies to help people back
into work.
3.9 The White Paper headline maximum withdrawal
rate of 76% will not be achieved unless council tax is also included
as an element in universal credit. A separate CTB scheme (whether
with local or national rules) will preserve the multiple tapers
of the current system and result in a higher top rate of withdrawal
(a fraction over 80% if the current 20% rate is applied).
3.10 The outstanding feature of universal credit
is that by combining all the various elements of other means tested
benefits (out of work, working tax credits, child tax credits
and housing costs) income is assessed in one go and a single taper
can be applied as income increases. This eliminates the remaining
worst excesses of the poverty trap which arise from concurrent
tapers being applied separately to a number of benefits over the
same range of income.
3.11 This key feature is not dependent on there
being a centralised administration. Entitlement to any one of
the various elements (out-of-work, child care, housing) as well
as the income could be assessed locally or centrally and combined
later. Provided income is assessed according to common rules and
the excess income deduction is applied to the combined elements
then the integrity of the scheme is preserved.
3.12 CIH believes that the proposals for the
administration of universal credit will be too heavily dependent
on online claims and remote telephone contact. Whilst this will
work for many cases, there will be many others where the claim
cannot be resolved over the telephone and will require face to
face contact. We fear that DWP local office presence will be inadequate
to cope with the scale of such requests and in the early stages,
DWP staff will have insufficient experience to resolve some of
the trickier issues (around housing costs) that are currently
dealt with by the local authority.
3.13 Local authorities are more likely to fully
appreciate the concerns of the many landlords operating in their
area and so will be in better position to help manage these relationships.
The transfer of "help with housing costs" is a potential
threat to the viability of landlords business plans; a fact that
is causing a causing a good deal of unease in the landlord community.
Should responsibility for housing costs support be removed outside
of local authorities control, landlords will have little incentive
to engage with their local authority and all enquiries will be
directed to the DWP with the subsequent loss of strategic partnership
working on a local level.
4. GUARDING AGAINST FRAUD AND INCORRECT PAYMENT
4.1 The causes of fraud and incorrect payment
are many and complex but the key to controlling it is good administration.
There are a number of commonly acknowledged risk factors that
can allow fraud to leak into the system which include:
— complexity
within the benefits system;
— poor
intelligence—often as a result of the remoteness of the
administrator from the claimant; and
— a lack
of rigour in procedures for verifying and checking each aspect
of the claim.
4.2 The first of the above risk factors is often
cited as a reason why universal credit will be more secure against
fraud. It is certainly true that universal credit will radically
simplify the structure of the benefits system by reducing
the number of benefits available. It is also true that the current
system with its multiple and often overlapping benefits provides
opportunities for fraud especially since different benefits are
administered by a number of different agencies and the procedures
for sharing information are often not as good as they could or
should be.
4.3 However, although there is undoubtedly a
degree of fraud between benefits as a result of structural
complexity we suspect that the majority of fraud and incorrect
payment occurs from within benefits. Therefore, if anything,
it is complexity within rather than between benefits
that is a bigger cause of fraud. In the late 1990s, the National
Audit Office identified the complexity of housing benefit as a
major reason why it was particularly prone to fraud.[52]
4.4 The maximum amount of an award is also a
risk factor in vulnerability to fraud. The higher the potential
award the higher the risk. The high rent levels payable in the
private rented sector is one reason (together with a highly mobile
population) why the benefit was a target for fraudsters in London
and other more expensive property areas.
4.5 Viewed from this perspective universal credit
should be regarded as being especially high risk. Although it
will simplify the range of benefits available the benefit itself
will (necessarily) be very complex by combining out-of-work, childcare,
and housing costs into a single payment with potentially very
large awards.
4.6 It is also well known amongst administrators
that new benefits are also often a target for fraudsters because
the procedures for preventing and the opportunities for committing,
new frauds can never be completely predicted even by the most
vigilant authorities. This was the case with the introduction
of tax credits whereby false claims for childcare costs increased
partly encouraged by the remote administration and lapse procedures
(online claims with inadequate verification).
4.7 Since housing costs and childcare costs are
locally determined high quality intelligence for a secure universal
credit service will be dependent upon local knowledge and robust
procedures for identifying fraudulent claims. It is difficult
to implement robust procedures in a remotely administered system
because without local knowledge it will be difficult to identify
when an item of evidence is suspect.
4.8 This weakness would considerably reduce if
the housing and childcare elements were to continue to be assessed
and verified locally. Local authorities will have good knowledge
of both private rented sector housing providers and child care
providers operating in their areas, including awareness of both
providers and claimants that present a high risk. Where suspicion
is aroused it is also easier for locally administered service
to institute checks (such as verifying residency). The same arguments
would apply for locally authority involvement in assessing in-work
claims (they will have better knowledge of local employers).
4.9 Apart from rigorous data matching of every
claim it is difficult to envisage how residency will be verified
within a centrally administered universal credit. One approach
would be to relax the residency requirements as they currently
operate but this will result in either new opportunities for fraud
or benefit being (correctly) paid to customers who have no need
for it.
4.10 The volume of claims (including verifying
changes of circumstance) together with the quantity of evidence
that will be required to verify each element of every individual
claim will create huge pressures in a wholly centrally administered
system. If the new benefit is to be seen as a success then the
political pressure for rapid processing will be huge. This will
create a tension between customer service and security outcomes.
4.11 If local authorities have no stake in the
new system and no incentive to continue to invest in sound fraud
prevention measures due to the winding down of local authority
involvement, then there is a danger that the levels of fraud within
the legacy housing benefit caseload will increase. Without economies
of scale it may become uneconomic for authorities to invest in
fraud prevention for a residual council tax benefit service.
5. ADMINISTRATION AND PAYMENT ISSUES
5.1 Much of the discussion about universal credit
has focussed on payment issues especially around the issue of
payment of the any housing costs element to the customer rather
than to their landlord/housing provider. The concern for landlords
here is payment security: the fear that tenants will not
use their award (including any housing costs element) for the
purpose for which it was intended and that rent arrears will rise
to a level that is unsustainable.
5.2 Whilst this is undoubtedly a real issue that
needs to be resolved the amount of attention it has received has
distracted attention from an issue that is arguably an even more
important, cash flow. The security provided by direct payment
is of little use to either the landlord or the tenant if it takes
months to process the claim. This is precisely the position that
some landlords found themselves in during the crisis in housing
benefits administration at the turn of the century.
5.3 Cash flow problems arising from the changes
will particularly adversely affect local authority landlords.
Under the current system, local authority tenants are paid by
rebate, which means benefit is always direct to the landlord and
there is no delay due to the benefit payment cycle (tenants paid
by rent allowance are currently paid two weekly in arrears, or
if benefit is paid directly to their landlord, four weekly in
arrears).
5.4 CIH estimates that the change to payment
four weekly in arrears for local authority landlords is equivalent
to around a four or five per cent loss in their annual rent roll—a
consideration to landlords who are currently formulating their
business plans for self financing.
5.5 It is widely accepted that housing benefit
is currently the most complex benefit to deliver because of the
numerous aspects of the claim that need to be verified. Despite
any simplification to the system that universal credit may achieve,
its multiple elements mean it will be considerably more complex
to deliver.
5.6 There is a real danger that the processing
of any one individual claim will be slowed down to the slowest
part of the process and that a strictly linear assessment (ie
assessing each of the elements in turn) will result in the rapid
escalation of payment delays if there is no facility for the parallel
processing of each of the various elements.
5.7 Retaining a local element in administration
of housing costs would enable parallel processing of initial and
subsequent reassessment claims to take place. Provided the new
regime allowed for the housing costs element to be paid independently
(and the Government has already stated that payment of housing
costs will not be subject to the labour market tests) if other
aspects of the claim were problematic the tenant would at least
have the means to pay their rent.
5.8 CIH would urge the government to review the
proposed assessment and payment system so that elements of a claim
could be paid in chunks, so claimants would not have to wait for
payment pending completion of all elements of the assessment process.
5.9 The central aim of universal credit is to
help people back into work; but it should be noted, that a settled
home is a prerequisite for obtaining and maintaining stable employment.
If payment delays are endemic, then there is a real danger that
those who are willing to work will be unable to and will face
unnecessary barriers to starting or maintaining work. They may
also face a crisis in housing or accommodation if their claims
are not settled quickly.
6. ENSURING SUCCESS: A PARTIALLY LOCALISED UNIVERSAL
CREDIT
6.1 CIH advocates the administration of universal
credit is localised in order to maintain all the existing advantages
of the current scheme with none of its inherent disadvantages.
It would also solve the problem of how council tax benefit fits
into the new scheme, allowing for local administration whilst
ensuring that the maximum possible work incentive is achieved.
6.2 This would apply the partnership model of
service delivery that has been so successful in raising standards
of administration over the past ten years. It would also preserve
the existing administrative structures and in so doing would greatly
reduce the very risk of failure inherent in designing a whole
new administrative system from scratch.
6.3 Concurrent processing of the various elements
would also be possible and thus allow for faster claims processing
times—which will be essential if universal credit is to
be viewed as a success.
6.4 A partial localised scheme will help break
down the award into more easily handled bite sized chunks and
will help avoid the danger that the processing is slowed to whatever
happens to be the most problematic element in each particular
case. This is possible because universal credit will comprise
of two different basic types of element:
— flat
rate elements (out of work, child and disability); and
— variable
elements (housing costs, childcare and council tax).
6.5 With the exception of the childcare element
that, which assessed both locally and nationally (by HMRC), all
the variable elements are currently assessed locally because they
relate to costs that vary locally. In the interests of ensuring
a successful transition the less risky option would be for this
to continue with a minor change with respect to childcare.
6.6 The childcare element should be assessed
wholly on local basis because childcare is a locally provided
service. Local knowledge about providers will help prevent fraud
leaking into the system. This arrangement also avoids the DWP
taking on an aspect of assessment in which they have no current
experience and would also mean that all the variable elements
would then be processed together.
6.7 Local authorities will be in better position
to make a judgement as to the need for advice and support for
claimants (eg the number and location of local offices) including
how best to make savings (for example, extension of the current
trend for shared services).
6.8 None of the above would prevent the initial
claim from being made online. Indeed online application would
provide single gateway and avoid duplication of effort. However,
where a claim is less than straightforward the claimant would
at least have the option of being able resolve it by visiting
their local service if they so wished.
6.9 It would be possible in this system, for
responsibility for assessing income to be wholly with the DWP
or the local authority or by either. One option would be that
income assessment would be carried out by whoever processes their
part of the claim first: the result would then be binding on the
other.
6.10 Another option would be for the local authority
to be responsible for assessing income for in-work claims and
the DWP for out-of-work claims (largely retaining the current
split). This option would also help guard against fraud because
local authorities have better knowledge of, and access to local
employers.
6.11 Whoever is responsible the process must
be straight forward. Once income has been assessed the decision
maker (local authority or DWP as the case may be) would deduct
the tapered excess from their elements. If the tapered excess
was greater any remainder would be passed over to their partner
authority so that it could be applied to the remaining elements.
If there was no excess income the appropriate partner would notify
the other of a zero income together with the total of their elements
(so that the overall cap could be applied if appropriate).
6.12 Local authorities would become responsible
for assessing help with housing costs for home owners for the
first time. On current caseloads this would equate to around a
further 220,000 cases, or 4.5% increase in their current housing
benefit caseload a modest increase which is well within local
authorities' capacity to deliver.
6.13 Conversely a centrally administered universal
credit scheme would involve the DWP taking on the assessment of
housing costs for an extra 4.87 million customers (or 2,200% increase).
The DWP caseload (ie disregarding passport cases) would increase
by around 950,000 for universal credit and a further 350,000 for
pension credit (circa 20% increase for both).
6.14 Responsibility for help with owners' housing
costs would complement the local authority strategic housing role
and would integrate well with existing services (eg mortgage rescue
and the repossessions prevention fund) to help low income owner
occupiers.
7. CONCLUSION
7.1 We firmly believe that lessons from history
and the experience of local administration of housing benefit
show that both customers and the tax payer would benefit from
the housing part of universal credit being delivered and administered
locally and that this can be done whilst retaining universal credit
as an overall national system.
August 2011
8. REFERENCES
DWP, 2002, Housing Benefit Operational Database
http://statistics.dwp.gov.uk/asd/hobod/index.php
DWP, 2011, Right Time Indicator http://statistics.dwp.gov.uk/asd/asd1/rti/rti_jul2011.xls
HM Treasury, (1998 The Modernisation of Britain's
Tax and Benefit System, Number 3, The Working Families Tax
Credit and work incentives
National Audit Office, 1997 Measures to Combat
Housing Benefit Fraud, HC 164
9. APPENDIX: LESSONS FROM HISTORY ON ADMINISTRATION
OF BENEFITS
The various different systems and administration
arrangements used over the last 30 years to help households meet
their housing costs have taught us a great deal about administration
of benefits. We have learned what enables good and effective administration—delivering
best results for claimants and the tax payer. We have also learned
which approaches are ineffective and inefficient—leading
to waste and tardiness.
The Beveridge welfare state and the problem of
rent
A1. Beveridge was unable to find a satisfactory
solution to the "problem of rent" within his scheme
of flat rate benefits. Rent was a problem in a flat rate scheme
because it represents the largest item in the household budget
and also, unlike other essential items, it varies widely from
place to place.
A2. Unable to find a solution housing costs were
excluded from his scheme—in effect the problem was deferred
in order that wider reform could take place. The creation of a
national housing benefit scheme some years later from local rent
rebates and allowances was the eventual solution.
The evolution of the housing benefit scheme
A3. Prior to 1982-83 there were several different
schemes for helping low income tenants with housing costs which
varied according to tenure and income:
— Local
authority tenants were entitled to a rent rebate based on a proportion
of their rent administered by their local authority according
to national rules.
— All
other tenants (private and housing association) all local authorities
were required to run a rent allowance scheme but could set local
rules.
— Rrunning
in parallel was a rent rebate scheme administered by the DHSS.
— Tthe
DHSS also provided a separate scheme for help with rent by including
the whole of the rent in the calculation of entitlement to supplementary
benefit, entitlement to which disqualified the claimant to a local
authority rent rebate/allowance.
A4. These disparate schemes were first brought
together into unified housing benefit scheme in 1982-83 administered
by local authorities. However, these two incompatible methods
of assessment were rather clumsily stuck together. The "sticking
plaster" was a complex special procedure designed to resolve
cases whereby the claimant on a local authority rent rebate/allowance
would otherwise be worse off after paying their rent than a supplementary
benefit claimant (the so called "better off problem").
A5. At the time when the new scheme was introduced
local authority housing was the dominant rented tenure accounting
for 68% of all rented housing. Housing associations accounted
for less than 6% of the rented stock (the remainder being privately
rented). Given that local authorities were responsible for paying
housing benefit it made sense for local authority tenants to be
paid by rent rebate which has the same effect as direct payment
to the landlord.
The 1988 scheme and its subsequent development
A6. A more radical restructuring took place in
1988—partly to resolve the better off problem—by providing
for a single assessment of income and awards based on 100% of
the eligible rent. The common method of assessing income and needs
was mirrored in other means tested benefits (income support and
family credit).
A7. Ever since its introduction the scheme has
been subject to an almost constant stream of amendments some of
them fundamental but many more of them minor. The more fundamental
changes were often as a result of consequential changes made to
other means tested benefits.
A8. The endless change and the increasing complexity
of the scheme was a major factor in the crisis of administration
at the turn of the century which led to a major select committee
inquiry and report. However, despite the constant change the two
key features of the 1988 reforms (unified income assessment and
entitlement based on 100% of the eligible rent) remained largely
intact.
A9. The most significant changes to the 1988
scheme (that did not arise from changes to other benefits) where:
— In
1990 rate rebates were replaced with community charge benefit
and subsequently superseded by council tax benefit in 1993 following
the introduction of the council tax.
— in
1996 restrictions were introduced for private sector tenants so
that the maximum eligible rent was based on the median rent (the
"local reference rent") for similar dwellings across
a fairly wide local area. For young single people the rent was
based on a room in a shared house (the "single room rent").
— In
2003 benefit periods (which restricted the life of a claim to
a maximum of 60 weeks) were abolished as part of the pension credit
reforms (paragraphs 2.xx-xy).
— In
2008 (following a pilot phase which began in 2003) the local housing
allowance (LHA) largely replaced the local reference rent rules
for private sector tenants. The novel feature of the LHA was that
it was a flat rate based on a broad average rent for appropriately
sized property rather than the lowest of either contractual rent
or a number of individual rent officer valuations (which included
the local reference rent).
— In
2010 the Coalition announced numerous changes to the scheme following
the Emergency Budget and October Spending Review designed to reign
in housing benefit expenditure. These reforms will take effect
between April 2011 and April 2013.
The social security committee inquiry into housing
benefit
A10. The Social Security Committee inquiry into
housing benefit in 2000 proved to be a turning point in the administration
of housing benefit. The almost constant stream of complex amendments
and other burdensome administrative requirements (often designed
as response for the need to reduce to fraud and incorrect payment)
had in many cases brought local authority administration close
to breaking point.
A11. In 2001 the average benefit processing time
for new claims was 58 days but in many local authorities considerably
longer. The payment delays caused considerable distress for tenants
and major cash flow problems for landlords.
A12. Following the Committee's influential report
a new working relationship based on partnership developed between
the DWP and local authorities whereas the previous culture was
predominantly one of blame and centrally imposed sanctions for
authorities that failed to improve (eg the threat of compulsory
contracting out).
A13. The new working relationship encouraged
investment in staff development and professionalisation (for example,
DWP funded a study into the characteristics of effective managers).
DWP also embarked on a programme gradually simplifying the housing
benefit scheme in close consultation with the local authority
representative and professional bodies.
A14. The LHA reforms were partly developed as
a direct response for the need to simplify the system and streamline
the administrative procedures. The LHA ended the need for each
individual claim to be referred to the rent officer and the local
published rates allowed immediate assessment and provided greater
transparency.
A.15. The new collaborative working arrangements
have been so successful in harnessing the skills of local benefits
managers that by April 2008 average processing times for benefit
claims had more than halved to 26 days despite a 16% increase
in the caseload. However, the caseload rise concealed a much more
dramatic 53% increase in the number of rent allowance claims and
a 71% increase in the number of private rented sector claims (both
of which are progressively more complex to process).
A16. By December 2010 (quarter 3, 2010) average
housing benefit processing times had fallen further and were down
to 22 days . No authority had processing times longer than 50
days—eight to nine days less than the average processing
times during the low point in the administration in 2001-02 (see
spread sheet supplied).
A17. The performance improvement achieved by
local authorities has been so outstanding that it is now widely
accepted that housing benefit, despite being the most complex
of all benefits to administer is now consistently the best performing
service across the whole benefits system.
The introduction of tax credits and pension credits
A18. Family credit evolved into the more generous
working families' tax credit in 1998 and was itself replaced by
the tax credits scheme in 2003. Although this did not affect housing
benefit itself the new schemes were sufficiently generous to "float
off" large numbers of working households from housing benefit
altogether.
A19. An intended effect of this floating off
was that households avoided the deepest part of the poverty trap
(ie the very high overall marginal deduction rates). The reforms
also eliminated the numerous discontinuities that occurred across
the income scale in which marginal deduction rates exceeded 100%.
However, a relatively small number of working households—those
with higher rents—entitled to both tax credits and housing
benefit still faced overall marginal deduction rates in excess
of 90% as a result of concurrent withdrawals being applied. Treasury
models estimated that the number of households with marginal withdrawal
rates in excess of 90% had fallen from 130,000 to around 20,000.
A20. Another feature of tax credits is that they
departed from the unified income assessment and were based on
historic gross income rather than net current income. This added
some complexity to the structure of benefits with different methods
of assessing income being applied to different benefits.
A21. It is worth mentioning here that the original
tax credits processes were based on online claims which were characterised
by failure eventually resulting in the withdrawal of online claims
partly because of their vulnerability to fraud.
A22. Universal credit has many more elements
and will be considerably more complex not least because income
will be assessed in real time (ie as and when a change occurs)
rather than tax credits which are a passive system (based on historic
annual earnings).
APPENDIX
Source: DWP (2011) Right
Time Indicator; and DWP (2002) Housing Benefit Operational Database
| | Q3 2010-11
| 31 March 2002
|
| | New
Claims
| Change of
circumstances | New
Claims
| Change of
circumstances |
| | |
| | |
| GREAT BRITAIN | 22
| 11 | 59 | 18
|
| |
| |
| |
| ENGLAND | 22 |
10 | 61 | 18
|
| |
| |
| |
| NORTH EAST |
| | 49 |
1 |
| | |
| | |
| County Durham UA | 34
| 17 | 76 |
|
| Darlington UA | 9 | 5
| 49 | 7 |
| Hartlepool UA | 21 | 11
| 49 | 2 |
| Middlesbrough UA | 20 | 8
| 32 | 9 |
| Northumberland UA | 26
| 9 | 32 |
|
| Redcar and Cleveland UA | 25
| 12 | 7 | 4 |
| Stockton-on-Tees UA | .. |
.. | 71 | 11 |
| | |
| | |
| Tyne and Wear (Met County) |
| |
| |
| Gateshead | 27 | 11
| 59 | 15 |
| Newcastle upon Tyne | 22 |
8 | 59 | 33 |
| North Tyneside | 57 | 25
| 34 | 15 |
| South Tyneside | 19 | 14
| .. | .. |
| Sunderland | 18 | 5
| 40 | .. |
| | |
| | |
| NORTH WEST |
| | 61 |
19 |
| | |
| | |
| Blackburn with Darwen UA | 19
| 9 | 94 | 24 |
| Blackpool UA | 34 | 29
| 41 | 31 |
| Cheshire East UA | ..
| 15 | 44 |
|
| Cheshire West and Chester UA | 23
| 12 | 36 |
|
| Halton UA | 16 | 4
| 53 | 27 |
| Warrington UA | 17 | 10
| .. | 25 |
| | |
| | |
| Cumbria | |
| |
|
| Allerdale | 28 | 11
| 57 | 12 |
| Barrow-in-Furness | 19 | 8
| 56 | 14 |
| Carlisle | 24 | 10
| 48 | 17 |
| Copeland | 26 | 14
| 56 | 47 |
| Eden | 20 | 14
| 53 | 11 |
| South Lakeland | 29 | ..
| 31 | 13 |
| | |
| | |
| Greater Manchester (Met County)
| |
| |
|
| Bolton | 20 | 9
| 49 | 26 |
| Bury | 26 | 11
| 56 | 4 |
| Manchester | 26 | 15
| .. | .. |
| Oldham | 16 | 7
| 33 | 13 |
| Rochdale | 29 | 19
| .. | .. |
| Salford | 24 | 10
| .. | .. |
| Stockport | 20 | 13
| .. | .. |
| Tameside | 24 | 9
| 22 | 16 |
| Trafford | 14 | 8
| .. | .. |
| Wigan | 29 | 16
| .. | .. |
| | |
| | |
| Lancashire |
| |
| |
| Burnley | 18 | 5
| 42 | 5 |
| Chorley | 17 | 7
| 36 | 1 |
| Fylde | 42 | 24
| .. | .. |
| Hyndburn | 19 | 10
| 43 | 15 |
| Lancaster | 18 | 9
| 72 | 19 |
| Pendle | 19 | 9
| 75 | 11 |
| Preston | 22 | 12
| 62 | 23 |
| Ribble Valley | 17 | 5
| 26 | 7 |
| Rossendale | 19 | 9
| 67 | 21 |
| South Ribble | 23 | 12
| 40 | 24 |
| West Lancashire | 15 | 9
| 45 | 31 |
| Wyre | 18 | 4
| 109 | 9 |
| | |
| | |
| Merseyside (Met County) |
| |
| |
| Knowsley | 23 | 9
| 127 | .. |
| Liverpool | 24 | 13
| 102 | 47 |
| Sefton | .. | ..
| 54 | 19 |
| St. Helens | 24 | 10
| 56 | 22 |
| Wirral | 19 | 9
| 83 | 32 |
| | |
| | |
| YORKSHIRE AND THE HUMBER |
| | 54 |
17 |
| | |
| | |
| East Riding of Yorkshire UA | 17
| 5 | 71 | 14 |
| Kingston upon Hull, City of UA | 19
| 17 | 68 | 19
|
| North East Lincolnshire UA | 21
| 12 | 52 | ..
|
| North Lincolnshire UA | 19 |
11 | .. | .. |
| York UA | 18 | 8
| 45 | 13 |
| | |
| | |
| North Yorkshire |
| |
| |
| Craven | 22 | 8
| 37 | .. |
| Hambleton | 18 | 8
| 63 | 19 |
| Harrogate | 24 | 8
| 53 | 7 |
| Richmondshire | .. | ..
| 15 | 8 |
| Ryedale | 25 | 9
| 45 | 4 |
| Scarborough | 18 | 12
| 41 | 9 |
| Selby | 16 | 5
| 30 | .. |
| | |
| | |
| South Yorkshire (Met County) |
| |
| |
| Barnsley | 19 | 10
| 53 | 7 |
| Doncaster | 18 | 10
| 29 | 8 |
| Rotherham | 24 | ..
| 31 | 8 |
| Sheffield | 25 | 16
| 99 | 26 |
| | |
| | |
| West Yorkshire (Met County) |
| |
| |
| Bradford | 17 | 13
| 35 | 61 |
| Calderdale | 20 | 12
| 69 | 22 |
| Kirklees | 18 | 13
| 68 | .. |
| Leeds | 19 | 12
| 38 | 13 |
| Wakefield | 22 | 10
| 51 | 37 |
| | |
| | |
| EAST MIDLANDS |
| | 53 |
16 |
| | |
| | |
| Derby UA | 23 | 17
| 59 | 22 |
| Leicester UA | 20 | 12
| 125 | .. |
| Nottingham UA | 50 | 12
| .. | .. |
| Rutland UA | 15 | 7
| 30 | 3 |
| | |
| | |
| Derbyshire |
| |
| |
| Amber Valley | 17 | 7
| 36 | 8 |
| Bolsover | 21 | 8
| 26 | 13 |
| Chesterfield | 19 | 10
| 34 | 2 |
| Derbyshire Dales | 24 | 7
| 18 | 2 |
| Erewash | 19 | 7
| 84 | 33 |
| High Peak | 13 | 5
| 19 | 3 |
| North East Derbyshire | 21 |
11 | 47 | 9 |
| South Derbyshire | 20 | 11
| 10 | 3 |
| | |
| | |
| Leicestershire |
| |
| |
| Blaby | 16 | 6
| 87 | .. |
| Charnwood | 21 | 17
| 48 | 16 |
| Harborough | 25 | 14
| 32 | 3 |
| Hinckley and Bosworth | 13 |
8 | 82 | 2 |
| Melton | 13 | 13
| 47 | 11 |
| North West Leicestershire | 17
| 8 | 20 | 6 |
| Oadby and Wigston | 10 | 7
| 21 | .. |
| | |
| | |
| Lincolnshire |
| |
| |
| Boston | 14 | 8
| 47 | 3 |
| East Lindsey | 15 | 6
| 41 | 7 |
| Lincoln | 14 | 12
| 42 | 15 |
| North Kesteven | 18 | 9
| 42 | 1 |
| South Holland | 15 | 7
| 43 | 1 |
| South Kesteven | 17 | 6
| 51 | 11 |
| West Lindsey | 14 | 8
| 34 | 31 |
| | |
| | |
| Northamptonshire |
| |
| |
| Corby | 15 | 6
| 75 | 16 |
| Daventry | 18 | 3
| 28 | .. |
| East Northamptonshire | 18 |
7 | 29 | 4 |
| Kettering | 20 | 13
| 67 | 36 |
| Northampton | 17 | 12
| 98 | 83 |
| South Northamptonshire | 16 |
8 | 68 | 7 |
| Wellingborough | 17 | 6
| 37 | 14 |
| | |
| | |
| Nottinghamshire |
| |
| |
| Ashfield | 22 | 9
| 72 | 17 |
| Bassetlaw | 24 | 5
| 44 | 8 |
| Broxtowe | 25 | 15
| 53 | 25 |
| Gedling | 21 | 7
| 34 | .. |
| Mansfield | 29 | 17
| 38 | 17 |
| Newark and Sherwood | 33 |
8 | 32 | 8 |
| Rushcliffe | 19 | 10
| 35 | 12 |
| | |
| | |
| WEST MIDLANDS |
| | 53 |
25 |
| | |
| | |
| Herefordshire, County of UA | 18
| 8 | 53 | .. |
| Shropshire UA | 21 |
8 | 29 |
|
| Stoke-on-Trent UA | 15 | 8
| 70 | 57 |
| Telford and Wrekin UA | 15 |
7 | 64 | 12 |
| | |
| | |
| Staffordshire |
| |
| |
| Cannock Chase | 26 | 11
| 57 | 2 |
| East Staffordshire | 27 |
14 | 65 | 13 |
| Lichfield | 26 | 16
| 58 | 1 |
| Newcastle-under-Lyme | .. |
13 | 35 | 6 |
| South Staffordshire | 22 |
12 | 86 | 36 |
| Stafford | 26 | 15
| 29 | 6 |
| Staffordshire Moorlands | 32
| 18 | 70 | 21
|
| Tamworth | 22 | 11
| 40 | 17 |
| | |
| | |
| Warwickshire |
| | 63 |
2 |
| North Warwickshire | 19 |
7 | 24 | 12 |
| Nuneaton and Bedworth | 12 |
13 | 84 | 28 |
| Rugby | 18 | 10
| 27 | 4 |
| Stratford-on-Avon | 19 | 9
| 62 | 51 |
| Warwick | 18 | 11
| 50 | 15 |
| | |
| | |
| West Midlands (Met County) |
| |
| |
| Birmingham | 18 | 4
| .. | .. |
| Coventry | 21 | 17
| 67 | 74 |
| Dudley | 16 | 10
| 43 | 21 |
| Sandwell | 21 | 7
| 54 | 26 |
| Solihull | 22 | 8
| 29 | 4 |
| Walsall | 23 | 15
| | |
| Wolverhampton | 21 | 12
| 40 | 15 |
| | |
| | |
| Worcestershire |
| |
| |
| Bromsgrove | 20 | 10
| 83 | 6 |
| Malvern Hills | 23 | 11
| 49 | 8 |
| Redditch | 20 | 11
| 45 | 6 |
| Worcester | 21 | 10
| 68 | 11 |
| Wychavon | 24 | 10
| 38 | 7 |
| Wyre Forest | 24 | 8
| 17 | 6 |
| | |
| | |
| EAST | |
| 53 | 15
|
| | |
| | |
| Bedford UA | 20 | 9
| 102 | 8 |
| Central Bedfordshire UA | 39
| 34 | 42 |
|
| Luton UA | 14 | 8
| 24 | 9 |
| Peterborough UA | 42 | 20
| 44 | 1 |
| Southend-on-Sea UA | 11 |
9 | 53 | 17 |
| Thurrock UA | 17 | 6
| 50 | 8 |
| | |
| | |
| Cambridgeshire |
| |
| |
| Cambridge | 12 | 5
| 29 | 1 |
| East Cambridgeshire | 14 |
6 | 41 | 6 |
| Fenland | 22 | 10
| 31 | 9 |
| Huntingdonshire | 22 | 7
| 50 | 12 |
| South Cambridgeshire | 23 |
10 | 28 | 11 |
| | |
| | |
| Essex |
| |
| |
| Basildon | 14 | 7
| 37 | 8 |
| Braintree | 18 | 5
| 55 | 4 |
| Brentwood | 6 | 6
| 43 | 17 |
| Castle Point | 19 | 7
| 85 | 26 |
| Chelmsford | 19 | 12
| 36 | 25 |
| Colchester | 28 | 17
| 47 | 24 |
| Epping Forest | 20 | 8
| .. | .. |
| Harlow | 17 | 10
| 32 | .. |
| Maldon | 13 | 7
| 74 | .. |
| Rochford | 32 | 20
| 38 | 2 |
| Tendring | 6 | 3
| 58 | 14 |
| Uttlesford | 19 | 7
| 43 | 6 |
| | |
| | |
| Hertfordshire |
| |
| |
| Broxbourne | 21 | 10
| 80 | .. |
| Dacorum | 21 | 14
| .. | .. |
| East Hertfordshire | 27 |
6 | 70 | 9 |
| Hertsmere | 16 | 10
| .. | .. |
| North Hertfordshire | 15 |
6 | 25 | 9 |
| St Albans | 19 | 7
| 22 | 16 |
| Stevenage | 24 | 16
| 42 | 11 |
| Three Rivers | 35 | 31
| .. | .. |
| Watford | 29 | 45
| 45 | 16 |
| Welwyn Hatfield | 14 | 6
| 32 | 7 |
| | |
| | |
| Suffolk |
| |
| |
| Breckland | 14 | 6
| 124 | 56 |
| Broadland | 19 | 10
| 91 | 27 |
| Great Yarmouth | 14 | ..
| .. | .. |
| King's Lynn and West Norfolk | 15
| 12 | 56 | ..
|
| North Norfolk | 31 | 11
| 70 | 23 |
| Norwich | 21 | ..
| 85 | 29 |
| South Norfolk | 5 | 3
| 91 | .. |
| | |
| | |
| | |
| | |
| Babergh | 16 | 6
| 68 | 26 |
| Forest Heath | 14 | 6
| 62 | 16 |
| Ipswich | 38 | 21
| 37 | 16 |
| Mid Suffolk | 19 | 7
| 89 | .. |
| St Edmundsbury | 18 | 8
| 42 | 34 |
| Suffolk Coastal | 38 | 20
| 37 | 14 |
| Waveney | 18 | 7
| 63 | 11 |
| | |
| | |
| LONDON |
| | 88 |
27 |
| | |
| | |
| Inner London |
| | 111 |
25 |
| | |
| | |
| Camden | 25 | 10
| .. | .. |
| City of London | 26 | 13
| 25 | 5 |
| Hackney | 29 | 18
| 230 | 4 |
| Hammersmith and Fulham | 42 |
37 | 58 | 3 |
| Haringey | 33 | ..
| 102 | 23 |
| Islington | 22 | ..
| 120 | 31 |
| Kensington and Chelsea | 12 |
9 | 52 | .. |
| Lambeth | 24 | 13
| .. | .. |
| Lewisham | 8 | 6
| 43 | 13 |
| Newham | 33 | 19
| .. | .. |
| Southwark | 18 | 15
| 87 | .. |
| Tower Hamlets | 21 | 6
| 36 | 7 |
| Wandsworth | 19 | 10
| 124 | 54 |
| Westminster | 25 | 22
| 155 | .. |
| | |
| | |
| Outer London |
| |
| |
| | |
| | |
| Barking and Dagenham | 22 |
20 | 50 | 42 |
| Barnet | 17 | 5
| 53 | 8 |
| Bexley | 23 | 12
| 77 | 37 |
| Brent | 14 | 9
| 184 | 34 |
| Bromley | 22 | 11
| 83 | .. |
| Croydon | 18 | 6
| 58 | 14 |
| Ealing | 19 | 10
| 103 | 14 |
| Enfield | 39 | 21
| .. | .. |
| Greenwich | 25 | 12
| 62 | 17 |
| Harrow | 14 | 5
| 85 | .. |
| Havering | 16 | 12
| .. | .. |
| Hillingdon | 21 | 13
| 54 | 14 |
| Hounslow | 20 | 9
| .. | .. |
| Kingston upon Thames | 21 |
6 | 62 | 13 |
| Merton | 30 | 10
| 57 | 17 |
| Redbridge | 26 | 10
| 49 | 25 |
| Richmond upon Thames | 17 |
9 | 31 | 1 |
| Sutton | 13 | 8
| 55 | 22 |
| Waltham Forest | 31 | 19
| 31 | 3 |
| | |
| | |
| SOUTH EAST |
| | 51 |
15 |
| | |
| | |
| Bracknell Forest UA | .. |
.. | 56 | 18 |
| Brighton and Hove UA | 23 |
8 | .. | .. |
| Isle of Wight UA | 18 | 11
| 93 | 11 |
| Medway UA | 26 | 12
| 54 | 23 |
| Milton Keynes UA | 13 | 8
| 90 | 19 |
| Portsmouth UA | 24 | 14
| 54 | .. |
| Reading UA | 22 | 10
| 44 | 19 |
| Slough UA | 18 | 12
| 45 | 23 |
| Southampton UA | 17 | 10
| 50 | 31 |
| West Berkshire UA | 16 | 9
| .. | .. |
| Windsor and Maidenhead UA | 18
| 12 | 26 | 3 |
| Wokingham UA | 33 | 14
| 72 | 32 |
| | |
| | |
| Buckinghamshire |
| |
| |
| Aylesbury Vale | 10 | 4
| 27 | 11 |
| Chiltern | 13 | 4
| 24 | 5 |
| South Bucks | 18 | 8
| 105 | 3 |
| Wycombe | 16 | 8
| 44 | 15 |
| | |
| | |
| East Sussex |
| |
| |
| Eastbourne | 19 | 9
| 55 | 19 |
| Hastings | 15 | 9
| 43 | 14 |
| Lewes | 19 | 6
| 40 | 18 |
| Rother | 20 | 13
| 8 | 7 |
| Wealden | 30 | 31
| 60 | 35 |
| | |
| | |
| Hampshire |
| |
| |
| Basingstoke and Deane | 29 |
13 | 51 | 11 |
| East Hampshire | 16 | 7
| 39 | 8 |
| Eastleigh | 17 | 4
| 58 | 22 |
| Fareham | 17 | 6
| 53 | 17 |
| Gosport | 12 | 5
| 58 | 21 |
| Hart | 15 | 6
| 70 | 17 |
| Havant | 13 | 6
| 40 | .. |
| New Forest | 20 | 9
| .. | .. |
| Rushmoor | 8 | 2
| 64 | 18 |
| Test Valley | 16 | 8
| 65 | 2 |
| Winchester | 14 | 7
| 49 | 23 |
| | |
| | |
| Kent |
| |
| |
| Ashford | 27 | 6
| 39 | 15 |
| Canterbury | 16 | 8
| 38 | 14 |
| Dartford | 23 | 13
| 29 | 4 |
| Dover | 24 | 11
| 61 | 5 |
| Gravesham | 16 | 9
| 45 | .. |
| Maidstone | 14 | 9
| 26 | 1 |
| Sevenoaks | 30 | 12
| 78 | 19 |
| Shepway | 14 | 7
| 108 | .. |
| Swale | 12 | 6
| 54 | 25 |
| Thanet | 20 | 8
| 48 | 16 |
| Tonbridge and Malling | 27 |
8 | 27 | 3 |
| Tunbridge Wells | 13 | 9
| .. | .. |
| | |
| | |
| Oxfordshire |
| |
| |
| Cherwell | 19 | 12
| 55 | 12 |
| Oxford | 14 | 10
| 50 | 27 |
| South Oxfordshire | 29 | 22
| 58 | 5 |
| Vale of White Horse | 33 |
26 | 47 | 4 |
| West Oxfordshire | 18 | 9
| 43 | 1 |
| | |
| | |
| Surrey |
| |
| |
| Elmbridge | 11 | 6
| 17 | 2 |
| Epsom and Ewell | 24 | 12
| 21 | 5 |
| Guildford | 19 | 6
| 18 | .. |
| Mole Valley | 20 | 9
| 28 | 5 |
| Reigate and Banstead | 20 |
6 | 35 | 4 |
| Runnymede | 16 | 7
| 44 | 16 |
| Spelthorne | 24 | 10
| 33 | 6 |
| Surrey Heath | 15 | 8
| 52 | 4 |
| Tandridge | 17 | 9
| 34 | .. |
| Waverley | 12 | ..
| 27 | 9 |
| Woking | 20 | 7
| 40 | 13 |
| | |
| | |
| West Sussex |
| |
| |
| Adur | 16 | 8
| .. | .. |
| Arun | 15 | 8
| 71 | 8 |
| Chichester | 14 | 7
| 53 | 17 |
| Crawley | 11 | 5
| 69 | 26 |
| Horsham | 15 | 9
| 31 | .. |
| Mid Sussex | 16 | 7
| 43 | 1 |
| Worthing | 18 | 10
| 26 | 9 |
| | |
| | |
| SOUTH WEST |
| | 46 |
17 |
| | |
| | |
| Bath and North East Somerset UA | 19
| 9 | 38 | 1 |
| Bournemouth UA | 19 | 8
| 39 | 7 |
| Bristol, City of UA | 44 |
16 | 73 | 18 |
| Cornwall UA | 33 |
18 | 35 |
|
| North Somerset UA | 19 | 8
| 44 | 15 |
| Plymouth UA | 30 | 18
| .. | .. |
| Poole UA | 17 | 8
| 40 | 14 |
| South Gloucestershire UA | 24
| 13 | 50 | 47
|
| Swindon UA | 19 | 10
| 83 | .. |
| Torbay UA | 26 | 8
| 70 | 23 |
| Wiltshire UA | 21 |
9 | 41 |
|
| | |
| | |
| Devon |
| |
| |
| East Devon | 9 | 4
| 47 | 1 |
| Exeter | 11 | 6
| 69 | 14 |
| Mid Devon | 17 | 7
| 37 | 3 |
| North Devon | 17 | 6
| 31 | 5 |
| South Hams | 14 | 8
| 32 | 6 |
| Teignbridge | 22 | 9
| 34 | 5 |
| Torridge | 17 | 9
| .. | 11 |
| West Devon | 18 | 8
| 42 | 9 |
| | |
| | |
| Dorset |
| |
| |
| Christchurch | 28 | 13
| 27 | 5 |
| East Dorset | 30 | 12
| .. | .. |
| North Dorset | 32 | 17
| 17 | 3 |
| Purbeck | 18 | 7
| 26 | .. |
| West Dorset | 18 | 8
| 33 | 9 |
| Weymouth and Portland | 19 |
8 | 46 | 12 |
| | |
| | |
| Gloucestershire |
| |
| |
| Cheltenham | 17 | 3
| 26 | 6 |
| Cotswold | 15 | 7
| 35 | 11 |
| Forest of Dean | 14 | 8
| 34 | 13 |
| Gloucester | 21 | 9
| 47 | .. |
| Stroud | 19 | 13
| 36 | .. |
| Tewkesbury | 32 | 15
| 55 | 8 |
| | |
| | |
| Somerset |
| |
| |
| Mendip | 24 | 14
| 29 | 11 |
| Sedgemoor | 7 | 7
| 19 | 9 |
| South Somerset | 24 | 11
| 53 | 2 |
| Taunton Deane | 18 | ..
| 30 | .. |
| West Somerset | 15 | ..
| .. | .. |
| | |
| | |
| WALES | 22 |
9 | 56 | 13
|
| | |
| | |
| Isle of Anglesey / Ynys M¼n | 20
| 6 | 76 | .. |
| Gwynedd / Gwynedd | 40 | 11
| 51 | 13 |
| Conwy / Conwy | 21 | 8
| 65 | 11 |
| Denbighshire / Sir Ddinbych | 14
| 6 | 78 | 21 |
| Flintshire / Sir y Fflint | 20
| 11 | 47 | 7 |
| Wrexham / Wrecsam | 26 | 10
| 25 | 9 |
| Powys / Powys | 23 | 13
| .. | .. |
| Ceredigion / Ceredigion | 23
| 10 | 58 | 7 |
| Pembrokeshire / Sir Benfro | 17
| 5 | 73 | .. |
| Carmarthenshire / Sir Gaerfyrddin | 26
| 12 | 54 | 13
|
| Swansea / Abertawe | 15 |
5 | 81 | .. |
| Neath Port Talbot / Castell-nedd Port Talbot
| 15 | 6 | 43 |
8 |
| Bridgend / Pen-y-bont ar Ogwr | 19
| 8 | 75 | 27 |
| The Vale of Glamorgan / Bro Morgannwg | 17
| 8 | 55 | 12 |
| Cardiff / Caerdydd | 27 |
13 | 68 | 2 |
| Rhondda, Cynon, Taff / Rhondda, Cynon, Taf |
19 | 9 | 46 | 8
|
| Merthyr Tydfil / Merthyr Tudful | 21
| .. | .. | ..
|
| Caerphilly / Caerffili | 21 |
8 | 28 | 5 |
| Blaenau Gwent / Blaenau Gwent | 25
| 12 | 51 | 11
|
| Torfaen / Tor-faen | 20 |
12 | 39 | 7 |
| Monmouthshire / Sir Fynwy | 38
| 13 | .. | ..
|
| Newport / Casnewydd | 22 |
9 | 40 | 45 |
| | |
| | |
| SCOTLAND | 23 |
12 | 49 | 17
|
| | |
| | |
| Aberdeen City | 22 | 16
| 43 | 35 |
| Aberdeenshire | 26 | 11
| 44 | 8 |
| Angus | 20 | 8
| 54 | 18 |
| Argyll and Bute | 21 | ..
| 37 | 9 |
| Clackmannanshire | 19 | 6
| 33 | 21 |
| Dumfries and Galloway | 16 |
5 | 58 | 16 |
| Dundee City | 30 | 15
| 53 | 24 |
| East Ayrshire | 27 | 12
| 64 | 23 |
| East Dunbartonshire | 30 |
13 | 58 | 13 |
| East Lothian | 26 | 8
| 75 | 11 |
| East Renfrewshire | 30 | 16
| 13 | 11 |
| Edinburgh, City of | 30 |
12 | 68 | 37 |
| Eilean Siar | 39 | 15
| .. | .. |
| Falkirk | 21 | 12
| 48 | 17 |
| Fife | 20 | 11
| 25 | 24 |
| Glasgow City | 20 | 16
| .. | .. |
| Highland | 23 | 11
| 39 | 12 |
| Inverclyde | 20 | 7
| 71 | 15 |
| Midlothian | 36 | 41
| 65 | .. |
| Moray | 31 | 21
| 63 | .. |
| North Ayrshire | 18 | 7
| 81 | 29 |
| North Lanarkshire | 23 | 10
| 56 | 1 |
| Orkney Islands | 23 | 8
| 19 | 3 |
| Perth and Kinross | 36 | 17
| .. | .. |
| Renfrewshire | 26 | 16
| 22 | 45 |
| Scottish Borders | 25 | 13
| .. | 1 |
| Shetland Islands | 23 | 11
| 21 | .. |
| South Ayrshire | 15 | 9
| 57 | 19 |
| South Lanarkshire | 15 | 7
| 20 | 8 |
| Stirling | 17 | 7
| 27 | 12 |
| West Dunbartonshire | 25 |
14 | 93 | 16 |
| West Lothian | 22 | 11
| 53 | 16 |
| Key: | (in italics)
| New unitary authority from 1 April 2009 created from merger of two or more districts
|
| (in italics) | Figure calculated from average processsing times for combined constiuent districts weighted by caseload
|
| LA | claim |
change | |
| |
| Central Bedfordshire | 42
| | |
| |
| Mid Bedfordshire | 32 | 5
| | Mid Bedfordshire |
4,115 |
| South Bedfordshire | 50 |
.. | | South Bedfordshire
| 4,750 |
| | |
| | |
|
| Cheshire East | 44
| | |
| |
| Congleton | 40 | 2
| | Congleton | 2,921
|
| Crewe and Nantwich | 33 |
.. | | Crewe and Nantwich
| 5,247 |
| Macclesfield | 57 | 9
| | Macclesfield | 5,582
|
| | |
| | |
|
| Cheshire West & Chester | 36
| | |
| |
| Chester | 31 | 7
| | Chester | 6,311
|
| Ellesmere Port and N | 49 |
13 | | Ellesmere Port and N
| 4,131 |
| Vale Royal | 32 | 7
| | Vale Royal | 5,747
|
| | |
| | |
|
| Cornwall | 35 |
| |
| |
| Caradon | 18 | 8
| | Caradon | 4,243
|
| Carrick | 34 | 9
| | Carrick | 5,309
|
| Kerrier | 58 | 46
| | Kerrier | 4,944
|
| North Cornwall | 36 | ..
| | North Cornwall |
4,350 |
| Penwith | 25 | 5
| | Penwith | 4,962
|
| Restormel | 37 | 31
| | Restormel | 5,480
|
| | |
| | |
|
| Durham | 76 |
| |
| |
| Chester le Street | 80 | ..
| | Chester le Street |
3,912 |
| Derwentside | 55 |
.. | | Derwentside
| 7,738 |
| Durham | 72 | 9
| | Durham | 5,625
|
| Easington | 48 | ..
| | Easington | 10,236
|
| Sedgefield | 120 | 16
| | Sedgefield | 8,000
|
| Teesdale | 58 | ..
| | Teesdale | 1,284
|
| Wear Valley | 99 | ..
| | Wear Valley | 5,725
|
| | |
| | |
|
| Northumberland | 32
| | |
| |
| Alnwick | 25 | 2
| | Alnwick | 1,913
|
| Berwick upon Tweed | 30 |
8 | | Berwick upon Tweed
| 1,832 |
| Blyth Valley | 26 | 11
| | Blyth Valley | 6,747
|
| Castle Morpeth | 54 | 22
| | Castle Morpeth |
2,143 |
| Tynedale | 25 | 5
| | Tynedale | 2,595
|
| Wansbeck | 39 | 5
| | Wansbeck | 5,156
|
| | |
| | |
|
| Shropshire | 29
| | |
| |
| Bridgnorth | 25 | ..
| | Bridgnorth | 2,227
|
| North Shropshire | 35 | ..
| | North Shropshire |
2,541 |
| Oswestry | 34 | 8
| | Oswestry | 1,870
|
| Shrewsbury and Atcha | 25 |
3 | | Shrewsbury and Atcha
| 4,689 |
| South Shropshire | 28 | 6
| | South Shropshire |
1,893 |
| | |
| | |
|
| Wiltshire | 41
| | |
| |
| Kennet | 55 | 23
| | Kennet | 3,174
|
| North Wiltshire | 25 | ..
| | North Wiltshire |
4,480 |
| Salisbury | 42 | 19
| | Salisbury | 4,830
|
| West Wiltshire | 47 | 13
| | West Wiltshire |
4,950 |
| Key: | |
| (in italics) | No figure available for March next nearest date available used (June or Sepetmber)
|
| (in bold italics) | No caseload figure for March next nearest date avialable used or figure estimated
|
52
National Audit Office (1997) Back
| 
