Guidance

A3/2022 (revised): Changes to supported housing and temporary accommodation Single Housing Benefit Extract management information

Updated 20 December 2022

Guidance Manual

The information in this circular does not affect the content of the HB Guidance Manual.

Queries

You can get extra copies of this circular/copies of previous circulars.

For queries about the technical content of this circular, contact housing.policyenquiries@dwp.gov.uk

If you need to ask about the distribution of this circular, contact lawelfare.correspondence@dwp.gov.uk

Crown Copyright 2022
Recipients may freely reproduce this circular.

Who should read

All Housing Benefit staff

Action

For information

Subject

Changes to supported housing and temporary accommodation Single Housing Benefit Extract management information

Revisions

This circular has been revised to include:

• an example of where care, support and supervision costs are not available but the LA is satisfied that support is provided and the funding stream for this support is met outside of HB
• further information on LAs use of the property register
• links to the new HB guidance on supported housing claims
• further lines on standard deduction rates for ineligible meals
• clarity on local authorities actioning exception files
• clarity on where accommodation meets the criteria for both specified accommodation and temporary accommodation and how this should be recorded
• Frequently asked questions: Specific issues raised since the release of the IT changes at a new Annex C

Introduction

1. This circular covers IT changes to local authorities’ (LAs) front-end systems which will improve data collection for supported housing and temporary accommodation claims. Making these important improvements is vital to ensuring better outcomes for citizens and to support future investment decisions in the sector.

2. Associated with the IT changes to your front-end fields will be new requirements in providing data for supported housing claims.

3. LAs will be expected to action the following changes (as detailed further in paragraphs 15 and 25):

• download, test and deploy the new IT functionality
• populate their property register (see further details below)
• obtain the information on ineligible service charges for new claims
• to further specify the types of accommodations that meet the specified accommodation category
• manage the cases on the exception report and correct the data

Background

4. The government made an announcement on the future funding of supported housing in August 2018. This included keeping all supported housing within the Welfare System and committing to develop a new oversight regime to ensure quality and value for money.

5. As part of the Department for Work and Pensions’ (DWPs) effort to improve quality and value for money on supported housing, it is essential we understand more about the Housing Benefit (HB) expenditure to inform policy development and to ensure cases are accurately recorded.

6. As set out in the LAWD12/2021 bulletin, we have also been reviewing the available data for specified accommodation claims and identified a significant undercount of such claims across LAs as a whole. Along with the significant undercount, we have also identified various discrepancies in the use of markers.

7. We have engaged extensively with LA representatives and LA IT software suppliers to explore and develop new functionality on all LA IT systems to improve the quality of data when recording supported housing and temporary accommodation claims.

8. As a result, we will be implementing minor changes to LA IT systems to improve the collection of supported housing/temporary accommodation HB management information (MI). This will reorganise and simplify existing supported housing and temporary accommodation fields into a more intuitive process for all new claims.

9. We will use the Single Housing Benefit Extract (SHBE) data to analyse and track HB expenditure and supported housing caseloads for HB purposes. Therefore, it is essential that LAs comply with the new changes to improve the quality of the data.

IT changes for LAs

10. From April 2022, changes will be introduced to LAs’ IT systems to support the more accurate recording of information for supported housing. This might result in changes to the appearance of some LAs front-end fields.

11. Where LAs do not already have the necessary fields on their IT system, new fields will be added to capture ineligible service charges (see paragraph 34 for more information) and to further specify the types of accommodations that meet the specified accommodation category (see paragraphs 25 to 26 for more information).

12. LA IT software suppliers have developed a ‘property register’ for each LA which will support the automated population of front-end IT systems. It is strongly recommended that LAs use this available functionality as it is considered the most efficient solution.

13. It is important that LAs action the changes outlined in this circular and as further detailed in your IT software supplier guidance, to allow for future policy improvements in the delivery of HB through supported housing.

14. LAs should refer to the new HB guidance for supported housing claims for further information on LAs decision-making process for supported housing claims.

Actions required by LAs

15. LAs must undertake the following key actions:

• Download, test and deploy IT release functionality supplied by your IT software once released. For most LAs this will happen in April 2022 and we will contact LAs to seek assurance on completion of this key activity

• Take action to correct existing HB claims where supported housing and temporary accommodation markers held on LA IT software systems are incompatible. An exceptions file report to support LAs in identifying these cases will form part of the IT release

• Ensure the amount of ineligible service charges for new claims are recorded. These are the charges which will be deducted from the claimant’s contractual rent to determine the eligible rent figure for HB purposes. The ineligible service charges should be recorded as 2 types:

  • the charges to pay for the cost of providing care, support, or supervision services to the claimant, and
  • a total of all other ineligible service charges

• Read and comply with the IT software supplier release note guidance (these will be available on your IT software supplier’s Customer Portal. Note, LAs should ensure they always download the latest version of the release note guidance and the supported housing/temporary accommodation process guides once available on Glasscubes)

Key feature release of the ‘property register’

16. IT software suppliers and DWP identified a property register as an efficient way to collate data on how many properties in each LA areas are classed as supported housing.

17. The register will hold details of supported housing/temporary accommodation properties and will collate information to auto-populate front-end IT fields at an individual claim level, as well as making additional data available to support those LAs who currently maintain local registers. This should improve the processing of new HB claims, including the reduction of clerical input.

18. Where the property register is not used or properties are not included in the register, LAs will still be able to clerically populate their IT system’s front-end fields with the required information at an individual claim level. Those LAs who find it beneficial should populate the register, however, its use is not mandatory.

19. DWP will not have access to the property register held by LAs. We will only use the data which has been derived from the SHBE fields for HB related purposes.

New IT changes and requirements for processing supported housing and temporary accommodation new claims

20. LA IT systems have been amended to ensure only accommodation provided to discharge a statutory homelessness function, or to prevent homelessness, sourced by an LA or provided by a Registered Housing Association, are included under the description of ‘temporary’.

21. Do note, the wording for tenancy types 8 and 10 has changed (see Annex A for full list of tenancy types as listed in the SHBE specification which, if not held by LAs, can be found on Glasscubes):

• 8 - Temporary accommodation where the landlord is the LA - provided to discharge a statutory homelessness function or to prevent homelessness - HB is payable as Rent rebate and the claim is subject to the LHA-based subsidy rules and, for England and Wales, all other non HRA accommodation where the landlord is the LA

• 10 - Temporary Accommodation where the landlord is a Registered Housing Association - provided to enable an LA to discharge a statutory homelessness function or to prevent homelessness - HB is payable as Rent allowance and the claim is subject to the LHA-based subsidy rules

22. For clarity, if an LA has made the accommodation available to the renter on a temporary basis, to discharge any of the LAs functions under Part II of the Housing (Scotland) Act 1987, Part VII of the Housing Act 1996 or Part 2 of the Housing (Wales) Act 2014 , or to prevent the person being or becoming homeless within the meaning of Part II of the Housing (Scotland) Act 1987, Part VII of the Housing Act 1996 or Part 2 of the Housing (Wales) Act 2014, the case should be marked as temporary accommodation except where the accommodation is exempt accommodation.

23. Where an LA has housed somebody to discharge any of the LAs functions (as paragraph 22) and the accommodation is also supported housing, the appropriate marker would depend on whether the accommodation is on a temporary basis. In general, we would expect an LA to mark these cases following the same classification used to claim subsidy.

24. Validation, where not already present, will be introduced to ensure that LAs set the appropriate markers for all supported housing and temporary accommodation cases to avoid duplication, or incompatible markers being set, on new claims going forward. Therefore, LAs will be required to set a claim as either ‘temporary accommodation’, ‘supported housing (including sheltered and extra care accommodation)’ or ‘none’.

25. For new claims, we would only expect the ‘none’ category to be selected for Pension age claims where the pensioner isn’t housed in either temporary accommodation or supported housing (including sheltered and sheltered with extra care).

26. When selecting supported housing (including sheltered and extra care accommodation), LAs must specify the type of the accommodation.

27. LAs will be required to complete a new field to indicate whether the claimant is assessed as living in one of the categories of specified accommodation. The inclusion of this indicator is essential to allow both the critical identification and analysis of specified accommodation cases to support policy development.

28. The definitions have not changed and are reiterated at Annex B of this circular and further information can be found in the new HB guidance for supported housing claims.

29. The recording of each case should reflect which rules the claim has been assessed under. This is because exempt accommodation claims are assessed under different rules than the other 3 categories (managed properties, refuges, and LA hostels) of specified accommodation.

30. The legal definition for specified accommodation categories can be found in the Housing Benefit and Universal Credit (Supported Accommodation) (Amendment) Regulations 2014.

31. Cases should be recorded against the first applicable category in the list. For example, a case can only be marked as a ‘refuge’ if it does not meet any of the previous categories.

Exception reports

32. We know that there are cases within the current stock whereby markers are set which are incompatible with the new changes, for example we’ve introduced validation, where this doesn’t already exist, that would not allow a case to be marked up as both supported housing and temporary accommodation.

33. The new IT release will provide LAs with an ‘exception report’ which can be run locally to highlight all the cases with such incompatibilities. LAs are asked to act on all the cases within the ‘exceptions report’ to correct the markers at the earliest opportunity.

34. LAs are required to address inconsistencies in supported housing or temporary accommodation markers, for example, actioning any exception report for any existing discrepancies.

Recording ineligible service charges for supported housing

35. To help inform future policy development, from April 2022, LAs will be required to capture on their IT systems the amount of ineligible charges which have been deducted from the claimant’s contractual rent to pay for the cost of providing care, support or supervision services to the claimant.

36. To clarify, where applicable, the ineligible service charges LAs are asked to provide are those related to the care, support and supervision which satisfies the specified accommodation definition. In other words, provided by or on behalf of the landlord.

37. In line with the Housing Benefits 2006 Regulations, LAs are required to identify ineligible service charges such as ‘personal care or general support/counselling services’ when calculating the eligible rent and must be satisfied that the cost of providing care, support and supervision is funded from a source outside of HB.

38. When deducting ineligible charges, if the charge amount is specified, LAs should deduct the whole amount of the charge.^{[footnote 1]} However, if the LA considers the amount to be unreasonably low for the service provided, they should use their own valuation of the cost of providing the service when making the deduction. ^{[footnote 2]}

39. If the charge amount is unspecified, LAs should apportion an appropriate amount from the core rent or other service charges which represents a fair amount for that service.^{[footnote 3]} LAs should consider the cost of comparable services. LAs should deduct the full cost, even where the claimant does not fully use the service. This also applies where an ineligible service is provided but included in the rent amount. ^{[footnote 4]}

40. If the landlord cannot provide sufficient evidence that the care, support or supervision is sufficiently funded through a separate funding stream, the LA should assume that the cost is met through the rent charged to claimants (even if not explicitly) and make a deduction equal to the cost of this provision.

41. LAs should make every effort to complete the necessary field for SHBE with the required information and DWP will continue to work with LAs to understand the data. However, it is understood that there may be occasions where this information is not available. For example, if the landlord is a charity, that demonstrates they have a full-time support worker available to residents and that this support worker is fully funded from charitable donations. Although there is no breakdown of the costs at an individual level, the LA is satisfied that support is provided and that there is a separate funding stream for this support. Where the information is not available, the LA should leave the field blank.

42. The remaining ineligible charges not for care, support or supervision should be recorded as ‘Other ineligible charges’. ‘Other ineligible charges’ covers the amount of ineligible charges (excluding those for care, support, and supervision), which have been deducted from the claimant’s contractual rent. For example, ineligible charges for meals or personal utilities would be recorded in this field.

43. Where a charge for meals is identified and is ineligible to be met by HB, LAs should continue to apply standard deduction rates as set out in paragraph 2 of Part 1/Schedule 1 of The Housing Benefit Regulations 2006.

Recording eligible service charges for supported housing

44. LAs should request a rent breakdown from the landlord which sets out all the charges included in the rent and service charges when a new claim or rent increase is submitted. LAs should then consider whether there are any charges included in the rent which should be treated as an eligible service.

45. LAs are encouraged to record the amount of eligible service charges included in the rent when this is information readily available. However, as LA feedback has indicated this information is not always routinely available/gathered, this field will remain optional.

Process for LAs recording ‘types’ of supported housing

46. When recording supported housing cases and selecting the appropriate markers, LAs must specify whether the claim is transitional/short-term supported accommodation, long-term supported accommodation, sheltered accommodation/sheltered accommodation with extra care accommodation using the following meanings and descriptions listed below:

• Transitional/short-term supported accommodation for those in crisis, such as, domestic abuse, care leavers, those recovering from drug/alcohol dependence, those at risk of homelessness and prison leavers, etc

• Long-term supported accommodation for people with long-term physical disabilities, learning difficulties or a mental health condition

• Sheltered accommodation for over-55s with care and/or support needs (including sheltered accommodation with extra care)

47. Short-term supported housing is typically accommodation not intended as permanent settlement where care, support and supervision is provided. It should be noted that there can be a crossover between these categories, for example short-term housing for people with learning disabilities.

48. In most cases, the aim for the claimants in this type of accommodation is to move them into sustainable settled accommodation within 2 years. This excludes general needs accommodation and claims assessed as temporary accommodation.

49. Although sheltered and extra care housing is not specifically defined in HB regulations, it is a well-established entity within the supported housing sector and we are keen to utilise the existing fields to maximise the available data within this area. Further information on the LA requirement and definitions on sheltered accommodation and extra care accommodation can be found in circular HB A5/2019.

50. LA should continue to identify claims related to other specified accommodation that is not short-term in nature. However, LAs’ process for recording these claims may have changed. In that case, LAs should refer to both their IT software supplier’s guidance and process guides.

51. New Burdens funding was made available to LAs for the additional work these changes will create, as detailed in circular HB S3/2022.

Annex A

Tenancy types for Single Housing Benefit Extract specification

1 = LA tenant

2 = Private tenant regulated tenancy (non HA / RSL)

3 = Private tenant deregulated tenancy (non HA / RSL)

4 = Housing Association / RSL tenants (including Housing Action Trusts but excluding temporary or short-term accommodation cases.)

5 = Owner Occupier

6 = Private tenant other (use only if 2, 3, 4 or 10 cannot be used)

7 = Tenure not known

8 = Temporary Accommodation where the landlord is the LA - provided to discharge a statutory homelessness function or to prevent homelessness - HB is payable as Rent rebate and the claim is subject to the LHA-based subsidy rules and for England and Wales, all other NON HRA accommodation where the landlord is the LA

9 = Private Boarder

10 = Temporary Accommodation where the landlord is a Registered Housing Association – provided to enable an LA to discharge a statutory homelessness function or to prevent homelessness – HB is payable as Rent allowance and the claim is subject to the LHA-based subsidy rules.

 

Annex B

Definitions as extracted from circular HB A8/2014

Supporte ‘exempt accommodation’

Background

Ministers announced in 2012 that, as a short term measure, help with housing costs for those living in ‘exempt accommodation’ would be provided outside their Universal Credit (UC) award through Housing Benefit (HB) and that HB in respect of that accommodation would be excluded when applying the benefit cap. Regulations to provide for help with housing costs through HB came into effect from 28 October 2013^{[footnote 5]}.

In April 2013, Lord Freud, the Minister for Welfare Reform, wrote to the sector undertaking to extend this protection to other supported housing that, although not materially different to that which falls within the current definition, is subject to the Welfare Reforms.

Since October 2013, UC claimants have been able to claim help with their housing costs through HB where they live in ‘exempt accommodation’. Local authorities (LAs) continue to determine whether a person’s home is ‘exempt accommodation’, consider which costs are eligible for help and assess the level to which costs should be met. They also retain the discretion to make managed payment of rent direct to landlords. Additionally, these payments of HB are excluded from the benefit cap calculation.

Supported housing that is not materially different to those in the current definition includes supported housing where care, support or supervision is not provided by the landlord, or on their behalf, and LA provision. We have since been working with those close to the sector to fill in the gaps in our knowledge of its makeup and the extent of its dependency on benefit provision.

These regulations extend that short term protection to a new class of supported accommodation, termed ‘specified accommodation’.

We had also been asked to exempt supported housing from the Removal of the Spare Room Subsidy (RSRS) provisions. Those subject to RSRS will not be affected by these changes.

Outline of the changes

It is important to be clear that no change has been made to the definition of ‘exempt accommodation’ in the Housing Benefit Consequential Provisions where it is used to determine that the eligible rent is calculated using the pre 1996 rules.

The amendments are intended primarily to protect those in supported housing who are not already covered by the definition of ‘exempt accommodation’ (and therefore do not benefit from the current exemptions) and are most likely to be affected by the welfare reforms.

The amendments simply provide a gateway for the housing costs of supported housing that satisfy the definition of ‘specified accommodation’ from being assessed as the housing cost element within UC to HB. There are no changes to the way that the eligible rent is calculated for individual cases within HB.

HB and the benefit cap

There are now 4 categories of supported housing that are included in the new definition of ‘specified accommodation’ being introduced.

Exempt accommodation

The existing exclusion in HB of ‘exempt accommodation’ from the benefit cap is retained as one of the categories in the new definition. This relies on the definition of ‘exempt accommodation’ found in paragraph 4(10) of Schedule 3 to the Housing Benefit and Council Tax Benefit (Consequential Provisions) Regulations 2006.

‘Exempt accommodation’ is defined as being either: a resettlement place; or accommodation which is provided by a county council, housing association, registered charity or voluntary organisation where that body, or person acting on their behalf, provides the claimant with care, support or supervision.

Managed properties

The second category in the draft regulations is designed to cover those cases which fall out of the current ‘exempt accommodation’ definition solely because the care isn’t provided by the landlord or on their behalf. This is often due to the nature of the funding/care structures put in place.

This category relies, as now, on the property being provided by one of the specified social and third sector organisations and on the claimant being admitted to the dwelling to receive the care, support or supervision being provided. This looks to retain the conditionality of receiving support with occupying the home.

It would be expected that the admission process should include the need for care, support or supervision being identified by someone that the LA is satisfied is in a position to undertake it. Linking the person’s admission to supported housing with there being an identifiable need, requires that their occupying the home has been made knowledgeably either by a professional or someone with experience in the care/support sector, which could well be the landlord.

Receiving public funding for the care, support or supervision would be a reasonable indicator that it is both needed and being provided. However, support can still be provided even without public funding. Expert advice should be sought where necessary, such as from statutory authorities or recognised bodies, to confirm whether support should be accepted as provided or not and whether the dwelling is ‘specified accommodation’.

Much supported housing could be identified by it being commissioned by, or either designed or designated as such by local government or other statutory bodies. However, these can only be factors among others in the LA deciding whether the property is ‘specified accommodation’. As ever, the LA must make a decision on the facts.

The underlying assumption is that places in supported housing are in such short supply that someone with no need of their services would not be admitted. Certainly, where it comes to light that a person with no need of care, support or supervision is living in supported housing they cannot be treated as being in ‘specified accommodation’.

We have also added this conditionality to ensure that the legislation doesn’t cover cases of floating support where the property is standard social or third sector housing where the care, support or supervision being provided is not connected with living in the home.

In such cases, where the property has not been specially designed, acquired, adapted or designated to be supported housing, and whether or not the landlord is involved in providing care, support or supervision, we would not expect the rent being charged to be higher than ordinary social or third sector housing and therefore not in need of protection.

Refuges

The third category looks to protect the rents of both third and social sector refuges. This is again achieved through identifying the provider type as well as the reason why the person is living in the property (i.e. that they are fleeing domestic violence) and that this is a temporary arrangement.

The definition for domestic violence we are using is the same as the cross-government definition, with the exception that we do not include the reference to age because UC is available only to those aged 16 or over. The exclusion of the reference to partnership or familial relationships broadens the definition to include other types of violence that may occur in a domestic setting (for example, violence by a neighbour or landlord). This will ensure that the new definition provides protection for as wide a range of provision as possible.

The legislation refers to having ‘left the home as a result of domestic violence’. As a clarification, in this context the meaning is the home where the claimant usually lives and from where they initially fled, rather than any intermediate accommodation, which may well have been another refuge in some cases. All that is required is that there is a causal connection between the claimant being in the refuge and their having left their home as a result of domestic violence.

It has been estimated by stakeholders that around half of refuges currently available are protected because they are ‘exempt accommodation’. The rest are said to be outside the definition because the refuges only manage the properties they use, often for social sector landlords.

Many refuges are likely to already be covered by the first and second categories as this category includes the same types of providers already covered through the first two. However, it also includes LA refuges.

Hostels

The fourth category covers LA hostels that provide care, support or supervision. This relies on the existing definition of ‘hostel’ in Housing Benefit Regulation 2(1) which is currently only used for rent allowance cases. This relies on the property not being self-contained. The existing definition of ‘hostel’ identifies properties specialising in the higher need individuals most likely to need the care, support, or supervision often available in ‘hostels’.

While other hostels providing care, support or supervision will be covered by the first or second categories, this provision extends coverage to include LA hostels, but only where care support or supervision is provided. This is intended to cover the most intensive of provision where claimants are most likely to need protection from the benefit cap and certain aspects of UC.

Benefit cap

Housing costs paid for those in ‘specified accommodation’ will be excluded from the benefit cap within HB.

Frequently asked questions: Specific issues raised since the release of the IT changes

Q1. What management information is DWP planning to generate from the new IT changes?

A1. DWP is currently working to produce some management information (MI) to support the ‘bedding in’ of the new variables; in particular the number of specified/exempt properties.

DWP will continue to review new claims to understand HB expenditure on supported housing and temporary accommodation to help inform future policy decisions. DWP will continue to review the MI and decide how best to share information with LAs.

Q2. What is the requirement for LAs to identify ineligible service charges for care, support and supervision?

A2. Where applicable, the ineligible service charges DWP is asking LAs to provide are those related to the care, support and supervision which satisfies the specified accommodation definition, in other words, provided by or on behalf of the landlord.

In line with the Housing Benefits 2006 Regulations, LAs are required to identify ineligible service charges such as ‘personal care or general support/counselling services’ when calculating the eligible rent and must be satisfied that the cost of providing care, support and supervision is funded from a source outside of HB.

Q3. If we must identify the care, support and supervision charges outside the rent charge, can DWP confirm there is a legal gateway to allow us to collect this data?

A3. As you are aware, an LA must be satisfied that the cost of providing care, support and supervision is funded from a source outside of HB. We have consulted with our data protection colleagues and can confirm that LAs are legally able to collate care, support and supervision data and have always been legally able to share relevant HB information such as ineligible service charges.

Q4. What if we are unable to provide the information on the amount of ineligible service charge for SHBE?

A4. We appreciate that information on the amount of ineligible service charges is not always routinely gathered. Where this is not possible, the field for SHBE should be left blank. However, LAs should continue to make every effort to complete this field.

Q5. Will we get New Burdens for the ongoing maintenance of the property register?

A5. No, the concept of the property register was put forward by LA IT software suppliers to support LAs inputting the data onto their HB systems to make it quicker, easier, and more consistent. This should enable greater automation of the ‘front end’ IT systems saving on input and safeguarding accuracy. If LAs do not choose to use the property register, then they can populate the fields manually. However, the use of the property register by LAs is not mandatory.

Q6. Will the use of property register impact our Rent Officer referral process for supported housing claims?

A6. Having consulted with all LA IT software suppliers, we can confirm that the property register will not impact the Rent Officers’ rent referral process. Any issues an LA may have with the property register should be raised with their IT software supplier in the first instance.

Q7. Does any of the activity related to the new IT changes attract New Burdens funding?

A7. We have provided New Burdens funding for LAs to undertake corrective action on exception reports and populating the new data requirements for new claims going forward.

Q8. What will happen to existing supported housing and temporary accommodation cases that arise as a result of the new IT changes?

A8. Initially, this solution is about ensuring new claims are recorded accurately. However, the LA IT software suppliers will be looking to migrate data currently held to populate new IT system fields where possible. Where the information is rejected due to incompatibility with new functionality or validation rules, cases will fall into an exceptions report for LAs to action separately.

Q9. What is happening about the existing caseloads and are there plans to do a caseload review?

A9. LAs will not be expected to take any action on existing claims at this time unless they wish to do so. DWP will provide a further update on how we progress this.

Q10. Can an accommodation be both temporary accommodation and supported housing?

A10. Where an LA has housed somebody to discharge any of the LA’s functions under Part II of the Housing (Scotland) Act 1987, Part VII of the Housing Act 1996 or Part 2 of the Housing (Wales) Act 2014, or to prevent the person being or becoming homeless within the meaning of Part II of the Housing (Scotland) Act 1987, Part VII of the Housing Act 1996 or Part 2 of the Housing (Wales) Act 2014; the case should be marked as temporary accommodation except where the accommodation is exempt accommodation.

Where the accommodation is also supported housing, the appropriate marker would depend on whether the accommodation is on a temporary basis. In general, we would expect an LA to mark these cases following the same classification used to claim subsidy.

Q11. If an LA inadvertently made an error in the figure they recorded in the ineligible service charge field, could this lead to a subsidy penalty for when accounts are audited?

A11. If an LA inputs an incorrect figure in the ineligible service charge field, this may well impact the HB award calculation and, therefore, lead to an incorrect HB award. However, this will be dependent on how your IT software suppliers have implemented the new IT changes.

It is worth noting that auditors will look to ensure an HB claim has been assessed accurately, therefore if an ineligible service charge has been applied incorrectly, this would lead to the same conclusion irrespective of whether it is recorded on the HB IT system or held clerically.

1. Paragraph 3 (4), Part 1, Schedule 1 of the Housing Benefit Regulations 2006 ↩

2. Paragraph 3 (2), Part 1, Schedule 1 of the Housing Benefit Regulations 2006 ↩

3. Paragraph 3 (1), Part 1, Schedule 1 of the Housing Benefit Regulations 2006 ↩

4. Regulation 12 (8) of the Housing Benefit Regulations 2006 ↩

5. The Universal Credit (Transitional Provisions) and Housing Benefit (Amendment) Regulations 2013, SI 2013/2070 ↩