The positive outcomes after resuming enforcement visits.
Welcome to our blog series, exploring the key topics being discussed in the enforcement industry. In Part 9, we consider how enforcement has developed since visits resumed two months ago.
Since the lockdown restrictions on enforcement activity were relaxed at the end of August, many enforcement firms have informed us that they have been encouraged by the response. People are appreciative of the precautions that they are taking and welcome the opportunity to pay down their debts or set up repayment plans. The vast majority of those visits have been to enforce fines, traffic offences and other penalties that have been outstanding since before lockdown measures led to a suspension of activity.
But this is not to say there have not been unique challenges. CIVEA has acted quickly to take measures where we have identified room for improvement. We recently published a detailed reportbased on a survey of 21 enforcement firms and their field agents, which was originally prepared for the Ministry of Justice (MOJ). This provided unique insight from Enforcement Agents (EAs) about the safety measures put in place and whether they are sufficiently protecting themselves and their customers.
Our report is a balanced and candid, first-hand account of the challenge enforcement agents face. Councils in England and Wales are highly efficient at recovering taxes in fines, but there will always be a minority of debt that requires additional effort. The power of enforcement is that agents can visit people at home where they can see clearly whether someone is deliberately refusing to pay their debts or is vulnerable and in need of welfare support. Clearly, enforcement cannot be as effective without entering premises, but all our agents are acting according to CIVEA guidelines. Reviewing the responses from EAs allows us to see where additional training and guidance is needed. For example, agents had concerns about the removal of face coverings in certain situations and on the rules around handling cash.
EAs reported that some people were struggling to understand them when wearing face masks, especially those who do not have English as a first language. The CIVEA advice remains that face masks should be worn to protect the public where possible. However, providing that two-metre social distancing is maintained, we decided that it is reasonable for masks to be removed; especially where communication is difficult otherwise - and provided the agent keeps the required distance. Regarding cash payments, whilst online and card payments are the safest option and most people can pay this way, CIVEA advised that cash payment can be made safely where necessary. EAs should count the cash wearing gloves, and then seal it in an envelope or bag for 72 hours, according to the Public Health England and Wales guidance. As always, this advice should accord with individual company procedures.
CIVEA acted swiftly and contacted all its members to share this new advice and avoid confusion. We also reminded members that we continue to monitor government guidelines and work closely with the Ministry of Justice. We will continue to update members on new policy and advise them on best practice as we continue to learn the lessons.
Encouragingly, feedback from firms both large and small firms across England and Wales suggests that people are generally respecting social distancing and understand that EAs will not enter their homes.
After months without enforcement visits and with additional pressure on their budgets, councils will be encouraged to learn that our agents are still able to recover outstanding debts safely and responsibly. In a recent CIVEA survey, of over 370 councils that responded more than 90% have resumed enforcement visits. The situation remains dynamic considering the ongoing pandemic, but this is a vote of confidence that supports those councils that are adapting their offices to allow staff to back to work as soon as possible.
The full CIVEA report on post-lockdown visits is available here: https://www.civea.co.uk/blog/civea-report-one-month-of-enforcement-visits
Two animations remain available on the CIVEA website to outline the standard enforcement process as well as updates related to COVID-19, ‘COVID-19 Safe Working Practices’ and ‘CIVEA Guide To Enforcement’.
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