12. Before we decide if we should do a detailed investigation of a complaint, we look at whether there are signs the organisation has got something wrong. We do this by comparing what should have happened with what did happen. We have done this and have not seen any signs that something has gone wrong.
Instructions on the RPA website
13. Mr S told us the instructions do not include any warning about the final steps of the submission and how this can be missed out by accident.
14. The instructions on GOV.UK say certain fields need to be completed before the claim can be submitted:
• ‘the rotational options question in submit information. The applicant must answer with ‘Yes’ or ‘No’ if their agreement contains rotational options. If the agreement does not contain rotational options, they must answer ‘N/A’ • the applicant must confirm whether they have made changes to the claim form in other claim information • the applicant needs to mark ‘Yes’ in the declarations section to be able to submit the claim’.
15. Mr S accepts he did not complete these because he told us he accidently missed the final steps of the submission. We cannot say there is a failing here by the RPA because its instructions explain what was needed for claim to be completed. And, Mr S had signed his agreement to understand and comply with the requirements. The RPA’s view seems reasonable that if Mr S had followed the instructions and completed all fields, it is likely his submission would have been successful.
The user experience of the website and being told the claim had not been successful
16. The GOV.UK guidance says applicants will see a confirmation message when they successfully submit their claim. Mr S accepts he did not get a message. The Independent Appeals Panel (IAAP) said because of this it is reasonable and fair to say if there was no confirmation message, it meant the claim had not been submitted successfully. For this reason, we cannot say there are signs of a failing because the RPA did not tell Mr S he had not submitted his CS claim successfully.
17. The RPA said the rural payments screen on the website would have shown an error message when the submission failed. Mr S denied seeing any message. The RPA showed us an example of an error message which it says would have appeared when Mr S was using the page. We have not seen any evidence to tell us if this information was shown to Mr S when he was using the website.
18. The GOV.UK guidance includes instructions on how the applicant can check their application is submitted and shows them the status of their claim. Applicants, like Mr S, who make online submissions have access to the rural payments system (a self-service portal). This includes a page listing their CS claims and the submission status and date. The IAAP told Mr S that based on this Mr S would have been able to see if his claim had been submitted successfully. He should have seen a notification showing his claim was successfully submitted if it had been fully completed.
19. We acknowledge Mr S was frustrated because he says did not get any reminders to complete his claim. He says this is inconsistent with other RPA schemes, like the basic payment scheme, where he gets reminders. Mr S says the process is not in keeping with Natural England’s mission statement that says they will provide an excellent service and treat farmers as partners. RPA said there is no regulatory obligation for it to send claim reminders and we have not seen evidence of a commitment for it to do this. The fact that another scheme uses a different system does not mean the RPA’s system or decision is wrong. We cannot say not sending a reminder is a failing because the RPA does not need to do this and Mr S did not forget to make a submission. He did not submit the application in line with the guidance. The RPA guidance was clear he should have received an on-screen acknowledgement if his claim had been successful. Mr S accepts he did not complete all the fields and he did not get an acknowledgement of a successful submission.
20. Our Principles say organisations should act fairly. They say when making decisions organisations should behave reasonably.
21. We have not seen any signs of failings in the way the RPA carried out its process and it acted in line with our Principles.