We are unconvinced by the Department’s justification for why the Department cannot take ownership of remaining HSS claims. If the Department accepts the need for separation between initial decision- making and appeals processes, it is entirely within its power to establish a new, distinct and properly resourced appeals mechanism. Resourcing constraints are not an acceptable reason to justify retaining a system that is clearly failing claimants and contributing to unacceptable delays to them accessing fast and fair redress. (Conclusion, Paragraph 30)