Managing Discretionary Housing Payments

Institute of Revenues Rating and Valuation www.irrv.org.uk [email protected]

Managing Discretionary Housing Payments

Louise Freeth FIRRV Change and Service Development Manager

Liberata


One thing I don’t have……….


Agenda

•  What has changed over the past year?

•  Current challenges.

•  Where do we go from here?


What’s changed/not -‐ Funding

•  DWP set their limit annually; •  LA allowed to spend 2.5 Hmes this; •  Large increases from April 13 due to welfare reforms;

•  £60 million to £155 million naHonally; •  AddiHonal £5 million found;

– 21 least densely populated areas; •  AddiHonal £20 million “reserve” funding found


AllocaHon

2013/14 2014/15 Baseline £20 million £20 million LHA reforms £40 million £40 million “Bedroom tax” £30 million plus £55 million

£5 m for some areas £5 million £20 m “reserve” funding

Benefit Cap £65 million £45 million


Welfare Benefit Cap set to cost more than it saves……..


Regulatory issues •  No definiHon in law of further financial assistance; •  The need to have a consistent approach in decision making;

•  Need to consider each case on its merits; •  What consHtutes housing costs?

–  ShorZall in rental liability; –  Rent in advance; –  Rent deposits; –  Other lump sum payments such as removal costs or furniture packs;

•  Weekly limits vs non-‐weekly limits.


AdministraHon issues •  Only LA’s can accept claims not via DWP; •  Who or which department administers DHPS •  When can claims be made? •  Method of payment; •  Changes of circumstances; •  Stopping DHP awards early;


AdministraHon issues

•  Fraud prevenHon; •  Overpayment of DHP – not the same as overpaid HB.

–  Only opHon is to recover as a civil debt normally by using Sundry Debt invoice.

•  Increased volumes – New claims – Changes of circumstances – Disputes


InformaHon and Evidence

•  Must supply enough informaHon to enable a decision; •  Income and expenditure (disregards?) •  Unavoidable costs such as fares included? •  Treatment of expenses – what is fair •  HB/CT Support informaHon used •  Proof of other circumstances •  What will happen under UC with verificaHon?


Overlapping Funding •  Watch for the overlaps:

–  Rent deposits v Rent deposit schemes; –  Homeless funding

•  Specifics e.g. furniture packs to move to secure tenancies

–  Troubled Families funding –  Is the HB correct?

•  Bereavement and affordability protecHon cases; •  Benefit on two homes

–  S13(a)(1)(c ) –  CTR Hardship funds –  Short Term Benefit Advances –  Local Welfare Provision.


ConsideraHons

•  Changes during the last year – CondiHonality

•  Builds on ethos of UC but maybe difficult to apply

– Length of awards •  TradiHonally short term now possibly longer

– Re-‐applicaHons •  Increased checking/resources

–  InnovaHve ways of making awards –  Income Disregards

•  The moral dilemma of disability benefits


Judicial Review

•  Sandwell’s policy challenged •  DLA taken into account as income •  Disabled couple challenge:

–  Equality Act –  Human Rights Act

•  Permission granted January 2014


ReporHng Measures – April 2013

•  Increased audit arrangements from April –  First period spanned 1st April 2013 – 30th September 2013 –  Second period covered whole year.

•  Must consider why extra funding provided •  Need to record overriding reason:

–  Benefit cap –  Bedroom Tax –  LHA reforms –  CombinaHon of reforms –  No impact


Monitoring DHP budget Under each heading LA’s should also record expected outcome:

•  To help secure and move to alternaHve accommodaHon (e.g. rent deposit)

•  To help with short-‐term rental costs while the claimant secures and move to alternaHve accommodaHon

•  To help with short-‐term rental costs while the claimant seeks employment

•  To help with on-‐going rental costs for foster carer •  To help with on-‐going rental costs for disabled person in

adapted accommodaHon •  To help with on-‐going rental costs for any other reason


December 2013 report findings

Propor%on of LAs providing

data

DHP commi6ed spending

(Apr-‐Sept 13) £

DHP alloca%on 2013/14

£

Commi6ed spending as % of alloca%on

England 85% 44,172,164 118,282,644 37%

Wales 86% 2,849,943 6,231,201 46%

Scotland 88% 7,286,664 12,320,214 59%

Great Britain 85% 54,308,771 136,834,059 40%

51% of awards due to the “bedroom tax” 93% of commimed spend due to this welfare reform

DWP analysis of mid-‐year returns.


Meanwhile 2014 •  DWP PDT team visiHng approx 10 LAs •  10 areas being reviewed:

–  Policy –  Procedures – Monitoring above –  Process flow –  Training –  Budget –  ApplicaHons –  Learning –  Good PracHce –  Case Studies


Lord Freud Evidence to Work and Pensions commimee 12th February 2013

•  Last year, we had £12 million come back from councils. •  This year 86 bids for the £20 million addi?onal funding

•  We had a £20 million bidding fund for those councils that need extra resources, and we have had 86 bids for that. Interes?ngly, we did not receive bids that added up to the total that we had put aside. We were under-‐bid on that amount, but we have been distribu?ng those funds to those councils. I cannot say absolutely everyone got them, because we are finalising the thing, but my assump?on would be that all of the councils who applied would have.

•  £12,888,307 awarded –  Birmingham largest award £1,310,000 –  Fylde smallest award £10,000


Lord Freud Evidence to Work and Pensions commimee 12th February 2013

•  Our policy to help disabled people, par?cularly with adapted houses, is to provide discre?onary housing payments. Clearly, we are making sure in guidance that that availability will be for a reasonable length of ?me. I am not saying forever, but it will be long term.

•  Where it is clearly impossible for a husband and wife to share a room, we would expect them to get a DHP fall back.


26th March 2013


Findings

•  Described as “transiHonal protecHon” – Welcome but….

•  DiscreHonary –  A post-‐code lomery –  Differing prioriHes –  Amaching condiHons to awards –  Some are taking Disability Benefits into account –  Temporary in nature


RecommendaHons

•  More specific guidance •  Stronger guidance •  Less frequent applicaHons •  Long-‐ term awards for specific categories of claimants •  Long term awards for those who cannot adjust to the reforms

•  Announce 3 year funding •  Look at alternaHve means of support


The Future ……….

•  Funding 2015/16?

•  Universal Credit –  Pathfinders are already paying DHP claims

•  A radical overhaul?

•  A naHonal scheme?


Regional Differences •  Scotland – Scopsh Government pledged to use DHP funds to cover en?re shorZall from SSSC –  Added £20 million to the £15m DHP fund in 2013/14. –  Needs to add further £15m but limited by the 2.5 Hmes cap.

–  Requested that cap is liqed but DWP not yet responded.


•  Wales – Welsh Government pledged an addiHonal £1.3 million funding for 2013/14

•  Examining possibility of a naHonal scheme –  Based largely on model already operated by one Welsh LA

–  Providing support but also soluHons to underlying problems


•  Immediate engagement via Triage/face to face interacHon – Moving to smaller/cheaper property – Money/debt advice –  Input from housing opHons –  Local Welfare Funds –  Financial advice and support –  Discussion with landlord

•  Fail to engage – sHll consider DHP

•  CollaboraHve approach


Latest DWP Good PracHce Guidance Manual

•  Referrals to debt/employment advice agencies

•  Discussions with neighbouring LAs where “exporHng” claimants

•  Discuss pressure on other internal areas where “imporHng” claimants


Lessons from the LA Pilots

•  Best integrated into iniHal process

•  How will this happen under UC? –  Local Support Services Framework


Thank you

QuesHons?

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Managing Discretionary Housing Payments

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