Richard Brookes

Official 

Ms Anna Morris KC 
H.M. Assistant Coroner for Greater Manchester South 
H.M. Coroner’s Office, 
1 Mount Tabor Street, 
Stockport, 
SK1 3AG. 

Caxton House  
Tothill Street  
London   
SW1H 9NA 

28 January 2025 

Dear Ms Morris,  

RESPONSE TO REGULATION 28 REPORT TO PREVENT FUTURE DEATHS  

We write on behalf of the Department for Work and Pensions (“DWP”) in response to your 
Prevention  of  Future  Deaths  Report  made  under  Regulation  28  of  the  Coroners 
(Investigations) Regulations 2013.  

We would like to take this opportunity to express our condolences, both personally and on 
behalf of DWP, to the family of Mr Richard Brookes (“Mr Brookes”).  

You raised the following concerns in your report: 

1. This was a large payment of money to a vulnerable adult who was then required to 
self-manage  that  money.  In  these  situations,  it  is  important  that  there  are  robust 
systems in place for ensuring that the requisite assessments and checks are made 
of an individual to ensure that large payments can be made in a way that does not 
increase any vulnerability. 

2. I heard evidence from [DWP] that the DWP systems that are currently in place are 
hybrid of electronic and clerical systems and that payments can be initiated without 
there being a full note on the system of the content of the call with the individual. 

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3. I am therefore concerned that there is no way that an agent, quality assessor or 
team  leader  can  properly  evaluate  whether  any  agreement  made  between the  DWP 
and an individual regarding repayment has fully considered all the relevant factors 
regarding their vulnerabilities before a large payment is made. 

4. I am also concerned that the DWP currently has no ability to effectively audit its 
large payments caseload to ascertain whether the failure in record keeping evident in 
the present case has occurred in other cases. 

Our response to your concerns is as follows: 

(1) DWP processes in place to ensure large payments can be made in a way that does 

not increase a customer’s vulnerability 

The  department  has  Making  Large  Payments  guidance  to  support  colleagues  that 
administer  large  payments  to  customers  who  may  face  challenges  receiving  or  handling 
such payments, as a result of declared or known complex needs. Where we identify that a 
customer  may  benefit  from  additional  support  with  a  large  payment  (resulting  from,  for 
example,  a  previous  underpayment  or  backdated  payment  decision),  the  department  will 
discuss the payment with the customer or their representative and signpost them to support 
if required.  

The guidance [Annex A] defines a large payment as £2,000 or more and applies to every 
benefit administered by DWP. The exception to this definition is where a customer’s usual 
monthly Universal Credit (“UC”) payment is over £2,000, in which case the threshold used 
is whether the amount is twice their normal UC payment. 

The  guidance  prompts  DWP  agents  to  consider  vulnerabilities  and  mitigate  the  risk  that 
receiving  a  large  amount  of  money  might  expose  a  customer  to.  Different  departmental 
computer  systems  must  be  checked  for  key  indicators  of  potential  vulnerability,  such  as 
neglect, domestic abuse, physical or sexual abuse, or modern slavery.  

For  DWP  purposes,  the  description  of  vulnerability  is  'an  individual  who  is  identified  as 
having complex needs and/or requires additional support to enable them to access DWP 
benefits  and  use  our  services'.  Complex  needs  are  defined  as  ‘difficult  personal 
circumstances  and/or  life  events  that  affect  the  ability  of  the  individual  to  access  DWP 
benefits and use our services’. 

A checklist helps agents establish whether a customer has vulnerabilities or an appointee. 
Factors to consider include, but are not limited to, the following: 

•  additional support already noted on a departmental system 
•  addictions 
• 
•  homelessness 
•  mental health issues 

risk of financial exploitation 

If  there  are  no  concerns  identified,  normal  payment  routes  will  be  followed  and  notes 
inputted onto the computer system. If, following system checks, a concern is identified the 
case  will  be  paused  and  the  payment  will  not  be  made.  Relevant  local  agencies  will  be 
identified before a call is made to the customer to discuss payment options and the support 
available to help them manage the money. 

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The  customer  is  free  to  choose  how  they  wish  to  receive  their  payment  from  options 
including: 

lump sum payment, 

• 
•  payment to a third party, or 
•  staggered payments over a period of time. 

DWP cannot legally withhold benefit from a customer or force them to receive their payment 
in a particular way. 

If, following the call, an agent still has concerns about a customer’s vulnerability, the case 
will  be  escalated  before  any  payment  is  made.  Escalation  routes  include  liaising  with 
Vulnerable  Customer  Champions  (“VCCs”),  the  Customer  Experience Advanced  Support 
Team  (“CEAST”)  and  Advanced  Customer  Support  Senior  Leaders  (“ACSSLs”),  further 
described below. VCCs, CEAST and ACSSLs will decide how best to provide support, and 
agents must follow the steps agreed and update the system with the action taken. 

CEAST teams within Working Age (the business area where ESA sits) were established in 
January  2021  to  support  colleagues  who  identify  customers  with  vulnerabilities  and  who 
need advanced support. CEAST have VCCs based in all processing and telephony teams. 
VCCs are the first level of additional support available to DWP colleagues working to ensure 
vulnerable  customers  receive  tailored  support.  If  the  VCC  has  any  complex  queries  that 
cannot be resolved as part of standard processes, they will escalate to CEAST as the next 
level of additional support for more complex cases. If yet further support is required, CEAST 
will refer to the ACSSL as the most advanced level of support available. 

Key  to  the  ACSSL  role  is  the  building  and  maintaining  of  relationships  with  external 
organisations  that  support  vulnerable  citizens,  acting  as  a  link  into  external  agencies’ 
escalation  routes,  enabling  increased  cross-agency  case  collaboration  and  more  holistic 
support for customers. DWP has a network of ACSSLs throughout Great Britain, who coach 
and  engage  with  colleagues  across  DWP  services  to  help  support  its  most  vulnerable 
customers.  

In Mr Brookes’ case the Making Large Payments guidance was used as the amount owed 
to him was over £2,000 and the agent identified him as vulnerable. Despite not recording 
system notes, the agent is confident that they called Mr Brookes and discussed his payment 
options. As a result of that call the large payment was broken down into smaller amounts, 
quality checked and scheduled to be issued over eight months. 

The department accepts that the notes recorded by the agent were inadequate and there 
was no record of what was discussed and decided during the call with Mr Brookes. Feedback 
has been given to the agent regarding the need to record details of the conversations leading 
to the splitting of payments in this way.  

Existing guidance does not expressly state that recording notes of calls with customers on 
computer systems is mandatory, although training packages and upskilling communications 
do  include  the  need  to do this. The  department  is  reviewing  the  Making Large  Payments 
guidance  within  Working  Age,  with  a  view  to  mandating  that  any  calls  made,  and  any 
agreements reached, be recorded on the DWP systems, and that any related documents 
are stored in the digital repository. The department is also designing a letter to be issued to 
customers who have requested or agreed a staggered payment. 

Whilst this activity is currently localised within Working Age, improvement teams across the 
department  are  working  together  to  monitor  the  progress,  to  potentially  influence  wider 
guidance changes. 

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As  part  of  the  learning  the  department  has  taken  from  Mr  Brookes’  case,  an  upskilling 
communication has been circulated to all colleagues within Working Age to remind them of 
the correct process to follow when making large payments. This includes the requirement to 
consider  the  size  of  the  payments  and  the  importance  of  recording  conversations  with 
customers.  

(2) Limitations  of  the  DWP  computer  systems  used  to  administer  Employment  and 

Support Allowance, and supporting guidance for vulnerable customers 

The process of administering Employment and Support Allowance (“ESA”) involves the use 
of a number of different, standalone IT systems. 

JSAPS (Job Seekers Allowance Payment System) is the DWP system used to manage the 
day-to-day assessment, award, payment and maintenance of ESA. JSAPS is over 22 years 
old and therefore has limited functionality. It is relevant to this case to note that JSAPS does 
not have the function to stagger ESA payments, like Mr Brookes’ Severe Disability Premium 
(“SDP”) arrears, and a separate, standalone system is used to make these payments. 

In  cases  where  high  value  payments  to  ESA  customers  need  to  be  broken  up,  like  Mr 
Brookes’  case,  the department  has  ‘Staggered  Payments’ guidance  [Annex  B]  to  support 
agents because different systems need to be used. As this part of the process is manual it 
means  there  is  no  built-in  checklist  or  system  generated  prompt  to  check  for  accuracy. 
However,  the  departmental  process  does  specify  that  the  calculations  and  the  decision 
should be referred to a team leader for verification. In Mr Brookes’ case, records confirm the 
calculations were verified by a quality checker and the staggered payments were verified by 
a team leader before being inputted to the payment system. 

(3) How the Move to UC will improve the way relevant factors regarding a customer’s 

vulnerabilities are checked and assured before large payments are made  

As explained above, JSAPS does not have a built-in checklist to confirm every step of the 
Making  Large  Payments  process  has  been  completed,  specifically  the  notes  of  the 
conversation between the agent and the customer. Neither is there any functionality to block 
a  payment  being  issued  where  the  checklist  is  incomplete.  To  mitigate  this,  internal 
processes and quality assurance have been improved and are further described below.  

As the department plans to close some legacy benefits, including Income Related ESA, by 
the  end of  March  2026,  there  are no  plans  to  invest  money  or  resources  in  the outgoing 
computer systems. The work required to update the old JSAPS system would be expensive 
and an inefficient use of resources, so instead policy and guidance are reviewed to support 
colleagues using the legacy benefit systems. Existing Income Related ESA customers will 
migrate to UC which operates on a digital platform, known as “the UC Service”. This has 
additional functionality including both automated and agent led processes. UC will now be 
briefly explained, as well as how the process of making large payments will be improved on 
the UC system. 

UC was introduced by the Welfare Reform Act 2012 to replace six legacy benefits, including 
ESA,  with  a  single,  streamlined  and  simplified,  digitally  delivered  benefit  system  that 
provides work incentives for those who can work and support for those who cannot. UC has 
been introduced in a controlled and phased manner with legislation preventing new claims 
to  working  age  income  related  benefits and existing  legacy  benefit  claims terminated  if  a 
claim to UC is made. This means all new claims for income related benefit are now to UC. 

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All customers currently claiming legacy benefits who want to maintain their entitlement to 
income-related working age benefit will have to make a claim to UC. They may choose to 
make a claim to UC (voluntary migration), or they may experience a change of circumstance 
that  means  they  need  to  claim UC (natural  migration).  The  remainder  of  legacy  benefit 
customers, who do not move voluntarily or through natural migration, will be informed that 
they must claim UC to maintain their benefit entitlement (managed migration). 

On 12 November 2024 the Minister for Social Security and Disability announced that DWP 
will steadily increase the number of migration notices being sent to customers receiving ESA 
over the next months, with all notices due to be sent by the end of 2025.  

UC  has  specific  guidance  on  ‘Handling  Larger  Payments’  which  compliments  the 
department’s  Making  Large  Payments  guidance.  It  supports  UC  agents  handling 
circumstances  like  those  of  Mr  Brookes,  where  a  UC  customer  may  be  due  a  large 
payment. It  recognises  that  some  customers  may  find  receiving  and  managing  a  large 
payment challenging for a variety of reasons such as their personal circumstances, risk of 
financial abuse, or difficulties in understanding, processing or managing financial matters. 

As Mr Brookes was not a UC customer, it was the Making Large Payments guidance and 
not the Handling Larger Payments guidance that was used in his case. The UC guidance is 
included  here  to  provide  assurances  that  UC  has  processes  to  support  agents  and 
customers in these circumstances. 

The UC specific guidance advises colleagues to investigate which other benefits a customer 
may be claiming to identify any vulnerabilities that may have been disclosed elsewhere. That 
information must be used to decide how to best support the customer. 

Where an agent identifies that a customer may need additional support, they must: 

•  call the customer or their appointee before making the payment to discuss whether 

the customer requires support, 

•  make at least 3 contact attempts over two days. If there is no appointee, the agent 
will advise the customer through their journal that they are going to phone to discuss 
making a payment, 

•  consider using other departmental systems to see if other contact numbers are listed 

where attempts to contact the customer are unsuccessful, 
record a note in the 'Customer history' of the UC account detailing the actions taken. 

• 

If contact is made, the agent must: 

•  explain to the customer the amount of arrears payment they are entitled to and why. 
•  ask the customer if it would support them to: 

i) receive this as a lump sum, 
ii) have the payment made to another person,  
iii) have the payment staggered over a number of months, or 
iv) have a combination of these put into place, 

•  consider signposting the customer to third party support,  
• 

record  details  of  the  conversation and  choice  made  by  the  customer  and  attach  a 
pinned note to the claim regarding any payment arrangements agreed. 

If an agent has any concerns or has been unable to contact the customer or their appointee, 
the case can be escalated to the ACSSL by a Team Leader for advice on how to proceed 
before releasing the payment.  

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When all steps have been exhausted and no contact has been made or the customer has 
failed to engage, the customer is still entitled to the payment and it must be issued. All the 
actions taken must be documented before this decision is made. 

Where an  agent  decides  that  the  customer  does  not  require  additional  support,  they  can 
make the payment in one lump sum. 

Alongside the Handling Larger Payments guidance, the UC Service has a check list, 
known as a ‘to-do’, built into the system to guide the agent through the process described 
above step by step. The checklist does not specify that a note must be made of the 
conversation with the customer but it does contain a notes field, and the expected 
standard across DWP is that when a call is made to the customer notes are recorded in 
either in the notes field of the ‘to-do’ or in the history notes section of the UC claim.  

The Service prompts the agent to check for additional support needs and, if identified, the 
customer must be contacted and alternative payment methods offered. If the agent has not 
answered any of the questions in the to-do, they cannot progress to the next stage. This is 
a robust feature built into the computer system that the ESA systems could not provide. 

(4) How ESA audits its large payments caseload to prevent errors occurring  

Severe Disability Payment Arrears Review 

To prevent and rectify errors on ESA claims, a specialist team was set up within Working 
Age to review cases where ESA customers were claiming Personal Independence Payment 
(“PIP”) but did not have the Severe Disability Payment (SDP) element which they may have 
been eligible for. Receipt of PIP is one of the qualifying criteria for SDP. As Mr Brookes had 
been reawarded PIP in 2020 his case fell under the scope of this team. 

As a result of the issues identified in Mr Brookes’ case, activity has taken place within that 
specialist team to improve compliance with the Making Large Payments guidance. Clerical 
forms have been revised to prompt agents to: 

•  establish whether the customer is vulnerable, 
•  confirm a call has been made to the customer, 
• 
• 

record all conversations that have taken place with the customer, 
record all decisions made about how the customer wants to receive the payment.  

The revised forms are checked by Team Leaders on every case to ensure compliance with 
guidance, including a check that calls have been made to customers, where appropriate, 
and  that  notes  have  been  made. Agents  are  required  to  provide  any  missing  or  unclear 
information  as  a  priority.  In  addition  to  the Team  Leader  check,  the  case  goes  through  a 
quality assurance check by a separate team. This quality assurance check reviews the entire 
process, including a check of calculations of high value payments. This has introduced a 
two-tier, holistic check that was not in place before Mr Brookes’ case.  

Since introducing these more robust checks Team Leaders have been able to coach agents 
in the level of detail the revised forms require. Team Leaders are also now verifying cases 
where no vulnerability has been identified by an agent to avoid any doubt that vulnerability 
has been considered. 

This extra assurance activity only applies to this specialist team working on SDP cases and 
is not currently a national process. Nationally, teams follow the existing process for Making 
Large  Payments  which  includes  service  assurance  checks  regarding  the  value  of  the 
payments and quality assurance checks as set out below.  

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Two-Tier Quality Assurance Framework 

In  addition  to  the  specific,  improved  multi-level  checks  mentioned  above,  the department 
does have a robust, two-tier quality assurance process to ensure colleagues are adhering 
to DWP’s Quality Framework. This framework is used to check the Making Large Payments 
process. 

The Framework includes Customer Support Standards which were designed specifically to 
improve the experience of customers with complex needs and significantly reduce instances 
of serious cases by providing the right support at the right time. The four Customer Support 
Standards are;  

•  Advance Customer Support  
•  Accessibility Requirements  
•  Appointees  
•  Six Point Plan (DWP’s response to declarations of suicide or self-harm) 

The Customer Support Standards are incorporated in both tiers of the department’s quality 
assurance process and focuses on customer experience. 

Tier  1  checks  see  line  managers  checking  samples  of  their  team’s  work.  This  identifies 
individual errors or non-compliance with guidance and allows for immediate feedback and 
coaching.  For  example,  if  there  is  no  evidence  of  a  call  being  made  to  the  customer  to 
discuss making a large payment, then feedback would be given to update the system with 
the action taken and decisions made. 

Tier 2 checks see a dedicated quality team checking a sample of customer cases to assure 
compliance  with  relevant  guidance  and  processes.  Where  an  error  against  the  Customer 
Support  Standards  at  Tier  2  is  identified,  a  pause  is  put  in  place  to  consider  how  any 
correction  activity  might  affect  a  customer’s  vulnerability.  This  is  fed  back  directly  to  the 
service line to make colleagues aware of the risk to be managed when rectifying the error.  

The  department’s  Quality  Assurance  processes  are  intended  to  reinforce  training  and 
upskilling  campaigns.  They  enable  DWP  to  identify  where  additional  support  could  have 
been  provided  to  customers  with  varying  needs  or  vulnerabilities,  reducing  the  risk  of  a 
negative customer experience and potential development into serious cases. 

Conclusion 

The department is committed to ensuring that customers are given the right support at the 
right time. This commitment is reflected in the improvements that have already been made 
to  record  keeping  and  quality  assurance  checks  where  vulnerable  ESA  customers  are 
entitled to large sums of money.  

Robust  guidance  exists  which  supports  agents  to  follow  the  correct  process  and  support 
vulnerable  customers  in  these  complex  cases.  Escalation  routes  into  more  specialised, 
advanced support are already in place to ensure that vulnerable customers receive a tailored 
service. 

As  Income  Related  ESA  customers  are  migrated  onto  UC,  vulnerable  customers  will  be 
supported  by  guidance  specific  to  UC  and  the  improved  functionality  of  the  UC  Service, 
seeing clerical forms being replaced by an automated process. 

We  hope  that  our response  addresses  your concerns and helps  to  assure  you  of  DWP’s 
commitment to improving the service it provides to vulnerable customers. 

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Yours sincerely, 

Operational Lead for Northeast England 

Chief Medical Advisor 

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Annex A 

Making Large Payments 
Some  customers  will  find  the  experience  of  receiving  and  managing  a  large  payment 
challenging.  This  could  be  for  a  variety  of  reasons.  It  may  be  because  of  their  personal 
circumstances  or  particular  issues  they  are  dealing  with  or  it  may  be  they  have  limited 
capacity  to  understand,  process  or  manage  financial  matters.  They  may  or  could  be 
influenced or open to abuse by others. 

Not  every  claimant  with  complex  needs  will  require  a  change  to how  they  are  paid but  it 
should be considered. 

The  principles  of Listen,  Consider, Act  and  Review must  guide  any  decision  and  in  each 
case a record must be made of the reasons so we are able to explain this to the customer 
and other interested parties as necessary. 

A  generic  process  has  been  developed  which  includes  key  activities  all  services  will  be 
required to undertake. 

The generic instructions detailed below are intended to support the continuing work of each 
individual product line, and promote consistency of approach across the department. 

Staff  should  always consider  overlapping  benefits  and  abatements  where  applicable 
and refer to their own product lines for detailed, benefit specific, instructions on Advanced 
Customer Support: Making Large Payments. 

If it is identified that a customer is paid by Payment Exception Services (PES) which is a 
provision  via  vouchers  (Max  value  £100  per  voucher),  this  does  not  support  high  value 
payments. A MOP [method of payment] discussion must be undertaken with the Customer 
to decide on an alternative payment method, ideally a simple bank account.  

Payment stage 

If the customer is due to receive an arrears payment / underpayment or payment outside of 
their usual payment cycle, you should always consider overlapping benefits and abatements 
where applicable. 

If payments are made by PES, shown as ‘Clearbank’ you must undertake an urgent MOP 
discussion, even if no vulnerability is identified. 

You must then: 

1.  Check  if  the  customer  has  support,  for  example,  a  Power  of  Attorney  (POA)  or  an 

Appointee. 

Note: If the customer has a POA or Appointee, then follow the normal process to issue the 
payment and update the system with the action taken. No further action needed. 

2.  Consider the amount being paid. Refer to Checklist. 

Note: If the amount is below £2000, you must follow the normal process. (Exceptions can 
be  considered  in  cases  where  the  customers  circumstances  are  known  and  indicate  the 
payment may be a cause for concern). Refer to Checklist. No further action needed. 

3.  If  the  amount  is  £2000  or  above,  you  must  check  Owning  Benefit  systems  for  key 

indicators of potential vulnerability concerns. 

Note:  Utilise  the Checklist to  identify  additional  considerations  using  information  where 
possible from DWP systems. 

4.  Has a Vulnerability concern been identified? 

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• 

If No, you must follow the normal process and update the system with the action 
taken. No further action needed. 

• 

If Yes, continue at step 5. 

5.  Is there Debt interest? 

• 

• 

If No, continue at step 6. 

If Yes,  do  not  issue  payment.  Email  to  Debt  using Offsetting Arrears  of  Benefit 
proforma answering Yes to Vulnerable Customer. Update system with the action 
taken. No further action required. 

Note: If  Debt  email  the  Offsetting Arrears  of Benefit  proforma  back  with  details  of  arrears 
due to customer, you should always consider overlapping benefits and abatements where 
applicable and then continue at step 6. 

6.  Discuss  Vulnerability  concern  with  a  Team  Leader  /  nominated  person.  You  must 
consider utilising  the District  Provision Tool if available  for  your  process  /  product  line. 
You must consider the payment options available, for example, Breakdown / Staggered. 
This information will be used to prepare for the call to the customer. 

7.  Make outbound call to the customer. See: Making Payment Safely Call Guide. 

Note:  If  the  customer  has  an Alternative  Format  or  a  Reasonable Adjustment  recorded, 
consider whether an alternative method of communication should be used. You must contact 
the customer using the alternative method of communication, and update the system with 
the action taken, including agreed next steps. 

8.  Was contact made with the customer / 3rd party? 

Note: You must attempt to contact the customer 3 times over 48 hours, and at different times. 

• 

• 

If No, you must update the system with the action taken, continue at step 9 

If Yes,  you  must  explain  the  purpose  of  the  call,  and  give  the  customer  clear 
payment options. Update the system with the action taken, continue at step 9 

Note: If the customer requires additional support, use the District Provision Tool to identify 
appropriate  partners.  If  the  customer  wishes to  consider  their  options or  speak  to a  third 
party, agree a time with the customer to call them back to discuss their choice. 

9.  Has a payment option been agreed with the customer? 

• 

If Yes, you must follow the normal process to implement their choice, then update 
the system with the action taken. No further action is needed 

• 

If No, you must discuss with Team Leader / Nominated person 

10. Do you still have Vulnerability concerns? 

• 

If No, you must follow the normal process, then update the system with the action 
taken. No further action is needed 

• 

If Yes, then continue at step 11 

11. Identify escalation routes available for product line.   

•  Follow  escalation  route  for  example, Vulnerable  Claimant/Customer  Champion 
(VCC) Advanced  Customer  Support  Senior  Leaders  (ACSSL)  as  agreed  with 
Team Leader / Nominated person 

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• 

• 

If you contact the VCC, then the VCC will decide how best to support you. You 
must follow the next step as agreed with the VCC, then update the system with 
the action taken 

If  you  contact  the  ACSSL,  then  the  ACSSL  collaborates  with  relevant 
organisations where appropriate. You must follow the next step as agreed with the 
ACSSL, then update the system with the action taken 

12. Once all reasonable steps have been taken use all the gathered information to decide 
how payments should be issued as per normal process, and update system with action 
taken. 

Annex B 

Staggered Payments  
Staggering high value payment arrears  

1.  The  Opstrat  system  does  not  have  the  function  to  stagger  Employment  and  Support 

Allowance (ESA) arrears payments.  

2.  When the system calculates an arrears payment this will generate FF100s in amounts 

of £499.99 – these are to be cancelled.  

3.  The  payments must  be transferred  to  form  ESA14P  to  record  the  staggered payment 

periods and amounts.   

See Making Large Payments   

See Advanced Customer Support Hub  

4.  The following instruction will guide you through the process.    

5.  If the claim is maintained on the system:   

Step   

Action  

1 

2 

3 

4 

Select  F2  in  dialogue  JA405  to  change  the  arrears payment  to ‘CG’  (clerical 
cheque) and select ‘END’    
Note:  This  will  breakdown  the  payment  and  generate  FF100  in  amounts  of 
£499.99. 

Cancel FF100s as these are not to be used. 

Complete  ESA14P  showing  details  of  the  agreed  staggered  payment  period 
and  amounts  and  record  on  Central  Payment  System  (CPS)  as  ongoing 
payments. 

Refer ESA14P to line manager (LM) for approval    
Note: The  ESA14P  should  be  held  in  a  secure  location  for  18  months  after 
approval in line with usual document retention policies. 

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5 

Enter a note in dialogue JA110 with details of the staggered payment and action 
taken.   

6.  If the claim is maintained clerically   

Step  

Action  

1 

2 

Complete ESA14P showing details of the agreed staggered payment period and 
amounts and record on CPS as ongoing payments.  

Refer ESA14P to LM for approval   
Note:  The  ESA14P  should  be  held  in  a  secure  location  for  18  months  after 
approval in line with usual document retention policies. 

3 

Record details of the staggered payment within the clerical record. 

7.  You  must  ensure  that  quality  notes  are  held  on  all  available  systems  to  explain  what 

actions have been taken and why.   

8.  Ensure that normal benefit payments are issued on time as business as usual.  

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