Official Complaint to Head of CMS Arlene Sugden

Dear Ms Sugden,

My apologies for the alarming subject line, however this is an alarming topic and one that I am sure I am not the first to raise with you. It is my understanding that ahead of raising a formal complaint with the Ombudsman, I must first do so with the CMS, and that is the purpose of this email.

I have conducted a study of mortality utilising data disclosed by your DWP colleagues under FoI, the report is attached. I have also set up a campaign website, which you will find at, as I believe this is a national scandal that requires immediate public awareness and for the DWP/CMS to take immediate action to halt further suicide driven by CMS practices.

I have also written to Baroness Stedman-Scott, Therese Coffey, Nadine Dories and Boris Johnson (separately and also CC'd to this email), together with an email going out to every current MP with a copy of the attached report. The media have also been informed, albeit that I suspect there is some restriction on them reporting anything to do with this topic, despite providing them with the facts, please confirm whether that is the case?

I have had a parliamentary petition request (calling for immediate suspension of CMS enforcement pending a public inquiry) turned down on the basis that the allegation I make is either false or unproven, yet it is neither on the strength of the attached report. It is my view that data disclosed by CMS confirms that there is a dramatically high excess mortality within the payng parent population, not mirrored in the receiving parent population, and which is almost exclusively attributable to the relatively small sub population of paying parents who have arrears, indicating therefore they are unable to pay but still subject to over-zealous enforcement practices that would result in any other debt collection organisation being shut down. Having personal experience of these over zealous enforcement practices, combined with a total absence of care in regards to the impact on the target parent, I have no doubts that CMS practices have played a substantial role in these excess deaths, which can only be realistically be attributed to a grand scale of suicide. The report identifies that the remainder of the sub population of paying parents with arrears, along with any others who may fall into financial difficulty, are at quite extraordinary risk of suicide, elevated by a multiple of 173 compared to the highest risk group nationally. Their plight will be compounded by the likelihood that they have been a victim of domestic abuse, and are currently being financially abused domestically, with the CMS being co-opted into that abuse. It is therefore essential that CMS treat the content of my report and this complaint as its number one priority for immediate attention and action.

Given the gravity of this situation and the potential criminal consenquences for you and your managment colleagues of any continued failure to act, I recommend that the CMS voluntarily suspends all enforcement activity where a parent is unable to pay, and requests that the government initiate an immediate Public Inquiry into the practices of CMS and how they are leading to such high levels of excess mortality.

As it would be a requirement for you to do so when implimenting any debt collection actiivity that could have serious health implications for those targeted, I request that you ensure disclosure by the CMS of all research undertaken into the impact of each of the enforcement powers exercised. It would have been research of that nature that would have guided the organisation in terms of appropriate minimum level of risk assessment, which you are obliged to undertake to protect the health and safety of service users.

I look forward to hearing from you very soon.


Brian Hudson

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