Andrew Western MP: speeches

Speeches

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q What is your view on its proportionality as a direct response to what has been a £35 billion challenge for the Department since covid? Given the increase in prevalence of both fraud and error—particularly fraud, which is estimate to have cost upwards of £7 billion—do you think that is a material consideration when assessing proportionality? Ellen Lefley: When I speak about proportionality, the degree of loss is relevant, but there is no question but that the economic wellbeing of the country is a legitimate aim. On whether measures are proportionate to achieving that aim, we must consider not only whether there is any reasonable suspicion, but the degree of external oversight. The Bill includes that consideration, and there are various ways in which some of the powers are subject to independent review. We have some suggestions as to how those independent review mechanisms can be a stronger safeguard and therefore make the measures more proportionate. For example, the independent review mechanisms seem to have the ability to access information but no power to demand it. That raises a query as to transparency and the full ability of the independent reviewer in different circumstances to meet their objectives. Also, when an independent reviewer lays their report before Parliament with recommendations and those recommendations are not going to be adopted, it might be helpful for there to be an obligation on the Department to provide reasons why not. That would be a more transparent way of ensuring that the oversight measure is as effective as intended.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Would that be the case in any preventive measure that we took in pursuit of tackling benefit fraud that did not come about as a direct result of suspicion of fraud? With anything that we try to do with the entire cohort, would we be open to that accusation? Ellen Lefley: Raising the risk of indirect discrimination when you have cohorts of the population that are disproportionately reflected in any subcommunity of the population that will be exposed to any power is a relevant consideration, so yes in that respect. When it comes to the eligibility-verification measures, the proportionality analysis is, in our view, strained because there is not that threshold of reasonable suspicion. The mere fact that benefits recipients are in receipt of public funds makes them subject to this power. Of course, that could go further; all the public servants and MPs in this room are in receipt of public funds. If that is the threshold that we as a society are happy with, some real scrutiny of its proportionality is required, because it is a power that can require private financial information.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Thank you. I am hopeful that, through the informal conversations and the formal consultation that we are required to have on the code of practice, we will be able to set this up in such a way that everything interplays in an acceptable way. You briefly mentioned direct deduction orders. I know you have some concerns about the debt recovery power, and this is an opportunity for you to set them out. Is there anything you want to elaborate on beyond what you have just said about that element of the powers we are proposing? Eric Leenders: There are two or three key areas for us. First is the affordability assessment. I think you have heard previously that the use of the standard financial statement would be helpful in outlining essential monthly expenditure. I will come back to that point. Secondly, I believe the caps differ between the PSFA and the DWP. We think that they should be aligned, with the PFSA’s 40/20 split also applied to the DWP. It is also quite important that there is some form of de minimis, so that individuals do not find themselves without any funds whatsoever. Our thinking is something aligned to the £1,000 threshold that there is in Scotland. HMRC has a threshold of about £5,000, or £2,000 for partners paying child maintenance. We think there should be a floor, but more essential is consideration of one month’s essential expenditure. That would allow the individual to readjust their expenditure in the period when they need to consider making the payments under the deduction order, or indeed the period in which the balances are withdrawn.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Could I come back on the last point you made, Rick, and the suggestion that this treats disabled people as a distinct part of the population under different rules and measures. The Bill targets the three benefits that have the highest levels of fraud and error at present: universal credit, pension credit and employment and support allowance. I would accept that there is a higher prevalence of people who are disabled in those cohorts, but this is not restricted exclusively to disabled people. Can you elaborate a little on how you feel that disabled people, in isolation, would be treated as a separate entity? Rick Burgess: Because we are over-represented in those classes. If you choose to target it at those cohorts, you are accepting an additional level of targeting towards disabled people, which is discriminatory.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Thank you both for joining us today. I have an overarching question about the impact of the proposed modernisation of DWP processes and whether you think that that will improve the detection of fraud and error. Joshua Reddaway: Specifically, do you mean the EVM—eligibility verification measure—stuff?

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q It was not, but we will leave it there, because clearly you are not aware of the powers that I am referring to. You talk about the inclusion of error, as well as fraud, in what we are attempting to do here. Do you accept that there is the potential, through the effective use of the eligibility verification measure, to detect overpayments through error sooner, thereby reducing any overpayment because it would come to light earlier? Jasleen Chaggar: Yes, and to stop people getting into debt is an incredibly laudable aim. The question is whether we are willing to infringe the privacy rights of the entirety of the population to do that. Perhaps a more proportionate solution would be to make it easier for those benefits claimants who are making mistakes to navigate the system in the first place. Coming back to your previous point, if you were happy to send me information about those powers, I would be happy to get back to you with our position on those.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q I suspect Minister Gould will have the bulk of the questions for you, Mark, but I have a very general question. There has, understandably, been a lot of discussion and questions today about the balance between people’s privacy and being able to prevent fraud. What is your overall view on whether the Bill strikes the necessary balance between the two? Mark Cheeseman: My view is that the Bill does strike that balance, and it tries to strike the balance. It is difficult, because you need to balance the ability to take action against someone who has committed fraud against the state with having fair and reasonable processes for looking at someone who has not. The purpose of an investigation is not to find fraud; it is to find fact. That is why we have professionals who are trained and have a code of ethics around objectivity; their role is to find fact, not fraud. The Bill tries to strike that balance both by having authorised officers and by having the oversight that is in place. The Government structure, in having the counter-fraud profession, provides some of that as well. My view of the Bill is that there is a fair amount of independent oversight—that is a good thing—to increase how well things are done.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q One more, if I may, Chair? Richard, one of the powers we intend to take is around search and seizure for the DWP when investigating serious and organised crime. That is a power that HMRC have had for some time. Can you reflect on what the benefits of that have been for HMRC’s operations, in terms of no longer needing to rely directly on the police to fulfil that function? Richard Las: Ultimately, it allows us to operate immediately and with real clarity. We would be under the same kind of governance and restrictions as the police would be, in terms of having to go to a court to get those warrants, but, in terms of our ability to—

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q I would argue that we are accepting a different level of checking on the eligibility verification measure for everybody in receipt of those benefits. I would be perfectly happy to accept that there may be some indirect discrimination against disabled people by virtue of the fact that they are over-represented in the cohort, but are you suggesting that this would amount to direct discrimination? Rick Burgess: I think it does edge into that. There is certainly established thinking and case law that begins to establish that. The Equality and Human Rights Commission need to be brought into this urgently. There need to be public and transparent equality impact assessments, because I do not see how this does not breach a right to privacy and represent discrimination against groups who are over-represented in these cohorts.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  I will not ask any more questions, but I just say to Rick that I think it might be helpful for a follow-up conversation to take place. Without wishing to get into a protracted argument, there were some things that I did not recognise as part of the Bill, but clearly that is how people are feeling and how the people you represent are feeling. I am very happy to ask officials to pick up a conversation to go through the detail.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Thank you. Richard, you made a point around the existing powers that HMRC has had, since I think 2011, to request information on every interest-bearing bank account in the country, as I understand it. Could you explain what safeguards and oversight you have in place, because that feels like a similar bulk data exercise? Do you think the oversight that we are proposing to put in place alongside these powers is equivalent, or do these powers have more or less oversight than the powers that HMRC has enjoyed for 14 years? Richard Las: It is the Finance Act 2011 that you refer to, which allows us bulk data gathering powers on information that we believe will support our functions. I guess it is not just the banks, but we do get the information on interest-bearing accounts. It is an annual exercise, not a real-time exercise. It is clearly timed in such a way that it helps us understand whether the right amount of tax has been paid on interest that has been accrued. We are talking about large accounts because in most cases people’s interest is quite small, but there will be some people who get a lot of it. We have a huge amount of controls over how we manage that information and how we use it and protect it; they are our normal requirements as with any other taxpayer data. We gather other information from third parties. We have information from merchant acquirers on transactions that businesses might make, for example. We also have information that we get from online platforms in terms of sales and things like that. It is all part of bringing that information together. HMRC very much respects taxpayer confidentiality and manages that data responsibly. I guess those safeguards can exist in other organisations.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q To clarify, you accept that there are bulk data powers, but it is just a different cohort of people. Jasleen Chaggar: I am not aware of powers that are similar to eligibility verification notices that are exercised by the DWP. I am aware that they have similar powers in relation to direct deduction orders, and maybe that is the distinction that the witnesses earlier were making.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Thank you for joining us today, and for the engagement that we have had so far; it has been incredibly helpful and you have my assurance that it will continue. I would like to test the point that you have just set out on the POCA measure within EVM, as well as rolling that out more broadly. Clearly we want to ensure that the burdens on banks that arise as a result of the EVM measure, and any of the other measures, interplay in an acceptable manner with the broad range of duties that fall upon you, including the consumer duty. In the interest of transparency, could you set out for the Committee your other concerns regarding potential conflicts if we do not get things right as we construct the code of practice? Daniel Cichocki: We are making this suggestion because under the Bill banks responding to an information request or a direct deduction order, would have to consider whether there is some indication of financial crime that under POCA requires them to make a suspicious activity report. We think it is simpler to remove that requirement, not least because where there is a requirement to make a suspicious activity report there is a requirement to notify the authorities; clearly, there is already a notification to the authorities when complying with the measure. Removing that requirement would avoid the risk that banks must consider not only how to respond to the measure but whether they are required to treat that individual account as potentially fraudulent. We are trying to manage risk out of the system more broadly with financial crime compliance, so we think it is much more proportionate and effective to simply apply the same exemption across all the measures in the Bill.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Given that we have no way of knowing if somebody is in breach of the capital limit once they have given their word that that is not the case, how would you suggest that we detect that particular form of fraud where there is no suspicion of fraud because we do not know what somebody has in their bank account? Jasleen Chaggar: I think that it is important that suspicion has already arisen before those policing powers can be enacted. The police already have powers to request that granular financial information where there is suspicion of fraud.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Just to test that a little further, were we to do anything in the prevent space on fraud and error that sought to increase the safeguards and checks in place for all benefit claimants, is it your view that all of those would directly discriminate against disabled people because they are over-represented in the cohort? Rick Burgess: It is about where that measure is one of a number of additional enforcement measures, rules or laws that would have negative consequences. The key to this is the trawling nature of the technology; it is not targeted, beyond being aimed at everyone on UC, everyone on ESA and so on. When you trawl, you do not target, and then you have a huge cohort. If, in that cohort, you have over-representation, without even thinking about it, you have then enacted a level of discrimination, because of the trawling nature of this approach. If this approach applied to everybody on benefits, that would also be slightly questionable, because you are applying a different level of privacy to people who get an award from the DWP versus people who do not. If it applied to the whole country, I suppose that would be fairer in one respect, but it would also be a breach of everyone’s privacy, which goes to another question. In terms of this measure being important for Government revenue, the amount lost to the tax gap is more than four times more—we are talking about £9.1 billion, but the tax gap is over £39 billion. You would recover more money if you subjected the whole country to this measure, but I would suggest that the reason you do not subject the whole country to it is that there would be outrage, because people would find their rights to privacy being completely abused. Applying this measure in these targeted ways suggests a level of, “Well, these are people who perhaps have less rights to privacy than the general population.” If you are happy to have your bank account monitored in this way, fine, but you have not suggested that this should apply to the general population. You have suggested that it should apply to a population who receive benefits, and within that population there is an over-representation of disabled people, who are already exhaustively monitored, reviewed and tested and having to provide proof, whether that is for a blue badge, personal independence payment, ESA, universal credit or a concessionary pass on public transport. The life of a disabled person is to be constantly tested and examined and having to produce proof, and this is another step in that. That is why this is germane to the United Nations report on the convention on the rights of persons with disabilities. We have continued down the road of removing rights, not respecting them, and of subjecting disabled people to greater scrutiny, greater surveillance and greater tests of their basic rights to be a citizen of this country. It is really quite distressing for disabled people to be in this position. Not only have we had two really damning reports from the United Nations, but the new Government is actually adopting old policies of the previous Government and continuing on that road. The level of anger and distress in the disabled community is absolutely enormous. It is really difficult to explain to people that this is not an obvious attack, or one motivated by ableist assumptions about how disabled people run their lives or whether they are more or less honest, or more or less genuine, than people who are not disabled. It is really hard going for us—I have to tell you that. Disabled people in Britain have had a decade and a half of being the scapegoat of this country, and it has to stop. This measure is actually making it worse, as opposed to stopping that scapegoating. Geoff Fimister: I just want to add something to a point that Rick made. We both made the point that the discriminatory aspect relating to disabled people arises, in the immediate sense, from the fact that these means-tested benefits are primarily in scope at the moment, and disabled people are disproportionately likely to be on low incomes. It is worth adding that if this measure were to be extended at a future stage to a wider range of benefits, potentially bringing disability benefits into scope, that would be even more sharp discrimination against disabled people. They are not theoretical points that Rick has been making—there is a really raw feeling among disabled people that they are being targeted. In the context of quite a lot of negative media publicity around the interface between employment and unemployment among disabled people, there is an unpleasant atmosphere for disabled people. That is certainly the feedback that we are getting.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Just for clarification, is there an independent oversight mechanism in place for the use of those powers? Richard Las: I do not know, if I am honest, whether there is. I can look that up for you.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q We are looking to set a limit so the DWP would be able to deduct a maximum of 40% of an individual’s total capital as a lump sum. Would that satisfy you, or would you like us to look at that further? Eric Leenders: We would like to consider a specific de minimis. There are probably two approaches: an absolute amount or a relative amount, dependent on the individual’s essential expenditure—not their lifestyle expenditure. That is why we feel that the standard financial statement would be a useful tool.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q Thank you for joining us. I have a couple of initial questions. You have neatly set out your position that there is no circumstance in which you would support the eligibility verification measure. I was interested when you said there are no other laws like this in the country. We heard from HMRC today about its ability to receive bulk data with regard to every interest-bearing bank account in the country, and it does that on a regular basis. How do you consider this power to be different from that one? Jasleen Chaggar: What is really important about the Bill is the conflation of fraud and error. It is not just people suspected of serious crime, or even low-level crime, who are pulled into the net of surveillance. It is also people who, while navigating the complexities of the benefits system, may have found themselves on the wrong side of making a benefits claim and made a mistake. It also involves DWP’s own errors, which make up one in 10 errors. What is critical when we are thinking about the Bill is that it is suspicionless surveillance that applies to everyone.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

  More

  Q I have one follow-up question to each of you separately, if that is okay. Joshua, you mentioned the challenge that we have at the moment in detecting capital fraud and our reliance on somebody’s word as the only real measure that we have in place to determine that. If we were not to pursue EVM, is there another way that we could assure ourselves, beyond just taking the word of a potential claimant that they do not have more than, for instance, £16,000 in their account? Joshua Reddaway: Is there an alternative? I am aware that DWP is thinking about open banking as an alternative, but that, of course, would have wider implications and at the moment is on a voluntary basis. You have got that. I honestly think that it fundamentally comes down to this: if you want to be able to detect, and if Parliament has set an eligibility criterion of capital as part of universal credit and some other benefits, DWP can either use that as a kind of symbolic deterrent so that you can opt out by owning up that you have that capital—that has a use—or if you want it to actually be enforced, you have to provide DWP with a tool that goes a bit further than just asking. There are various ways that you can get data matching from various different partners. This is the one that the Government have come up with.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (First sitting) · Hansard source

  More

  Q Alex, I have a final question regarding what you said earlier about the level of fraud you have seen remaining fairly static but you have increased your prevention measures. Which of the new measures you have stepped up have been particularly effective? Alex Rothwell: Data analysis has been particularly effective, as has getting better at recording and reporting—for example, we now have a ubiquitous case recording system that exists across the national health service. The greatest value we have seen so far has been in improved data analysis on large datasets that exist on, for example, national contracting. That is where the value lies in future.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (First sitting) · Hansard source

  More

  Q Thank you very much for joining us today. I want to ask Dr Kassem a question, just for my own understanding. We have talked a lot about the definition of fraud and error and the Department’s approach to them. On the DWP side, to my knowledge, we are not planning to change the definitions of those within the scope of the Bill, but, clearly, we are taking new powers to enforce against them. Just out of interest, is there an academically accepted definition of fraud versus error that people work to, or is it ultimately a question of judgment? Dr Kassem: There are lots of definitions talking about fraud, including lies, cheating and misrepresentation for personal gain, but my point is that personal gain can be financial or non-financial. The Bill specifically mentions financial gain, but what would you do if you had a staff member working for a public authority who, for example, allowed unauthorised access or shared information out of revenge? There is no financial gain in that case. Would you treat that as fraud?

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (First sitting) · Hansard source

  More

  Q On your point about scope and the level of intrusion associated with the eligibility verification measure, you said you would like to see the power restricted to the most serious investigations. From our perspective, that would run contrary to what we are trying to achieve in capturing data that enables us to identify those who we had no idea were committing fraud or in receipt of an overpayment, albeit unwittingly. Is there another way you think we could achieve this? Helena Wood: That is a very good question. It goes back to the balance between individual rights to privacy and society’s rights as a whole. Only you can make the decision about where that balance falls. Going back to the previous question, I would like to see built into the oversight of the use of the power a specific requirement for the independent reviewer to look at instances of collateral intrusion and where mistakes have been made, and to report on those to Parliament. If we can build that into the code of practice—forgive me for keeping on going back to that code, but I think a lot of the use of this power hinges on how it will be used in practice and by whom. We need to build some significant guardrails against that. The second point I would make is that to my knowledge, this is an unprecedented power internationally, so how can we be sure it is going to be effective in practice? We know, for example, that individuals rarely have one bank account in one institution any more. In fact, numerous pieces of research—forgive me; I do not have the figures in my head, but I can refer those back to the Committee—show that individuals now have masses of bank accounts across five, six, seven and up to 10 or 20 institutions. By targeting one institution, are you really going to get a full picture anyway? If this is to be proportionate, we have to be clear that intrusion is proportionate and is going to be effective in practice. I am yet to see the evidence that it is, if it is used in a scattergun way. That is why it would be great to build into the code of practice something much more targeted around risk. For example, high-risk postcodes coming through in intelligence around organised crime attacks on the benefits system might be one way to look at this.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (First sitting) · Hansard source

  More

  Q Part of the reason that we do not have a specific intent to look at organised crime is that it makes up less than 10% of the fraud that we see in the Department—certainly of the overall fraud and error figures. I am reflecting on your comments about balance, but I am then hearing the questions about the efficacy of going to look directly into only one financial institution’s accounts. My concern is about broadening the scope. We have taken significant steps, when set against previous proposals in this area, to narrow the scope of the Bill. For instance, we are initially looking only at the three benefits where we see the highest levels of fraud and error. Universal credit is obviously principal among those. Does the work that we have done to narrow the scope reassure you at all when you look at the Bill—for example, the removal of the state pension and the restriction to only one financial institution? Clearly, without that, we would have to look at every single bank account in the country in detail and investigate why every single person in the country has £16,000, if we are unable to see across the full range of bank accounts that they have. Helena Wood: Absolutely, and I will answer that question in two parts. If we compare this Bill with the predecessor Bill that was put forward by the previous Government, the concerns have been listened to. There is much more significant oversight and much more limited scope. If we look at that in comparison with the predecessor Bill, that is absolutely true. On the second part of your question, you make a very good point that this is not always organised crime. I would build on the point made by my predecessors in giving evidence that this is absolutely what we would refer to as a first-party fraud-driven approach. At Cifas, we run a fraud behaviours survey every year, questioning individuals about their general attitudes to fraud—individual-level fraud—and we see those numbers ticking up year on year about what individuals deem acceptable. Your point is well made and fully made about the rising levels of first-party fraud. We do have to look at it as both a first-party fraud and an organised fraud response.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (First sitting) · Hansard source

  More

  Q I will ask one more question about the systems that we have in place. What do you perceive as the principal weaknesses in the DWP’s current powers to detect fraud? Helena Wood: A really good point was made, and others who follow me in this Committee’s evidence sessions will make it as well: fraudsters rarely simply defraud the public sector or the private sector. It is often the case that those with a propensity towards fraud will look at any channel through which they can gain financial benefits. This is very much a narrow-facing Bill, but we have to look at it in its broader context. I would question whether DWP could be doing more to share information with the private sector, using existing powers to do so. There are plenty of voluntary information and data-sharing schemes available to which DWP is not plugged in. It would complement this particular power to be able to layer the data picture and the intelligence picture, and not just look at this single piece of information in isolation. There will be a number of data points across the private sector that you could gain through voluntary data-sharing schemes that DWP is currently not engaging with.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (First sitting) · Hansard source

  More

  Q I asked this question of the first panel, but I am interested, both in broad terms and specifically within the parameters of your role in the NHS, in whether you have seen changing attitudes to fraud in recent years. Obviously there are various public attitude surveys that would indicate that that is the case, but has there been an increasing prevalence of fraud that the NHS has had to contend with, and do you have any comments on general changes in attitudes? Alex Rothwell: I certainly echo your thoughts in terms of attitude. We have seen that expressed in a number of different ways through surveys and transparency—the international transparency index, for example. In terms of statistics, we have seen our fraud prevalence rate remain fairly steady over the last five to seven years, but it is a complex picture because I think that we have been increasing our fraud protection measures as well. What we have seen across the board are bitter pay disputes and a sense that contracts do not pay enough. We have extensive provider assurance programmes that are recovering funds through what we classify as error. I do not see any change in that climate necessarily. Opportunities to strengthen prevention, for us, are the most important factor to influence people’s decision making before they commit fraud. So it is a huge concern to me, but not necessarily in terms of statistics. Kristin Jones: During my career, I have seen sentences for fraud increase dramatically and that sends a clear message but, over my career, instead of only a few people being exposed to fraud, when you answer your telephone, there is a good chance you have a scammer at the other end; it could happen once a week, if not several times a day. If you are being targeted, it could be every mealtime, with the scammer hoping that while you are distracted you will fall for some con. The worry is that the public are exposed so much to fraud that its seriousness gets watered down in their mind. You have these forums where you can recommend how to claim various things from the Government and how to hit sweet spots to get that benefit or grant. So it has changed and perhaps people are not as shocked by fraud as they used to be.