UKVI Front End Services Under Scrutiny
An Inspection of UK Visa and Immigration Front End Services (August 2020 – June 2021) was published on 25 November 2021 by David Neal, the Independent Chief Inspector of Borders and Immigration. The Inspection was presented to Parliament pursuant to Section 50(2) of the Borders Act 2007. All Inspection Reports are available to access: here.
Purpose of the UK Visas & Immigration Inspection
The purpose is set out as follows:
“In the ICIBI Inspection Plan 2020-21, the Chief Inspector indicated an intention to carry out an inspection of UK Visa and Immigration (UKVI) Front End Services (FES), to examine the efficiency, effectiveness and consistency of FES delivered by UKVI and through its commercial partners (CPs), particularly its streamlined and digitised UK Visa and Citizenship Application Service (UKVCAS) in-country and Visa Application Centres (VACs) overseas. This inspection focused on:
- guidance, instructions and assistance provided by the Home Office and CPs to assist individuals making applications
- the availability of free appointments
- the ‘customer experience’ when engaging with application and booking processes, support services, and when attending appointments at a UK or overseas application centre, including ‘Added Value Services’ (AVS)
- resourcing and training for staff within the Home Office and CPs
- quality assurance, mechanisms for feedback and the handling of customer complaints
- the consideration of vulnerable customers when designing and delivering FES in the UK and overseas
- continuous improvement, including progress in implementing recommendations from previous ICIBI inspection reports”.
As practitioners we have seen many changes in the process of submitting an application whether in or out of the country and changes to the Front End Services including the appointment process and Added Value Services.
Availability of Free Appointments
As practitioners we are often frustrated by not always being able to secure a free appointment for our clients, particularly given the costs already incurred in submitting an application. Providing biometrics is an essential and often unavoidable part of the process. Additionally the lack of transparency on appointment availability and cost can present an additional hurdle where an outcome is, for example, particularly time sensitive. Before the introduction of UKVCAS in November 2018 and the Service and Support Centres (SSCs) in March 2019, it was possible for biometrics to be provided at Home Office-designated Post Offices located throughout the UK, or alternatively at Premium Service Centres, where a fee was chargeable.
The Inspection Report acknowledges the difficulty in securing a free appointment, despite promises that have been made:
“Despite Home Office attempts to ensure that free appointments are available to all, it was clear from the CfE that this has not yet been achieved. This limited availability sometimes led to customers having to opt for appointments at a cost, removing the element of choice and imposing a financial burden on them.
Respondents to the CfE described the existing system to obtain free appointments as being difficult to navigate, busy, limited and available only at a small number of sites. UK Visa and Citizenship Application Service (UKVCAS) provided free appointments at only 6 ‘core’ service points or 7 Service and Support Centres (SSCs). Respondents felt let down by the shift from free appointment availability at a nationwide network of Post Offices to only 6 ‘core’ service points. Additionally, when a Member of Parliament raised concerns about a “significant shortage of free appointments”, the response by UK Visas and Immigration (UKVI) and CP Sopra Steria Limited (SSL) was “disappointing with no solution offered (by the CP) other than for customers to keep checking for availability”.
This is confirmed by the fact UKVCAS call centre agents commented that a common problem and source of enquiry is not being able to secure a free appointment. This is recognised by senior managers and the Home Office.
One of the examples given in the Inspection Report is a maximum of 35 calendar days wait for a free appointment in Birmingham in March 2020 compared to a waiting time of 2 days for a chargeable appointment. The Inspection reported that free appointments appeared to be released in ‘a random manner’. Stakeholders raised challenges around viewing free appointments on the website.
In assessing the impact of free appointment unavailability the Inspection Report reads:
“Inspectors observed that ‘free appointment availability’ was featured on the UKVCAS Risk Register. This specified a risk of customers being “unable to book and attend appointments due to unavailability of free appointments” and as a result, “limiting access to appointments to customers who can afford to pay” or “customers delaying their application to await free appointments”. The current likelihood and current impact on the Risk Register are rated as ‘very high’ and ‘major’.
Submissions received from service-users and stakeholders within the UK highlighted instances of customers having to opt for appointments at a cost due to a lack of free appointment availability. One legal stakeholder described an instance where a family of 4 incurred appointment fees of £796, and stated that this instance was representative of 95% of their clients who ended up paying for appointments due to the unavailability of free appointments or waited for weeks to attend one.”
The lack of transparency is a further identified issue:
“Customers also highlighted issues around a lack of transparency and flexibility within appointment booking systems. One described finding a free appointment on VFS’s system as “a lottery” and said that they had to check the website at various times during the night. Another described the booking system as “outdated” and raised difficulties resulting from only being able to see the next available date as opposed to being presented with a list to choose from”.
The Inspection Report concludes:
“Responses from the CfE indicated that the Access UK and GOV.UK websites were reasonably easy to use; however, some described the CP websites as being “frustrating”, “dated and clunky”, “full of glitches” and sometimes being “slow and non-responsive”. In addition, the websites suddenly “crash” or “time out” individuals which has led to problems with customers uploading documents. UKVI’s internal Customer Insight report, which was provided to inspectors, also echoed such views around websites lacking a user-friendly interface, and technical issues preventing them from uploading their own documents”.
Geographical location of service points
Applicants are often willing to travel to secure their appointment, but do question whether they should need to. The Inspection Report concludes:
“Customers have indicated that with the move from national Post Office provision to UKVCAS, with 6 core sites and 38 Enhanced service points across the whole country, customers may need to travel longer distances to access appointments, and for those who wish to access free appointments in some cases further so, with an example cited of someone from Bournemouth having to travel to Croydon. Concerns around geographical locations and accessibility were also evident in UKVI’s Customer Insight report, which identified a “recurring theme” where “customers felt that they were forced to travel long distances to attend their appointment”, both in the UK and overseas.”
Added Value Service (AVS)
Added Value Services (AVS) can include for example, scanning services and document checking.
The Inspection Report acknowledges that although these services are optional, many users reported feeling confused as to whether they should purchase a package:
“Staff working in UK diplomatic missions overseas have also expressed concern about the reputational impact of this “upselling” of AVS, particularly considering this may be the first interaction an individual has with the UK immigration system”.
The Inspectors were told there is certainly no ‘hard sell’ but customers and stakeholders did not agree:
“Inspectors were told in the responses to the CfE that, due to the complicated nature of the available guidance and the way these AVS are packaged on the website, some customers are uncertain as to whether they should purchase these services to ensure that they get the process right:
“It is unclear to the layperson whether buying added value services will influence how their application is viewed by UKVI […] unrepresented clients are not clear which services they are required to purchase, if any, in order to make their application valid […] and [this] has the potential to add additional financial burdens to people engaging in an already costly process.”
This was reinforced by the Law Society who stated that there is a:
“serious concern as individuals making visa applications may be particularly vulnerable due to the complexity of the immigration process and the importance of the issues at stake, and as a result, induced into paying more money than is necessary in an attempt to influence the success of their application. Whilst the commerciality of the companies providing FES [Front End Services] is recognised, vulnerability of applicants should not be exploited to garner profit.”
Resourcing, Training, Quality Assurance and Feedback
Although there is training guidance and there are assurance systems, the Inspection Report suggests that improvements should be made.
There remain some concerns, the Inspection Report concluding:
“The Home Office SSCs were seen in a very positive light by stakeholders and customers, with a high level of overall satisfaction with the services they provide to support vulnerable customers. Customers highlighted the ease of making SSC appointments, the well-informed and well-trained staff who interact with customers effectively, and the provision of the right advice to address the additional needs presented by this cohort of customers. However, geographical coverage of SSCs is a concern, with only 7 locations currently. Enhancing this coverage will improve accessibility for vulnerable customers”.
In conclusion the Inspection Report recommends:
- Review the existing Front End Services (FES) guidance on Access UK and GOV.UK and, building on stakeholder feedback;
- Regularly publish performance data on waiting times and the availability of free appointments;
- Work to enhance competency of the system for accessing and uploading supporting documents;
- Review communication with references to AVS;
- Undertake a review of training to staff;
- Ensure that data on customer feedback and company are consistently recorded;
- Complete the full post-implementation review of the FES programme as accepted in its response to the ICIBI published report on the Home Office’s Borders, Immigration and Citizenship Systems (BICS) policies and practices relating to charging and fees in April 2019; and
- Ensure that any outstanding reviews of the Equality Impact Assessments (EIAs) relating to the operation of FES are completed by December 2021 in accordance with current best practice advice from the Home Office’s PSED team. Ensure that compliance with PSED is a regular agenda item at CPs’ performance meetings going forward.
We await with interest which recommendations are acted upon and whether improvements to the system are seen.
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