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Page 1: Interim workflow routing solution for visitor, short-term student … · 2 days ago · Version 1.0 . Page 2 of 28 Published for Home Office staff on 12 August 2020 ... An interim

Page 1 of 28 Published for Home Office staff on 12 August 2020

Interim workflow routing solution for visitor, short-term student and overseas domestic worker applications

Version 1.0

WrightA3
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Contents

Contents ..................................................................................................................... 2

About this guidance .................................................................................................... 3

Contacts ................................................................................................................. 3

Publication .............................................................................................................. 3

Changes from last version of this guidance ............................................................ 4

New interim approach to streaming and workflow routing .......................................... 5

Suspension of streaming tool and associated risk classifications .............................. 6

Complexity ................................................................................................................. 8

Four step workflow routing process ............................................................................ 9

Step 1: Bulk tables .................................................................................................. 9

Step 2: Direct routing .............................................................................................. 9

Step 3: Person-centric attributes............................................................................. 9

Step 4: Evidence based risk and harm profiles ....................................................... 9

Step process flow diagram: .................................................................................. 11

Person-centric attribute framework........................................................................... 13

Applications where person-centric attributes will not be used ............................... 13

For allocation directly as complex: ........................................................................ 13

For allocation directly as non-complex: ................................................................. 14

Separate categories in the Immigration Rules to be allocated directly as non-complex and not included in the Application Complexity Routing System (ACRS).............................................................................................................................. 14

Person-centric attributes .......................................................................................... 15

Decision-making ....................................................................................................... 17

Training .................................................................................................................... 19

Enrichment framework ............................................................................................. 20

Decision assurance review ....................................................................................... 23

Baseline reviews ................................................................................................... 23

Tactical operational reviews ................................................................................. 23

Interim decision assurance framework ................................................................. 25

ECM approval ....................................................................................................... 25

Full Quality Assurance (FQA) review .................................................................... 26

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About this guidance This guidance sets out the arrangements which all Visas and Citizenship Decision-Making Centres (DMCs) must follow from 7 August 2020 when routing and assessing applications from those customers who are applying from overseas as a visitor, short-term student or overseas domestic worker under the relevant Immigration Rules. The guidance proposes a new interim process which removes the previous reliance on nationality and all Global Visa Risk Streaming (GVRS) data in the streaming tool, which is currently suspended. We will be testing the new interim process, using feedback mechanisms and Management Information (MI) data capture. This will evaluate the effectiveness of the workflow routing, decision-making, enrichment and assurance proposals without the use of the streaming tool and its associated risk classifications around Red, Amber and Green cases. Where any substantive changes are made to the interim process as a result of this evaluation, updated guidance will be published for DMCs. All decision-making proposed in this guidance must initially be undertaken by Executive Officer Decision-Makers (EODMs). Administrative Officer Decision Makers (AODMs) must not be allocated any cases to make decisions under this new interim process until they receive re-training and we are satisfied, under our ongoing evaluation of the process, that it is appropriate for them to do so. DMCs can under this interim process use administrative officer graded staff to carry out administrative activities in relation to the routing or allocation of cases.

Contacts

If you have any questions about the guidance and your line manager cannot help you or you think that the guidance has factual errors then email Visas and Citizenship’s Central Operations Team at UKVI Central Operations Team. If you notice any formatting errors in this guidance (broken links, spelling mistakes and so on) or have any comments about the layout or navigability of the guidance then you can email the Guidance Rules and Forms team.

Publication

Below is information on when this version of the guidance was published:

• version 1.0

• published for Home Office staff on 12 August 2020

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Changes from last version of this guidance

This guidance replaces all guidance previously used by Visas and Citizenship Decision Making Centres in respect of streaming applications and use of the streaming tool in visitor and other short-term routes under the Immigration Rules. Related content Contents

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New interim approach to streaming and workflow routing This guidance sets out for all UKVI Visas and Citizenship Decision Making Centres (DMCs) an interim approach to streaming, enrichment and decision assurance. It covers arrangements for dealing with applications made in the visitor, short-term student and overseas domestic worker routes within the Immigration Rules. It contains some changes in the way that DMCs are required to route, enrich, process and assure applications. The terminology around streaming will also change and the previous Red, Amber, Green (RAG) rating process will be replaced by routing applications based on their complexity.

The interim approach removes the reliance on nationality and all Global Visa Risk Streaming (GVRS) data and replaces it with a model which applies, for the overwhelming majority of applications, consistent person-centric attributes to determine the workflow routing. This will enable DMCs to route work to the appropriate grade of decision-maker based on likely complexity of the application. The process, as well as each attribute, has been considered for impacts on characteristics such as race, sex or age that are protected by the Equality Act 2010. The Equality Impact Assessment (EIA) assures that the system does not directly discriminate against any groups protected by the Equality Act 2010 and that any indirect impact is justified in pursuit of the legitimate aim of ensuring the overall integrity of the immigration system. Visas and Citizenship staff are required to continually review the impact of our policies and processes, and if any equality or discrimination issues are identified at a later stage, these should be raised and flagged to the Central Operations Team (COT) for further consideration. Details of the person-centric attributes are set out in the Person-centric attribute framework. Decision-makers at all grades must continue to assess each application on its individual merits against the Immigration Rules. Each application will continue to be decided based on the information provided by the customer and any other relevant factors at the date of decision. Decision-makers at all grades must consider the suitability and eligibility requirements of the rules and must be satisfied that they are met in order to issue a visa. Administrative Officer Decision-Makers (AODM) grade staff will only be able to issue visas if they are satisfied the Immigration Rules are met and they will not be able to refuse applications. Where an AODM considers the rules are not met, they must re-route the application to an EODM for further consideration. Further training, guidance and ongoing communications will be made available to DMCs about the new interim process. Related content Contents

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Suspension of streaming tool and associated risk classifications From 7 August 2020, DMCs must no longer classify applications as Red, Amber Green (RAG) where these classifications relate to any aspect of the streaming tool or GVRS data. From this date, no applications should be streamed through the RAG process, and risk classifications of this nature should play no part in the end to end process. Applications received by DMCs before 7 August 2020 where a decision has not yet been served must also be considered under the new complexity routing process and any previous streaming outcome set aside. All DMCs must deactivate the current streaming tool. There are 2 steps to be followed in deactivating the current tool:

1. The MS Access Databases must be removed from their current location in the DMC Proviso drive to an archive folder in the DMC S: drive. This will break the link between the desktop streaming tool application and the MS Access Databases.

2. Each computer in the DMC should have the desktop application deleted. Any emails retained by staff which were issued by local streaming leads containing the desktop application should also be deleted.

All DMCs must also amend their Proviso case-working systems which will ensure that each application will default to “Green” until this field can be amended or removed from Proviso. This means that all applications will be shown as having a ‘Green’ RAG outcome on the main page of Proviso, but this does not indicate either a low risk application (in risk terminology) or a non-complex outcome, and decision-makers should not take any account of it. DMCs must make this change in Proviso by selecting Administration - System Defaults - Default Risk Types (see Figure 1 below). This change can only be performed by a user with the appropriate administrative privileges, normally an entry clearance manager at HEO grade or above.

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Figure 1

Related content Contents

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Complexity DMCs processing applications made by visitors, short-term students or overseas domestic workers must replace the existing RAG system with 2 workflow routes based on complexity: non-complex or complex. Complexity is determined by reference to a series of person-centric (application specific) attributes that would, amongst other factors, ordinarily enable a decision-maker to assess whether an application meets the requirements of the Immigration Rules. For example, where there is an indication that the Immigration Rules have been previously met and complied with, a decision-maker might be able to more readily assess the customer’s intention to leave the UK and that the current application meets that element of the relevant Immigration Rules regarding an intention to leave the UK at the end of their stay. These applications would normally be processed by an Administrative Officer Decision Maker (AODM), although where a DMC has no AODMs then an Executive Officer Decision-Maker (EODM) can also make a decision. An AODM will be able to assess only non-complex applications but an EODM can assess applications of any complexity outcomes. Related content Contents

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Four step workflow routing process An interim workflow routing solution has been designed, Application Complexity Routing Solution (ACRS). All DMCs must ensure that workflow is routed using this new 4 step workflow routing process when applying the new complexity approach.

Step 1: Bulk tables

DMCs must identify applications with known fraud or harm factors by manually checking against a table listing those factors. These tables must not include nationality or other protected characteristics including age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race (including colour, ethnic or national origins), religion or belief, sex and sexual orientation. These tables can, for example, contain credit card details, email addresses and telephone numbers identified as having been used in previous fraudulent applications. If there is a match against data held in a bulk table, the application should be treated as complex and should go directly to Step 4. The UKVI Central Operations Team will review all bulk data elements to ensure they are compliant with our obligations under the Equality Act 2010 and DMCs must not operate any bulk table data until that review has taken place. A centralised bulk data table will be created for use by all DMCs.

Step 2: Direct routing

Certain distinct application cohorts have been identified as involving lower or higher levels of complexity. These will be allocated to either an Administrative Officer Decision-Maker (AODM) or Executive Office Decision-Maker (EODM), as appropriate, and person-centric attributes (Step 3) will not be used, but the application should still be considered under Step 4. If the application does not meet the category or sponsorship cohort, it will proceed to Step 3. Further details of these cohorts are set out below.

Step 3: Person-centric attributes

There are 4 different person-centric attributes which will usually need to be applied to most applications by DMC staff.

Where at least three of the four attributes are met, an application must be recorded as non-complex by the DMC. If less than three of the four attributes are met it must be identified as complex. All applications will still proceed to Step 4.

Step 4: Evidence based risk and harm profiles

DMCs can apply their own profiles or those provided by Immigration Intelligence teams to determine whether there should be any further changes to the complexity rating after Steps 1 to 3. Profiles must be supported by statistical data and/or intelligence. Profiles must not include any data which contains nationality indicators. They must be supported by an EIA completed by the profile originator before a DMC

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can use them in any aspect of the decision-making process. Where there is a potential indirect impact identified based on protected characteristics, the EIA must demonstrate that use of the profile has a legitimate aim and is justified and proportionate. Any direct discrimination identified under the EIA will be unlawful unless an exemption applies. All applications will be considered under Step 4 even if they have already been identified as complex. This is to ensure the EODM is aware of the entire step process as this may inform their decision to seek additional enrichment as part of their assessment.

Where an application matches a profile, it must be routed as complex even where it may have previously been identified as non-complex. Immigration Intelligence colleagues will be working closely with DMCs to review and refresh profiles to ensure they are compliant with equalities criteria. The UKVI Central Operations Team will review all profiles to ensure they comply with our legal obligations. For example:

• at Step 1 of the workflow routing process an application does not match the bulk table and Step 2 does not identify a directing routing on category or sponsorship scheme - the application proceeds to Step 3 where it meets 3 of the 4 person-centric attributes and is identified as non-complex - at Step 4 it matches a profile for customers travelling to the UK to attend a particular sporting event and so is identified as complex and allocated to an EODM

• the profile for a sporting event has been provided to UKVI by Immigration Intelligence and is not based on nationality or point of application data and is the subject of an Equality Impact Assessment

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Step process flow diagram:

Figure 2

The routing process will define whether applications are complex or non-complex and DMCs must ensure that they classify applications in the Proviso ‘Spare’ Field as complex or non-complex. The agreed codes to be used are CX (Complex), NCX (non-complex) and RCX (re-routed from non-complex to complex). Codes can be used with other agreed Management Information (MI) codes, but the complexity code must appear first in the data string. MI can be pulled using the Business Activity Monitoring overview or Proviso ‘Event Note Search’. For example, in Figure 3, an application has been routed as non-complex, but the customer has also purchased the Keep My Passport While Applying service, the spare field code will show NCX CPP.

Move to Step 4

RISK PROFILE

Does the application data match a

risk profile?

Paste final complexity outcome to

Proviso event note

Has the applicant declared

criminality or is applying in the ODW

route or a member of a trusted

sponsor scheme?

If YES, move to Step 4

If NO, move to Step 3

PERSON CENTRIC ATTRIBUTES

Complete Person Centric Attribute

questions

STEP 1

STEP 4

Does the application data match a

bulk table?

If YES, move to Step 4

If NO, move to Step 2

Application Complexity Routing Solution (ARCS) STEP PROCESS

STEP 2

STEP 3

BULK TABLES

STEP 2 DIRECT ROUTING

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Figure 3

DMCs are already required to use the complex/non-complex definitions and corresponding deferral event notes in Proviso to identify where a case is unlikely to be resolved within the published service standard due to factors outside of their control, for example, referral to another unit. It is important that DMC staff do not use the ‘Defer Complex’ events in Proviso to indicate routing complexity and only use the ‘Spare’ Field codes as set out above. Related content Contents

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Person-centric attribute framework The aim of these attributes is to indicate to DMCs the likely complexity of an application and, based on this, allocate to the appropriate decision-maker for assessment. The routing process based on complexity must not be used to direct the outcome of an application. Once an application is assigned to a decision-maker, each application will be assessed on its individual merits by that decision-maker. Complex applications will be allocated to an Executive Officer Decision-Maker (EODM) who is trained to assess them. Non-complex applications may be allocated to an Administrative Officer Decision-Maker (AODM). In DMCs where there are no AODMs, or AODMs have yet to receive appropriate training in the interim process, EODMs are also able to make decisions on non-complex applications. AODMs must not assess complex applications. In order to identify non-complex applications, questions have been created which are linked to positive attributes. These positive attributes are identifiable from the customer’s answers on the visa application form (VAF). Although we would normally expect applications with positive attributes to be non- complex, it is possible that they could be complex, and will need to be dealt with at the appropriate grade. For example, an application is routed as non-complex as at least three of the four, person centric attributes are met including travel and compliance. During the assessment it is noted that, whilst the customer left the UK within the validity of their visit visa, they in fact stayed for a full 6 months. This might indicate that the customer is effectively living in the UK and their statement about employment is not credible, but this will need a more comprehensive assessment.

Applications where person-centric attributes will not be used

Certain distinct application cohorts have been identified as involving lower or higher complexity. These will be allocated to the appropriate grade of decision maker and person-centric attributes will not be used.

For allocation directly as complex:

• all applications made by overseas domestic workers which are complex due to the consideration of safeguarding requirements

• applications where the customer has answered yes to any criminality or security questions.

These applications must still be checked against the Evidenced based risk and harm profile criteria at Step 4 by DMCs.

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For allocation directly as non-complex:

• customers applying through a UKVI preferred partnership or trusted sponsor schemes – details of companies or organisations who are part of these schemes will be held locally at DMC level

These applications must still be checked against the Evidenced based risk and harm profile criteria at Step 4

Separate categories in the Immigration Rules to be allocated directly as non-complex and not included in the Application Complexity Routing System (ACRS)

• all customers applying through the Approved Destination Status (ADS) agreement - applications submitted in the ADS route are non-complex as a result of the requirements of the route and checks made in advance of the application by the operators

• customers who are eligible to travel to the UK using the Electronic Visa Waiver (EVW) process, but have chosen to apply for a visa instead - applications from these customers are non-complex, as the creation of the EVW scheme demonstrates that these individuals can travel to the United Kingdom without entry clearance with no need for any evidence to be submitted

Related content Contents Approved Destination Status (ADS) agreement Electronic Visa Waiver (EVW)

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Person-centric attributes The new interim process has identified 4 attributes relating to individuals which will be considered to identify the potential complexity of an application. Negative attributes have not been included; the outcome of an attribute is either positive or neutral. Responses to questions which indicate complexity, for example a declaration of criminality, are not included. Any application with such a declaration that indicates complexity would be routed for EODM assessment. If at least three of the four positive attributes are indicated on the Visa Application Form (VAF), the application is likely to be sufficiently straightforward so that it can be routed as non-complex, subject to the outcome of Step 4:

• previous compliant travel to or current residency in New Zealand, Australia, Canada, United States of America, United Kingdom, Ireland, Schengen or EEA countries during the 5 years prior to application – this is relevant to the customer’s own immigration history

• total cost of visit equates to no more than 10% of declared income from all sources – this includes those being sponsored by a spouse, other family members or other sponsor if the customer is unemployed or a student - in this case, income will be assessed in line with that of the financial sponsor as declared on the VAF

• the customer or their financial sponsor has been in continuous employment or self-employment for the last 2 years - a customer’s income and financial circumstances, or that of their financial sponsor, are relevant to the affordability of the trip

• less than 1 month stay intended in the UK - the duration of stay is relevant to the customer’s financial circumstances or that of their financial sponsor for the affordability of the trip

In the case of minor children travelling in a family group, we should reasonably accept the outcome of the parent’s attributes as being relevant to the child. In these cases, the minor children should follow the complexity outcome of their parents. If the customer declares on the VAF that they are unemployed or supported by another person, the VAF does not automatically generate a question about duration of employment, which means that the income questions may also be incomplete. In these cases, the attribute response will be ‘no’ which is likely to route the application as complex, because the decision-maker will need to analyse financial support. Each of the 4 attributes has been considered in an EIA. It is important that DMCs only use the agreed attributes and do not include any other attributes when assessing an application for the purposes of workflow routing – any other potential

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additional attributes will require a full EIA before they can be considered for inclusion. However, DMCs are encouraged to feedback views on potential attributes for consideration as part of the ongoing evaluation of this interim process or whether any of the above attributes would benefit from clarification or amendment. Related content Contents

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Decision-making DMCs must maintain a clear distinction between workflow routing and decision-making and ensure that the routing of a case does not drive the decision. Workflow routing should only direct the route of the application based primarily on the outcome of the person-centric attributes. Administrative Officer Decision-Makers (AODMs) must assess each application against the relevant Immigration Rules and guidance for visitor and short-term student applications, and each decision must be based on the information provided by the customer and any other relevant factors at the date of decision. If the AODM is satisfied that the application meets the relevant requirements of the rules, the application can be issued once the UKVI Operating Mandate checks have been completed. The Visit guidance can be found on GOV.UK. The Short-term student guidance can be found on GOV.UK. Applications that are complex may also contain other indicators which are not present in the rules, such as compelling and compassionate circumstances, which must be taken into account. Assessing why a customer has not travelled and complied before, or why a customer has a negative immigration history, requires a more considered view, which weighs a wider range of both positive and negative factors. These decisions will be made by Executive Officer Decision-Makers (EODMs) who have been appropriately trained. Furthermore, applications which are subject to an UKVI Operating Mandate match, may also contain complex elements which require further analysis. AODMs should route such applications through to EODMs.

AODMs must not refuse applications, or draft refusal notices for EODMs. These are skills for EODMs, who receive further training and guidance on considering refusals and the drafting of refusal notices.

AODMs must also re-route a non-complex application to an EODM if:

• no evidence is presented with the application

• they are unable to assess the application in full because, while some evidence has been submitted to enable a consideration to take place, some information is missing

• the application includes evidence which, following consideration, indicates irregularities, and the decision-maker considers that further analysis or checks are required to confirm the veracity

• a previous application has been refused for the use of forged evidence or deception

• they have any other doubts about the evidence presented

• they have any other concerns that the rules might not be met

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When AODMs re-route an application to an EODM, they must complete a full case note explaining the reasons and defer the application in the Proviso system. The deferral event note will vary depending on local DMC practices, but this would normally be facilitated using the ‘Defer – Other’ event note, and the ‘Spare’ field code must be changed from ‘NCX’ to ‘RCX’ to aid workflow routing and MI counting for the number of cases which are being re-routed. EODMs will also assess each application against the rules and each application will be decided based on the information provided by the customer and any other relevant factors at the date of decision. There must be no presumption that an application will result in a particular outcome based on it being routed to or re-routed to an EODM. There is no bar to an EODM assessing an application that would normally be allocated as non-complex, for example where no AODMs are available at a DMC to assess all the applications routed to them. Related content Contents Visit Guidance Short-Term Student Guidance

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Training New training packages will be developed to provide additional guidance as a result of these changes. The Visits UK Training Team will lead on the development of these training packages which will be shared with overseas teams, and available for face to face or virtual delivery. Training packages will include:

• Administrative Officer Decision-Maker (AODM) upskilling to refresh understanding of Appendix V of the Immigration Rules, the department’s published Visit guidance, credibility assessing ‘in the round’ and the common indicators in differentiating complexity outcomes - the existing AODM foundation training course will be updated to incorporate the relevant areas covered in this guidance and be available in due course

• Confirmation bias training for all decision-makers to refresh awareness of equality discrimination legislation - this training course is being prioritised and will be ready by week commencing 10 August 2020

• Fraud awareness training for all decision-makers to aid the identification of fraudulent documents and harm indicators as well as cases routed as non-complex which may be fraudulent - this training course is being prioritised and will be ready shortly

AODMs will not be used to assess non-complex applications until they have taken the updated AODM foundation training, Confirmation bias and Fraud awareness course and met the required standard. Related content Contents

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Enrichment framework From 7 August 2020 an interim enrichment framework will also be introduced for DMCs operating the new interim approach on complexity that will not be based on nationality risk or any other protected characteristic. This process also excludes the use of Red, Amber and Green (RAG) risk ratings and global visa risk (GVRS) data. All enrichment will take place after the routing process using the ACRS and the routing process will not direct any enrichment. The interim process will be based solely on the circumstances of the application. The interim framework will have 2 levels of checks:

• UKVI Operating Mandate (OM) checks

• Optional checks Enrichment checks provide the decision-maker with further information in addition to that provided with the initial supporting evidence. Checks can provide new information but can also confirm the veracity of declared information. Under the new interim process, DMCs must not direct any front-end checks at the application routing stage. Once an application has been assigned to a decision-maker based on complexity, the decision-maker must initially determine whether to issue or refuse the application in accordance with the Immigration Rules. In some cases, the decision-maker may require further information in order to reach a judgement on whether, on the balance of probabilities, the application meets the relevant requirements of the Immigration Rules. Both Administrative Officer Decision-Makers (AODMs) and Executive Officer Decision-Makers (EODMs) can request additional checks and the requirement for any checks must be entirely on the merits of the individual application. All checks commissioned by decision-makers must be approved by an Entry-Clearance Manager (ECM) or Operations Manager (OM), justifying the requirement for a check and to ensure it is compliant with the requirements of the Equality Act 2010. Decision-makers may request enrichment checks where they are planning to issue an application, for example where a quick check might mitigate the absence of employment of financial evidence which would otherwise support an issue. Decision-makers should not request checks where there are sufficient grounds to refuse an application on the available evidence, unless the evidence provided indicates there are grounds to suspect fraudulent activity, for example, where it is obvious that a bank statement has been altered on inspection. Whilst enrichment checks may help to mitigate against issues of possible non- compliance, they will not always negate it. Similarly, a decision to send a case for enrichment must not, of itself, influence the decision-making process. Decisions must be based on evidence, not the fact that enrichment has been required.

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________________________________________________________________ Official – Sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use only.

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The information on this page has been removed as it is restricted for internal Home Office use only. ___________________________________________________________________ Official – Sensitive: end of section Related content Contents Operating Mandate

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Decision assurance review From 7 August 2020 an interim assurance process will be introduced that will not be based on nationality risk or any other protected characteristic. This process also excludes the use of Red, Amber and Green (RAG) risk ratings and all GVRS data. The interim process will be based on the circumstances of the application. Where possible reviews should be undertaken on the same working day as the initial decision is made. In tandem with these changes we will work to a revised decision assurance framework. The framework will still include the requirement for baseline and tactical reviews.

Baseline reviews

Baseline reviews previously required reviews of red-rated issues and green-rated refusals. The requirement for reviews based on RAG ratings has been removed, but baseline reviews will continue.

One hundred percent of required checks must be completed daily. Reviewers will be allocated a random sample of 25% of all non-complex decisions and a minimum of 10% of complex decisions which must be reviewed daily. Where DMCs have the scope to increase the volumes of baseline reviews they are encouraged to do so. In view of the low volume of intake, DMCs may choose to undertake a higher percentage of baseline reviews during the first few weeks of implementation, which might negate the requirement for tactical reviews to be completed. The percentage of baseline reviews has been increased to provide additional mitigation of risk during the interim period. Baseline reviews must be randomly allocated and not focus on a nationality cohort or any other group which has protected characteristics. Baseline reviews can be found in Table 4: Interim Decision Assurance Framework.

Tactical operational reviews

Tactical operational reviews are undertaken to focus on a specific element of the decision-making process, for example endorsements, and/or improve decision quality, ensuring that the rules are being applied correctly and must be completed on 100% of cases until the Operations Manager (OM) is satisfied that this has met the required standard within the DMC.

When the OM is satisfied and can evidence that decisions are robust and appropriate, the Central Operations Team must be informed and any further checks on these cases can form part of the random sampling to ensure decision quality and integrity.

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Where this process identifies individual decision-makers as requiring development, the OM can remove the requirement for further checks from the tactical operational reviews ensuring that the DM receives the support required through the performance development processes. The increased percentage in required baseline reviews will capture a greater number of those reviews which would otherwise be defined in the tactical group. In view of this the volume of tactical reviews can be adjusted to offset those captured under baseline reviews provided the key driver for the tactical reviews is not compromised. In some DMCs, a higher percentage of baseline reviews might negate the requirement for tactical reviews altogether. The Entry Clearance Manager (ECM) approval process must be undertaken by an ECM. Full quality assurance reviews may be conducted by decision-maker peer groups. Those selected must be substantive in grade for at least 6 months, not subject to a Data Quality (DQ) improvement plan, have received mandatory training on assurance reviewing and have been recruited through open and transparent expression of interests. A standardised DQ Assurance Template will be created and must be used by all DMCs when completing a full quality assurance. Related content Contents

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Interim decision assurance framework

This updated framework must be used from 7 August 2020.

ECM approval

In these circumstances the decision-maker (DM) will be referring a case to the ECM for their approval on the proposed course of action. _____________________________________________________________ Official – Sensitive: start of section

The information on this page has been removed as it is restricted for internal Home Office use only.

Official – Sensitive: end of section

The ECM is not required to view any further documents or the Visa Application Form (VAF) as part of the approval process. The ECM should enter their notes in the ECM Approval box on Proviso (Figure 4), where this box is not available the ‘ECM Review Other option’ should be selected (Figure 5) and the narrative on the type of approval should be entered in the note window.

Figure 4

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Figure 5

In order to reduce operational impact, ECM approval should be completed on the same day as the referral for approval by the decision-maker to the ECM.

Full Quality Assurance (FQA) review

Reviewers undertaking FQA reviews will look at the decision itself and the quality of the justification of the course of action – the issue notes or refusal notice. The reviewer must review the full application after the DM has made the decision. _____________________________________________________________ Official – Sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use only. Official – Sensitive: end of section

The review of a refusal decision covers the following areas and the reviewer should enter their notes in the ECM Review box following the DQ Assurance Template:

Table 4

Baseline Reviews Issue Refusal Comments Minimum reviewer level

_____________________________________________________________ Official – Sensitive: start of section

Restricted information removed for internal Home Office use only.

Restricted information removed for internal Home Office use only.

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Table 4

Baseline Reviews Issue Refusal Comments Minimum reviewer level

Official – Sensitive: end of section

GGFR Application of para. 320 2(b)(c)(d); 7 (a)(b); 11; 18A; 18B; 19 and App. V 3.6

ECM Approval

ECM Approval

To ensure that these are being applied correctly. The ‘fatal error’ and standard wordings for these paragraphs negate requirement for full ECM Review.

ECM

New DM’s or one on a Performance plan

Full Review

Full Review

Length of oversight depends on performance of the DM. This covers LTECO, STECO (FPO/FTA) and all other DMs dealing with complex or non-complex work. Full review required to support further actions this can progress to ECM approval /dip sampling to reflect performance change.

Peer and/or ECM

Applications where validity has been restricted by a DM

ECM Approval

NA To ensure that the restriction is appropriate, and the customer notified accordingly as outlined in the Visitor policy guidance.

ECM

Unaccompanied minors ECM Approval

NA Safeguarding assurance – the starting point is for ECM Approval. DMC can evidence to Central Operations why no ECM approval is required to deviate from this or why a full ECM review is required - sign off from the centre required.

ECM

Quality assurance file sampling of non-complex applications

Full Review (25%)

NA This should cover all applications a DM assesses and may take place over different days. Applications to be selected randomly.

Peer

Quality assurance file sampling of complex applications

Full review (10%)

Full Review (10%)

This should cover all applications a DM assesses and may take place over different days. Applications to be selected randomly.

Peer

Super Priority Full Review

Full Review

Due to the quick turnaround time and the expense of this route a full ECM review is required to ensure the quality

ECM

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Table 4

Baseline Reviews Issue Refusal Comments Minimum reviewer level

of the decision and refusal notice.

Previous application refusal within the last 3 years

ECM Approval

ECM Approval

To ensure that a balanced and proportionate decision has been reached and any repeat refusal is justified

Peer

High Profile Case as referred to in OPI 840

ECM Approval

Full Review

If a DM receives an application which they believe may be high profile they must firstly seek advice from their ECM who must also alert the Operations Manager.

ECM

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