Hi,

Client is appealing a DLA decision - GL24 duly completed and posted, but returned to the client asking her to get her rep to sign it.

We call DCS and ask why, and we never did this before, and so forth, they say it is a new procedure "to protect claimants". We ask for copy of the procedure. It came:

"Information Note 18/2008 issued 13/3/2008
Representative's signature with appeal request

1. When a customer has a representative authorised to act on their behalf at appeal, represtative's signature must be obtained.

2. If the representative has not signed any of the appeal documentation, Draft Letter DLA?? must be issued to the representative requesting their signature."

Anyone else had this happen? I think it makes life very difficult eg what do you do when offering initial advice followed by a specialist referral? Also, they haven't followed their own procedure but returned client's appeal, which I find objectionable - what authority do they have to reject an appeal containing all the relevant info??

Or I might just be getting crabby because it's the end of the day ...

Sue

haven't come across it, however we generally send in the GL24 for our clinets with a covering letter confirming we are repping them. Is the signature needed specifically on the GL24 itself?

am wondering if it's related to signs that appeared in teh appeals waiting room some time back warning appellants about unauthorised/ unqualified reps who may be charging them unlawfully?

No the reps signature isn't requested on the GL24. DCS tried to convince me otherwise by pointing to the box under the reps details but that clearly requires the client's signature, so then they switched to "it's our policy".

I haven't seen those notices at venues near us. Might be a local difficulty?

We've never been asked to do this - normally we have the client sign an Authority the wording of which permits us to represent from Reconsideration through to Commissioners if necessary. Armed with that, we normally dispense with the GL24 and submit a letter formally lodging an appeal, and setting out the grounds for it. We have never had any problem with Wembley, Blackpool or the Appeal Service accepting our signature.

If there is an addition to the DLA internal guidance then it's hardly likely we will get to hear about it until someone misinterprets it, as seems likely in this case. If you get any more "It's our policy" I'd try contacting their Customer service manager.....

Is it possible that there is confusion about the final box on GL24 which reads 'If someone has been officially appointed to act for you or someone has the authority to act for you, they should sign here'. I assume this means under a power of attorney etc, but has it been misunderstood within the DCS?

The best person to contact is Frank Pitfield, Customer Services manager based in Wembley DBU -

Frank Pitfield
Customer Service Manager
Wembley Disability Benefits Centre
Tel. 020 8795 8509
Mob. 07732 626238
Fax. 020 8795 8798


Pitfield Frank DCS <[email protected]>

We've had a spate of these too, over the last few weeks, the offending box looks like and has always looked like a box for appointees and power of attorneys to sign. Looks like, more dysfunction from on high.

I've been writing letters back pointing out i'm a rep not an appointee etc etc, actually they have then let the appeals proceed as normal, anyway more evidence of neo-liberal institutional dysfunction spreading ever wider.

I feel crabby too. Still mustn't grumble Torquay are off to wembley again.

Andy

which competition .......?

If you're looking for daft stories on a Friday afternoon (well, effectively) how about this? Submitted a DLA claim with signed authorisation covering application/appeal/recon. Client refused on application and recon, we appealed by letter. Phone call from DWP, can we fax authorisation? "You have authorisation" says I. Yes but we have had it some time. "I didn't realise they were time limited. Do you want a recently dated one?" No, just re-fax the old one. So I did, going for the soft option.

Well Mike its the errrrrrrrr ummmmmmmmm Carlsberg Trophy against Ebbsfleet.

Yes the time limited is usually 3mths unless you specifically state until the end of said process e.g. In this case the claim and appeal process . No point having a system that kind to trees and the enviroment if there are more ways to waste paper.

i never bother with a GL24. i just send an appeal letter accompanied by signed authorisation from the client. its never been onjected to in anyway

Quite right too. There is no rule at all that you use a GL24, only that you say which benefit, the date of the decision you're appealling against and why. The GL 24 is just a way of trying to get appellants to do this.

One of the (many) things that confuses me is how this new procedure protects claimants. So they have my signature on a bit of paper. Big cheer! A charlatan posing as a welfare rights adviser couldn't have signed a bit of paper, after all! We're saved!

I leave aside the issue of why anyone would want to pose as a welfare rights adviser. Can confirm it's not the pay or the conditions, or the job satisfaction.

Two GL24s have been returned to me this week with big red star stamped next to the box'If someone has been officially appointed to act for you or someone has the authority to act for you, they should sign here'and a request for client to sign this. Me thinks someone in the DWP is getting carried away with their star stamps. Thinking of getting a stamp of my own!

I have always signed the box on the GL24, have I been wrong doing this and could I get into trouble for doing so?

i just get a little weary of having to say 'i need you to sign the GL24 twice, once to say you want us to represent you and once to say you do want to appeal', cos like, signing it once would be so ambiguous.!

iut044 - I don't think you should worry if your appeals have been accepted. But the box is labeled something like "sign here TO AUTHORISE THIS PERSON TO ACT FOR YOU" (my emphasis). The rep is the person acting who needs the authorisation, seems obvious to me it's the client who is doing the authorising that should sign it.

Sue Welsh - I have not been signing that box, I have been signing the "If someone has been officially appointed to act for you or someone has the authority to act for you, they should sign here" right at the bottom of the form.

iut044 - apologies. I see what you mean, but I don't sign that either - I always assumed that was for appointees or people with power of attorney.

I am pretty outraged about them returning GL24's. Would it help to have a copy of the procedure the DCS sent to me on the website? Because that clearly says that, in the absence of a signature, they should write to the rep.

Sue

Sun 23-Mar-08 07:22 PM by paul__moorhouse

Iut, I agree that you don't need to sign the box as a representative. Although the wording is a bit ambiguous this should be signed by an appointee, or person with power of attorney rather than a rep.

However, I don't think it creates any problems if you do. If a rep does sign it I don't think it invalidates the appeal. So long as there is not an appointee or other person authorised who should be signing it instead, the DWP should just ignore your signature so long as the appellant has signed to make the appeal and to authorise you to act as representative for the appeal.

The problem is that they are now appear to be demanding that representatives should sign this box, in my view incorrectly.

I wasn’t going to wade into this but I just couldn’t resist. As long as the claimant has signed the GL24 in the box authorizing a named rep or a separate form of authority then the rep does not have to sign anything. This is a long-standing position covered by the common law of agency.

An appointee (and this won’t be the rep) will have to sign either a GL24 or a separate appeal letter as the appointee stands in the shoes of the claimant and acts in his/her place. If the DWP says otherwise then they are wrong.

If either or both of the above are complied with then there is a valid appeal lodged.

My client has now sent me a copy of what she was sent, and the DCS have sent back her GL24 with the follwoing handwritten note attached:

Dear ,
Sorry to return your appeal form.
Would you please ask your representative to sign the form *.
Thank you

... and on the GL24 there is a corresponding * against the officially appointed or authority to act box!

Which I am definitely NOT signing.

Sue

And if they won't process the appeal then seek a direction from TTS under reg 38 of the D&A Regs.

No doubt this explains why the occasional appeal case turns up in which the rep is reported on the cover sheet as being the appointee?

....which adds a whole new point of confusion when you then have to tell the panel that actually under legal help funding you can only in fact be there as a McKenzie friend, regardless of what any of the paperwork says.

I had a letter from DCS today about an appeal letter that I sent on behalf of a client, which was accompanied by our usual authority.

They say that they will only accept letters from the person who signed the claim form and they've written to my client asking if she wants a review, and that if the claimant doesn't want a review or doesn't reply, they won't take any action.

I wrote back with a reference to reg 33(1)(a)(ii) DA regs - which allows reps to make an appeal - pointing out that the appeal is properly made and they must deal with it regardless of whether or not they get a reply from the client.

I had assumed this was a one-off admin error but then I saw this thread.... (I've been away)

I despair Tony, I really do!

Thanks, nevip. I've already written pointing out they have no grounds to refuse to accept the appeal and will be following it up by phone week. Will report back.

There's absolutely nothing in the D & A Regs which requires a signature from a rep and I doubt that DWP could come up with any common law legal authority for this new practice.

I sounds like they may have had one or two cases where an appellant had nominated a rep without the rep knowing - feels like the typical DWP over-reaction to a minor hiccup.

In practice, the various examples described will all involve advisers in more time and are yet another hoop for appellants to climb through.

Given that this appears to be happening in more than one case, have any of the advisers affected sent in a formal written complaint to Customer Services at DCS and the MP? Otherwise one is just picking off individual cases rather than changing the wider malpractice.

I called today and client's appeal had not been registered. I spoke to the section dealing and they did agree to do it, but really it shouldn't have been necesary for me to call, IMHO. Feel a letter coming on.

I think I can top everyone! I had a GL24 back with red stars indicating where I should sign it - I did so and it came back this morning with green stars indicating another place I should sign it. Does this just go on until a) the form is completely covered in my signature or b) they run out of different colours. It could of course be that my writing is so appalling that they couldn't believe it was actually my signature but if that were the case numerous IB85's would no doubt be rejected too!

Ang on there. I just had a look at a GL24 (Saturday evening, yeah, I'm sad that way) and there is a box on it that says:
"If someone has been officially appointed to act for you or someone has authority to act for you, they should sign here." I can't remember noticing it before, maybe it depends on which version of GL24.

The other side has a space for the appellant to authorise a rep.

I can see that it would be a useful check that the person nominated as a rep really thinks they are - on home-made appeals in the past I have seen a solicitor and even a GP named as a rep, when plainly they knew nothing about it and it was just wishful thinking.

ariadne2

This has been discussed already, the "If someone has been officially appointed to act for you or someone has authority to act for you, they should sign here." should NOT be signed by reps, only apointees or people with power of atorney.

Do not feel bad about not knowing though, I have been signing that box myself mistakedly! It was only after reading this thread that I realised I was wrong!

I cannot believe that a discussion over a signature on a GL24 could generate over a 1000 hits ....

Anyway, notwithstanding the rights or wrongs of placing one's autograph on a GL24, I notice from Sue's original posting that they refer to an internal memo, (see below) which no one appears to have heard of - these would appear to be updates to the DBU version of a DM's Guide, which they call a TMG (team members guide). If they are, we'll have to ensure we start to get them in the same way that we get the updates to the DM Guidance.

Within that, in chapter 6 I think, you'll find intructions on what to do if a signed Authorisation is received from a representative. those instructions include noting the representative's details on the notepad section of the computer record, and keeping the rep informed of any actions taken with the claim. OK, so they don't do either in about 50% of cases, but ....

Going off at a tangent, but as a matter of interest, I know of at least one WRA who deliberately prints off her Authorities on yellow paper, and staples them to the front page of the claim, just to make sure they notice it - seems to work, because she even get notifications when an award is made.......not on every occasion mind you, but encouraging nonthe less.

"Information Note 18/2008 issued 13/3/2008
Representative's signature with appeal request

1. When a customer has a representative authorised to act on their behalf at appeal, representative's signature must be obtained.

2. If the representative has not signed any of the appeal documentation, Draft Letter DLA?? must be issued to the representative requesting their signature."

We have today received a similar letter (CAP22a) stating that the client has "told us that you will representing her for her appeal.The law says we can only deal with an appeal when it has been made in the right way. We are sending back the appeal letter because we need you to sign it and give us more information.Please tell us why you did not make the appeal earlier. Are there any special reasons for your lateness in writing to us.
You must reply within 14 days."
Then there is a copy of the GL24 with 2 red crosses either side of a box for the signature of "someone has been officially appointed to act for you...."

I have spoken to the DWP and challenged their decision to reject the appeal, as it was duly made in accordance with Reg 33 of the SSCS (Decisions and Appeals). There was sufficient information to warrant an appeal, it was signed by the appellant and it was well within the time period. They are in my opinion, working contrary to the law and to a DWP guidance note that Mike refers to in the previous response. There is nothing within the law that requires a representaive to sign any appeal, it is required if someone has power of attorney (legally appointed) or is an appointee.

I have submitted a letter expressing my concerns regarding this action to the DWP and will ensure that the Tribunal Service (District and Regional Chairs) are kept informed of the DWP's refusal to accept GL24's unless signed by a representative.That is if there is one. This is not a requirement of the Tribunal Service when the TAS1 is forwarded to the appellant all the appellant needs to do is give a name and contact address of a representative for correspondence etc.

The DWP are really getting out of hand. Not paying back recovered amounts of an overpayment later found by a tribunal to be unrecoverable, refusing to give out claim forms, insisting on reps signatures. I don’t give a toss what the DWP say or the way a GL24 is phrased. Until statute overrides the common law principles of agency (or the D&A Regs are amended) then any refusal to process an appeal and copy documents to an authorized representative is unlawful and the DWP should be chased all over town until it backs off.

Aren't DWP just getting confused between:
1. an appointee (who would sign the GL24 the same way as the claimant although GL24 not particularly well designed for this purpose);
2. someone who has been given written authority to lodge the appeal on the claimant's behalf under reg 33(1)(a)(ii). Not sure where they should sign given the format of the GL24. The reg doesn't specify the format of that written authority but this would not be relevant here anyway - if the GL24 has been submitted signed by the claimant then there would be no need to give authority for anyone else to lodge the appeal. The job's been done!
3.someone the claimant wants to represent them at the tribunal who doesn't have to sign the GL24 anywhere.

I'm sure there are practical and sensible ways of getting round the shortcomings of the GL24 if you are dealing with a reasonable organisation but if DWP are not clear about the distinction between the above 3 categories then you are probably going to get nowhere fast. It seems as if their policy of demanding extra signatures is based on the layout of the GL24 rather than an understanding of the regs. It shouldn't be that difficult to design an appeal form that can be used and clearly understood by the different categories of person allowed to make an appeal (and the DWP themselves).

And while they're busy re-designing the form, they could give enough space in the box to write more than 'see grounds of appeal attached'.

The GLA 24 has been around for a lot longer than many of these clerks who are now asking for signatures, and have the gall, nay the temerity to send back a form which doesn't have one, with stars stamped on it for good measure! do you get a gold one for signing in the right place at the right time?.

This form is almost unigue in DWP land because it is universal, and as far as I can recall we've never had a spot of bother with it before from any branch of the empire - until now. I spoke with DBU customer services this morning, and the nice lady confirmed that the the instructions referred to are indeed similar to the updates to the decision makers guide - they are updates to the DBU team members guide. She also said she'd get Frank to reply tomorrow.....

Anyway, as mentioned before, I can't see why they are so adament about these signatures on forms - we never use them - just write in with an Authorisation and lodge the appeal - with reasons etc.

A quote from Terry Moran, CE of the new Pensions, Disability and Carer Service - see todays rights news story...:

"...This will allow us to deliver services designed around our customers, rather than asking them to fit round us".


hahahahahaaaaa

ooooh i specifically liked the bit about them combining expertise....

now that is a novel idea ..............it'll never catch on though

The DMA Regs themselves are deeply mystifying. They say:

"An appeal or an application for an extension of time for making an appeal to an appeal tribunal shall be in writing either on a form approved for the purpose by the Secretary of State ... or in such other format as the Secretary of State accepts...as sufficient for the purpose and shall-
(a) be signed by-
(i) the person who under section 4(1) of the Vaccine Damage Payments Act, section 20 of the Child Support Act, section 11(2) of the 1997 Act or section 12 (2), has a right of appeal; or
(ii) where the person in head (i) has provided written authority to a representative to act on his behalf, by that represntative."

What is section 11(2) of the 1997 Act, I hear you cry. The 1997 Act is the Social Security (Recovery of Benefits) Act and is about who has a right of appeal there (you know, in persoanl injury damages cases). I have no idea what the Section 12(2) reference is to - even which Act - though I can tell you that section 12(2) of the 1997 Act was repealed by the Social Security Act 1998.

So unless it's a vaccine damage case, recovery of benefits in PI cases, or child support, the DMA regs don't seem to require anybody to sign anything.

What have I missed??? Or has the Sweet and Maxwell version lost something? But it does clearly say reps, doesn't it?

Ariadne, isn't that 'or' rather than 'and'?

I read that as saying that if a client who is appealing has signed the form then it would be valid, but that if for some reason they have not or cannot sign the form then the rep can - which doesn't seem to be what's being suggested by the stars and stickers?

or am i missing something?

Section 11 of the 1997 Act allows for a right of appeal. Section 12 of that act does not. However, section 12 (2) of the Social Security Act 1998 states “in the case of a decision to which this section applies, the claimant and such other person as may be prescribed shall have a right to appeal to an appeal tribunal, but nothing in this subsection shall confer a right of appeal in relation to a prescribed decision, or a prescribed determination embodied in or necessary to a decision”.

So I presume that the reference to section 12(2) is to the 1998 Act. Reg 33 of the D&A Regs is quite clear in my view. If the GL24 is signed by the claimant then that is sufficient. I have never had a problem with that. Similarly, I often dictate over the phone a brief appeal letter for a client to sign which includes a sentence along the following lines: “please send a copy of the appeal papers to my authorized representative…………” Again, never had a problem. If I lodge the appeal I send a letter signed by me with a signed form of authority. Again no problem.

The issues and procedures are, in my view, simple and straightforward. It is typical of public officials who have a limited understanding of the issues to then tend to overcomplicate things unnecessarily, resulting in havoc and uncertainty where once there was simplicity and order. Bloody bureaucrats! Fight the power!

I found s 12(2) of the 1998 Act later, which at least explains part of my problem!

We experienced our first problem with this last week. I wrote to the local centre in Leeds outlining my concerns by this approach, copied to the local Tribunal Service Office,and received a telephone call this afternoon.

it all seems to be a mistake. They were trying to get around the problem of clients listing reps who are not reps such as their GP, nurse etc when they are not. The very nice lady that spoke to me said that they would not be sending the GL24's out anymore as long as the client has signed both the front and back listing someone as their rep.

She even invited me to contact her again should we get anymore.

seems the problem is now solved................unless you know different?

Hi

This issue has started to hit us now as well and we are just banging our heads against a wall. We have been on the phone to Blackpool and have been told, in no uncertain terms, that they will not accept the GL24 without a named representative, and a signature from ourselves as they are "tightening up"!!!.

Could you possibly give me the contact details of the office in Leeds and we can contact them and make Blackpool aware of this cleardifference in practice between offices!!

Thanks

The contact in Leeds is Anna Wilson on 0113 230 9210. She invited me to refer any other instances to her (not sure if this covers the whole country, probably just her region)

I also made contact with the DWP via the web site and my query ended up with a customer services manager for the Pensions Service in Newcastle. She phoned me on behalf of the DWP as a whole!! Assured me that rep signatures on GL24/s are not required and agreed with me that the box on the GL 24 is for appointees, not reps.

Rather than arguing with whoever answers the phone in Blackpool I suggest a letter to the Customer Services manager with a copy to your local Tribunal Service HQ. Worked wonders for us.

Good luck

Graham Heard is External Relations Group Manager based at Norcross, Blackpool, FY5 2TA. It's worth writing to him and/or copying him into any complaints about this issue.

For comleteness

I have had another message from the DWP on this issue. This time from their HQ. Copied below.

"My colleagues have told me the advice is just plain wrong. Reps do not
have to sign the GL24. Steps are being taken to correct it. He can go
back to what he's been doing for the past 20 years.

Regards

Edward D'mello
DWP Enquiries
London HQ"

This has all the makings of a Brian Rix farce! (Who he? - ed)

We can report that this practice has now spread to Oxfordshire having received our first CAP22a today.

Wembley DBC appeal officer "who are you to tell me that the DWP is acting outside of the law".

Fortunately, our client is eligible for Legal Help so its always nice to know one dept. is paying us to put right something another dept. should have got right in the first place.

Oh, as a tax payer doesn't this mean me (and you)? Dear MP etc etc.

Sometimes I think that after 16+ years of representing at appeals etc nothing the DWP does can suprise me about the scale of maladministration and nonsense I get paid to sort out - then something always comes along to remind me how wrong I am!!!

Ditto! I sometimes describe my job as "policing the benefits system".

I've always wondered how much money is truly involved in administering benefits. It's not just the DWP budget, but local tax payers funding advice org's, LSC funding (or not!!) legal advice, national lottery funding, government grants, courts and tribunal administration, ombudmsen admininstration, etc, etc.

If they only did it responsibility and capably, just think how much more money there'd be for health, education, police, blah, blah. And how many other areas are there where similiar could be said...? What an appaling waste! And that's even before taking into account Prescott's food bill!!!

But how many readers of this forum would then be out of a job?
What would we do?
Would we become a hard to reach / place group of the unemployed that DWP 'third sector' service partners would not want to deal with?

JCP's worst nightmare - I have this monty pythonish vision 400 welfare rights advisers signing on as actively seeking gainful and meaningful employment...............................

With, of course, the right to limit our jobsearch to our usual occupation for the first 13 weeks...

Hi

I have come across this a few weeks ago where my clients GL24 was returned. This was to request us as reps to sign thebox at the back which is for appointees. I rang the DWP and explained that their own leflet states that this is to be signed by those who are officially appointed to act on behalf of their behalf, which we are clearly not. Explaiened that we had been instructed by the client to represent not act as appointees with powers of attorney. I would say this section is only for those officially appointed such as wit powers of attorney. However, it took quite a few calls before it was accepted by the DWP that i was right. They kept telling me that i had to sign it. In the end they rang me back after i kept chasing the matter up and told me i should not sign it and send the GL24 back!. So what was the whole point. I would say someone has misinterpreted the back of the GL24 where apointees sign. But i have to say i was quite annoyed as the GL24 was on my desk for weeks. I was also told initially that the procedure had changed as previously mentioned o this discusson forum.
If you look at the leaflet that comes with the GL24 it is very clear. therefore, there seems to be some confusion at the DWP or some of its workers.

salma

'JCP's worst nightmare - I have this monty pythonish vision 400 welfare rights advisers signing on as actively seeking gainful and meaningful employment...............................'

And I have this Alan Bleasdalesque vision of the first personal adviser to be told 'Gizza Job, I can do that....', now who is Rightsnet's Yozzer I wonder?

We have now received written confirmation, in the usual mealy mouthed wording, from Wembley DBC that the guidance and letter CAP22a have been 'withdrawn'.

Our clients MP has indicated he may riase a parliamentary question about the issue.

Please could readers post info on this thread if from today they receive a CAP22a or any other requirement for a representative to counter sign an appeal.

the question remains as to how such guidance ever saw the light of day when it clearly had no basis in law.

parliamentary written question and answer yesterday ....

Disability Living Allowance: Appeals

Mr. Andrew Smith: To ask the Secretary of State for Work and Pensions what advice has been given to staff handling disability living allowance appeals about the use of standard letter CAP22a.

Mrs. McGuire: The Pension, Disability and Carers Service recently established that instructions to staff in connection with appeals and the use of the standard letter CAP22a was incorrect. That guidance was withdrawn and instructions about the correct procedure were issued to all decision makers on 21 April 2008.

The new instructions direct that, where the customer has completed form GL24 to authorise another person to act for them in an appeal and the customer has also signed the form overleaf as the appellant, the appeal is valid and the representative's signature does not also need to be obtained.

Hansard link

Finally!!

The DWP could cause a row in an empty room.

We have now received a response (via Andrew Smith MP) from Terry Moran, Chief Executive, PDCS. This confirms the guidance was withdrawn in April. However, he does not explain why the guidance was issued in the first place when it clearly had no basis within the regs!

I haven't been able to read carefully all the previous posts due to the lenght of this topic but this is what has been recently written about the subject in internal publication- Decision Makers Exchange Issue 86 - April 2008

"Reps signature on appeal documents
DLA/AA Information Note 18/2008 and an amendment to DMPG Chapter 12 para 13 and TMG Chapter 12 stated that where an appellant has authorised a representative to act for them in an appeal, we need that representative’s signature on one of the appeal documents. This is not quite right and it has brought heavy criticism direct from customer representatives and via Rightsnet.
In order to correct the guidance please note that where the customer has completed GL24 to authorise another person to act for them, and the customer has also signed the form overleaf as the appellant, we don’t need the representative’s signature as well for the appeal to be valid."

And finally? - despite assurances that the original guidance has been withdrawn and all staff advised - only yesterday staff at Blackpool were stating that a representatives signature was required on a GL24. They said they were unaware of any recinding of the original erroneous guidance.

I do like the subtle understatement in Joanne's quote two posts above

'This is not quite right' .... must be the new DWP speak for 'We couldn't have got it more wrong if we tried'

Or 'we haven't got a clue?

We have asked Mr Moran to explain how the guidance came to be issued in the first place without, so it would seem, any check on whether it had any validity with the regs.

Fri 20-Jun-08 11:00 AM by ken

edited to correct text size

Oh, Paul, I wish I was in a mood to be subtle with them. This understatement of the century comes directly from the writers of the publications.
I am more of the "calling spade a spade" mould, but I understand that this is strictly forbidden within the DWP.

Fri 20-Jun-08 11:03 AM by ken

edited to correct text size

Well Yes - my reflection on working for the dept suggests that calling a spade a spade within the dept. tended to result in 'sideways' promotion!