Forty-first Report - Driving licence backlogs at the DVLA

The DVLA’s communication during the pandemic was ineffective, leaving many customers feeling as if their applications were making no progress. Customers had huge difficulty contacting the DVLA’s call centre during the pandemic to enquire about the progress of applications. Between April 2020 and March 2022, due to a surge in calls, around 60 million calls to the DVLA about driving licences went unanswered, 94% of the total it received. The number of calls it did answer fell by more than half, from over four million in 2019–20 alone, to 3.4 million over the two years from April 2020 to March 2022. Some of our constituents told us that when they did speak to the DVLA they found its response unhelpful, causing frustration and additional stress. Many DVLA customers went to their MPs for help: the number of complaints about the DVLA received via MPs increased tenfold between 2019–20 and 2021–22. Although most people affected by the backlogs were able to continue driving under an exemption in the Road Traffic Act 1988, this was not clear to many people. The DVLA says that it has recently modernised its telephony systems, so it should be able to cope better with future surges in demand. Recommendations: a) The DVLA should improve its communication to ensure customers understand the status of their applications and are updated regularly. This should include the information that they may be able to continue to drive while they wait for their application to be processed. b) The DVLA should also improve how it communicates this and other important information to stakeholders such as MPs. It should set out what it is doing to improve its communication in its Treasury Minute response to this report. 6 Driving licence backlogs at the DVLA

The DVLA’s efforts to encourage customers who can use online services to do so are not sufficient. Some customers need the option of applying for a driving licence using a paper form, but the DVLA assesses that around 60% of customers who apply on paper could have applied online. In the periods during the pandemic when customers who applied on paper experienced substantial delays, almost all customers without notifiable medical conditions who applied online had their applications processed within three working days. The DVLA rightly wants to avoid disenfranchising people unable to use online services, and its aim is to “create digital services so good people choose to use them” while keeping a paper option available. However, we believe there is considerable scope for improving take-up of DVLA’s online services and we do not agree with the Department’s approach of not setting the DVLA any targets for digitisation and digital take-up of driving licence services. Recommendations: a) The Department and the DVLA should consider what more they can do to increase take-up of the DVLA’s online services: • They should understand better why some customers have chosen not to engage with online services. • They should incentivise customers to use digital services and discourage people who can apply online from sending paper applications. b) The Department should, in its Treasury Minute response to this report, set out its plans to hold the DVLA to account for increased take-up of online services.

The DVLA gave insufficient attention to those driving licence service areas, such as medical notifications and its call centre, where staffing challenges led to the most detrimental consequences for customers. During the COVID-19 pandemic, the DVLA prioritised services with the highest volumes of applications or where it believed processing delays would cause greater problems, such as its services related to vehicles, knowing that this would take resources away from its driving licence services. Both the DVLA and the Department knew the system for managing paper-based driving licence applications was susceptible to disruption because it relied on people being on site. At the onset of the COVID-19 pandemic the DVLA sought to make paper driving licence services more resilient. It invested in new buildings and additional staff, made changes to the law to postpone driving licence renewals, and made more services available online, but these actions failed to prevent backlogs from building up and persisting for around two years. The DVLA also undertook work for other parts of government during the pandemic, such as printing vaccination invitation letters, which were of course very important tasks, but also diverted resources from DVLA’s core services. It told us this work used spare capacity in its printing and mailing facilities. Recommendations: a) The DVLA should write to us within six months to share an improved contingency plan. Driving licence backlogs at the DVLA 7 b) The DVLA and the Department should also jointly write to us, at the same time or earlier, to set out lessons learned from the driving licence backlogs saga and how they are responding to the lessons. c) The Department should ensure it understands the impact of the DVLA taking on work for other government departments and ensure there are mitigations in place to address any negative consequences for the DVLA’s core purpose.

The DVLA’s system to process applications from customers who have notified it of relevant medical conditions is slow, inefficient and in need of major improvement. Processing times for applications that involve the DVLA making a medical decision are far longer than for other applications, with many decisions taking a year or more. At the time we took evidence in November, the DVLA expected to clear its remaining backlog of such applications by January 2023, returning to meeting its target of processing at least 90% of these applications within 90 working days. But in our view even 90 working days is too long for customers to wait. Customers experiencing problems after notifying the DVLA of medical conditions have been the main source of complaints to the DVLA since 2018–19, and we are concerned that the DVLA’s poor service discriminates against its more vulnerable customers. The Department acknowledges that the legislative framework for medical licensing has not been reviewed for decades. The DVLA’s decisions often require information from GPs and other medical professionals, which is requested and returned using paper documentation. The DVLA intends to introduce modern, digital communications to speed up information exchange with the health sector but given the technical challenges involved, it is not yet clear to us when and how it will do this. Recommendations: a) The DVLA should in its Treasury Minute confirm that it has resolved the backlog in applications from drivers with notifiable medical conditions as expected, and if not, why it has not and when it will do so. b) By the end of 2024 at the latest, the Department should complete a strategic review of the system to process applications from driving licence customers who have notified it of relevant medical conditions, encompassing both the legislative framework and process management. It should set out its timetable for the review in the Treasury Minute. It should work with the Department of Health and Socia

The Department and the DVLA have not taken a strategic approach to maintaining and improving the infrastructure, estate and processes that the DVLA’s performance depends on. The Department has taken a hands-off approach to the DVLA, failing to ensure that its services are periodically reviewed and improved through timely adoption of modern working practices and up-to- date technology. Consequently, the driving licence application process has become inefficient through outmoded working practices, and it is not resilient to external shocks. We recognise that the DVLA has improved and modernised some of its services, for example paying road tax is now an easy and efficient process for vehicle owners. However, the pandemic exposed weaknesses in some of the DVLA’s other 8 Driving licence backlogs at the DVLA operations. Currently, most staff working on driving licences cannot work remotely because of data security risks and underlying technological challenges, which the DVLA said cannot be easily remedied. The DVLA acknowledges that while almost all its services are digitised, applications for vocational licences and applications involving complex medical decisions are not, and its plans for digitisation will take 10 years. The DVLA argues that it is now a much nimbler organisation after changes introduced during the pandemic, but we are unconvinced that it is ready for any future crises. Recommendation: The Department and the DVLA should work together to set out, by the end of 2023, a strategy for how the DVLA will re-engineer and modernise the driving licence process, over the next 3 to 5 years. Its strategy should address the extent to which its long-term digital transformation plan will make its IT infrastructure adequately resilient and if there is more it could do to enable secure remote working should another crisis occur. Driving licence backlogs at the DVLA 9 1 The DVLA’s customer service

On the basis of a report by the Comptroller and Auditor General, we took evidence from the Department for Transport (the Department) and the Driver & Vehicle Licensing Agency (the DVLA) on the scale and nature of the backlogs in driving licence applications, the underlying causes and the DVLA’s actions to manage and reduce the backlogs.1

We are also aware of other cases from our constituency work, for example of people being unable to work after a five-month wait for a driving licence and a bus driver threatened with losing his job because of delays at the DVLA. Other constituents have lost income or not been able to see family members.15

The Department acknowledged in the session that the human stories behind these cases can be genuinely very difficult, commenting that “this is not just a numbers game. It is not just about processing and backlogs. It is about real people and the impact that not being able to get a driving licence can have on their livelihoods and their lives.”16 The DVLA told us that it brought in workarounds to help customers who were badly affected by delays. For example, when the DVLA knew a customer had a job offer or employment 8 C&AG’s Report, paras 12, 20, Figure 8 9 DLB0031, DLB0036, DLB0017, DLB0028 10 DLB0052, DLB0067, DLB0015, DLB0014 11 DLB0040, DLB0058, DLB0063 12 DLB0044 13 DLB0049 14 DLB0040 15 Q 59 16 Q 56 Driving licence backlogs at the DVLA 11 dependent on their driving licence being issued quickly, it looked to prioritise their case.17 However, many of our constituents clearly did not benefit from DVLA’s attempts to help customers in this way and suffered as a consequence.18 The DVLA’s communication about customers’ applications

From April 2020 to March 2022, the DVLA did not answer 60 million calls to its drivers’ licence customer service number, 94% of the total it received. The number of calls to the DVLA about driving licences surged in Summer 2020 and stayed above pre- pandemic levels for two years, rising from an average of less than 0.5 million calls per month in 2019–20 to an average of 3.5 million calls per month in 2021–22. The DVLA did not increase its capacity to answer calls in response to the surge in demand – the NAO found the number of calls the DVLA answered fell by more than half, from over four million in 2019–20 alone, to 3.4 million over the two years from April 2020 to March 2022.19

The stress and frustration customers felt as a result came across as a clear theme in the written evidence our inquiry received from members of the public. For example, one person told us “Having no contact was useless because for all I knew, my application could’ve been lost in the post and never received, if it was in progress or even done.”20 Some of our constituents also told us that when they did speak to the DVLA they found its response unhelpful.21

Many customers went to their MPs for help: complaints received via MPs increased from 2,600 per year in the two years before the pandemic, to 26,800 in 2021–22. The DVLA explained to us that people were coming to MPs because they found it difficult to get through to the DVLA. The DVLA believes the surge in complaints to MPs reflects a change in customer behaviour towards bypassing its usual complaints procedure and going straight to MPs.22 In our constituency work we had mixed experiences of dealing with the DVLA on their behalf – including some very positive experiences but not all so. We felt the DVLA could have done more to keep MPs informed about the problems it was experiencing and advise MPs on how they could help their constituents.23 Although most people affected by the backlogs were able to continue driving under an exemption in the Road Traffic Act 1988, this was not clear to many people.24

The DVLA told us it has recently modernised its telephony systems, so in future it should be able to cope better with surges in demand. For example, with the new system it can more easily increase the number of telephone lines available. However, the DVLA cautioned that installing a new system on such a large scale is complex and challenging and it is therefore taking time to install.25 17 Qq 55, 73–75 18 Qq 59, 106 19 Q 103; C&AG’s Report, paras 2.14–2.15, Figure 8 20 DLB0053 21 Q 106 22 Qq 4–5; C&AG’s Report, Figure 9 23 Qq 1–7 24 Qq 59–60 25 Qq 105–106 12 Driving licence backlogs at the DVLA Under-use of online services

The DVLA told us that at the start of the COVID-19 pandemic its first priority had been to maintain its online services because most licence applications are initiated online.26 In the periods during the pandemic when customers who applied on paper experienced substantial delays, almost all customers without notifiable medical conditions who applied online had their applications processed within three working days. However, there will always be some customers who need the option of applying for a driving licence using a paper form instead of an online service.27 The DVLA wrote to us after the evidence session and told us of the Lloyds Bank Essential Digital Skills report, which indicates that a substantial proportion of adults do not have the skills to use online services. It told us its goal is to “create digital services so good people choose to use them” but that it should avoid disenfranchising people unable or unwilling to use online services.28

The DVLA told us it estimates that about 60% of the paper-based applications it receives could have been made online, and so those customers experienced longer waiting times than they needed to. During the pandemic, the DVLA investigated the reasons for this and found that some people do not trust putting their personal data into an online application. The DVLA adapted its publicity campaign to try to give people reassurance that its online services are safe and secure.29

We are concerned that the DVLA does not have a more active strategy for encouraging customers to switch from paper to online services, relying on customers to decide themselves to make this transition rather than proactively encouraging and supporting them do so.30 Although the DVLA told us it has seen a huge shift to digital over the last four or five years, the NAO found that the volume of mail arriving at the DVLA has decreased only by 6% between 2019–20 and 2022–23.31 The DVLA told us that future work to switch more of its business online will be challenging, as its digitisation work is past the stage of “early gains” and has moved into “hard graft”. The Department has not set the DVLA targets on digitisation so it remains unclear how the Department will actively monitor the DVLA’s progress in further digitising services.32 26 Qq 12–13; C&AG’s Report, para 11 27 Q 44 28 Qq 65, 97; Letter from DVLA to PAC dated 8 December 29 Qq 16, 93 30 Qq 94–95, 99 31 Q 17; C&AG’s Report, para 1.8 32 Q 96 Driving licence backlogs at the DVLA 13 2 Strategy and planning for driving licence services The DVLA’s contingency planning and prioritisation decisions

During the COVID-19 pandemic, the DVLA prioritised those services with the highest volumes of applications or where it believed processing delays would cause greater problems. The DVLA told us that in 2020, it prioritised reducing the backlog in paper applications for vehicle-related transactions, because at the time, these backlogs were a bigger problem than the backlog in paper-based driving licence applications. The DVLA prioritised vehicle services because of the higher volume of vehicle-related work, in the knowledge that it would have a knock-on effect on driving licence services. The DVLA told us that to address backlogs in driving licence applications, its approach was to arrange a change to the law that meant no customers needed to renew licences that expired in the first year of the COVID-19 pandemic.33

The DVLA’s system for managing paper-based driving licence applications relies on people being on site to manually process applications. The DVLA and the Department told us that when they determined priorities in 2020, they knew this system was susceptible to disruption during the COVID-19 pandemic, and that the solution was investment in the estate to enable more DVLA staff to return to work on site to process paper applications.34 Around a decade before, the DVLA had reduced and centralised its office space, which saved money but also reduced its resilience. The DVLA told us that, “for many years, it absolutely worked and was the right decision” but that in a pandemic, it meant the DVLA became susceptible to local levels of infection.35 The Department told us that by March 2022, the DVLA had enabled around 2,500 staff working on other services, such as vehicle services, to work remotely, despite none being able to do so before the COVID-19 pandemic. At the start of 2020, the DVLA had piloted remote working for some service areas and started to roll out laptops, but most staff on site still used desktop computers.36

At the onset of the pandemic, the DVLA sought to make paper driving licence services more resilient. The NAO reported that the DVLA decided to find additional office space in April 2020, when the COVID-19 pandemic in Wales had just started.37 The DVLA has since invested in new buildings and additional staff, and made more services available online. In 2020, it made changes to the law to postpone driving licence renewals, but the Department told us that it decided on road safety grounds to limit this legal extension to licenses that expired over an 11-month period, leading to a spike in renewals in 2021.38 The Department told us that although the DVLA had contingency plans, they did not anticipate and plan for the combined impact of industrial action and the COVID-19 pandemic continuing into 2021.39 33 Qq 11, 14, 18–20 34 Q 20; C&AG’s Report, para 16 35 Q 23 36 Qq 22, 35–36, 41–42 37 Q 20; C&AG’s Report para 3.6 38 Qq 19–20, 25–31; C&AG’s Report, paras 22, 24–25 39 Qq 20–22 14 Driving licence backlogs at the DVLA

The DVLA told us how it undertakes work for other parts of government to make best use of the DVLA’s infrastructure, expertise and the spare capacity becoming available as customers switch from paper to online applications. For example, it produces biometric residency permits for the Home Office, and it printed and mailed out vaccination invitation letters in its secure printing and mailing facility. The DVLA also wrote to us after the evidence session and told us that this work used spare capacity in its printing and mailing facilities and provided value for money for taxpayers. Its annual report and accounts show it carried out work for other government departments worth £22 million in 2021–22, compared with £15 million in 2020–21, £12 million in 2019–20 and £9 million in 2018–19.40 Notifications from drivers of relevant medical conditions

Despite the DVLA clearing the backlog in most driving licence applications by mid- 2022, there remains a backlog in applications that involve the DVLA making a medical decision. Processing times for applications that involve such decisions are still far longer than for other driving licence applications, with many medical decisions taking a year or more. For example, the NAO found that in September 2022, 33,000 applications were more than 200 working days old. Of the cases closed in September 2022, around 2,000 had been waiting for a decision for over 350 working days. At the time we took evidence in November 2022, the DVLA expected to clear this backlog by January 2023.41

Customers experiencing problems after notifying the DVLA of medical conditions have consistently been the main source of complaints to the DVLA since 2018–19. In 2021–22, around 53% of all complaints to the DVLA were in this category, rising to 68% in the first half of 2022–23.42 We raised concerns that the DVLA’s pattern of providing worse service—in particular, much longer turnaround times—to customers with certain medical conditions might be an equalities issue and a potential case of discrimination against disabled applicants.43 The DVLA told us that straightforward medical conditions are generally closed much faster than applications from customers with complex or multiple medical conditions. The DVLA’s usual standard, which it is aiming to return to, is to process 90% of drivers’ medical applications within 90 working days. In our view, 90 working days is still too long for a customer to wait.44

The Department commented that the current legislative framework of medical licensing has not been looked at for a very long time and raised the question of whether it was still fit for purpose. Many factors have changed since the legislation was introduced, notably the general population is now older and there is a significantly higher number of over-70s continuing to drive than when the current legislation was introduced.45

We also heard that the DVLA’s decisions often require information from GPs and other medical professionals, which is requested and returned using paper documentation. 40 Q 47; Letter from DVLA to PAC dated 8 December; Driver & Vehicle Licensing Agency, DVLA annual report and accounts 2019 to 2020, HC 441, July 2020, page 93 (viewed on 6 December 2022); Driver & Vehicle Licensing Agency, DVLA annual report and accounts 2021 to 2022, HC 590, July 2022, page 91 (viewed on 6 December 2022) 41 Qq 85–87, 91, 107; C&AG’s Report, para 15, para 2.10, Figure 7 42 C&AG’s Report, para 2.18, Figure 10 43 Qq 56–57 44 Qq 85, 87, 89–90 45 Q 52 Driving licence backlogs at the DVLA 15 This process is not covered by the GP contract with the NHS and the DVLA pays GPs for each response.46 Some applications that customers start online but which require a medical decision require postal correspondence between the DVLA and doctors, further slowing the process. The DVLA wrote to us after the evidence session to report that as of 2 December 2022, around 60% of applications in progress involving a medical licensing decision were waiting for information to be supplied by a third party, such as NHS doctors and consultants, hospital teams or the drivers themselves. The DVLA told us it is exploring how it could introduce modern, digital communications to speed up information exchange with the health sector. We heard that the DVLA has talked to the NHS about the idea but that finding a solution was difficult and building digital links will be technically challenging.47 The Department for Transport’s strategic management of the driving licence system

The evidence we heard from the Department suggested to us that it has taken a hands- off approach to the DVLA, and not ensured that the DVLA’s services are periodically reviewed and improved through timely adoption of modern working practices and up- to-date technology. For example, when we asked what the Department was doing to help the DVLA speed up the processing of applications from customers with relevant medical conditions, the Permanent Secretary acknowledged that the area was a challenge but did not describe specific actions the Department was taking.48 We recognise that the DVLA has improved and modernised some of its services, for example paying road tax is now an easy and efficient process for vehicle owners. The DVLA wrote to us after the evidence session and told us that over 80% of all its transactions are completed online.49 The DVLA acknowledged that while almost all its services are digitised, applications for vocational licences and applications involving complex medical decisions are not. On its plans for digitisation the DVLA commented that “it is more of a 10-year timeline to be predominantly or almost everything digital.”50 The DVLA argues that it is now a much nimbler organisation after changes introduced during the pandemic. It has taken steps to make its operations more resilient, including opening an office in a second location, Birmingham.51

The pandemic exposed weaknesses in the DVLA’s current operations which rely heavily on staff working on site and IT systems that hold customers’ personal information which staff can only access on site. Currently, remote working is limited, particularly for operational staff working on driving licences who have to be on site to work. The DVLA told us that at present, almost 60% of staff are working entirely on site as they have been doing throughout the COVID-19 pandemic, while the other 40% of the DVLA’s staff are in roles that permit hybrid working and work on site at least 40% of the time. The DVLA highlighted “a really strong sense of fairness” in its culture, which it said means the current situation where non-operational staff now have the opportunity to hybrid work between their homes and the office, while others must be on site, is challenging.52 The 46 Qq 51, 109 47 Qq 53, 80–82; C&AG’s Report, para 1.9; Letter from DVLA to PAC dated 8 December 48 Q 90 49 Qq 45, 105; Letter from DVLA to PAC dated 8 December 50 Qq 46, 47, 98 51 Qq 23, 76 52 Qq 36, 48; C&AG’s Report, paras 1.7, 3.15 16 Driving licence backlogs at the DVLA DVLA told us there were many issues with remote access to driving licence data systems, including security of the large amount of personal information it holds, and underlying technological challenges. The DVLA’s digital transformation plans aim to improve customer experiences, but do not aim to increase resilience through making it possible for more staff to work from home.53

We challenged the DVLA and the Department about their strategy for future of the DVLA. The Department told us that conversations are happening about what the future of driving licence services should look like. We heard that the DVLA will need to become more resilient to anticipated changes in the profile of its customers as the population ages, and respond to effect on road safety measures brought on by the potential growth in autonomous vehicles. Nevertheless, we did not feel that the DVLA and the Department were able to articulate a clear strategy for how they might re-engineer and modernise the driving licence process, encompassing for example a clear picture of what its future staff, estate and IT infrastructure needs to look like.54 53 Qq 68, 70 54 Qq 45–48, 122 Driving licence backlogs at the DVLA 17