A List of Routinely Eligible Intensive Housing Management Tasks & Functions
Updated November 2023
In May 2022 the DWP issued “Housing Benefit guidance for supported housing claims“. This Guidance is important in that it places the emphasis for eligibility for enhanced Housing Benefit on specifically property-related tasks and functions.
It also provides an inexhaustive list of what it deems to be eligible tasks, which I have added to my longstanding list below, to the extent to which both lists have different items.
Please be mindful that just because a task, activity or function is listed here it doesn’t necessarily mean that a local authority Revenues & Benefits Team will agree to fund it, or even agree that it’s eligible in principle. Different authorities take different views, but what I have listed below are things that are routinely accepted as eligible.
Enhanced Housing Benefit for Intensive Housing Management is a complex area. It’s based on regulation and case law and is subject to change. Landlords seeking Enhanced Housing Benefit to fund Intensive Housing Management services must comply with the Exempt Accommodation rules. The amounts claimed should reflect the reasonable costs of providing eligible services to people who have been genuinely assessed as needing Intensive Housing Management.
Claims for Enhanced Housing Benefit are rightly subject to scrutiny by local authorities, and the level of scrutiny is increasing as a consequence of abuses of the system by some unscrupulous individuals and organisations. The National Statement of Expectation for Supported Housing (England only) encourages local authorities and their strategic partners to ‘manage the supported housing market’. In practical terms this involves ensuring the quality of supported housing providers and controlling Enhanced Housing Benefit costs.
In May 2022 the DWP published “Housing Benefit Guidance for Supported Housing Claims“. This guidance has led to increased levels of srutiny of enhanced Housing Benefit claims and a stricter interpretation of eligibility, such that the emphasis is very much on property-specific tasks and functions.
This revised guidance also needs to be seen in the context of the UKUT hearing Allerdale BC v JD, the summary of which states: “What constitutes “general counselling or..any other support services” within paragraph 1(f) of schedule 1 to the HB Regulations 2006 must be assessed with regard to the legislative history of that provision. There is no automatic linkage between schedule 1(f) and the definition of “exempt accommodation” in the HB and CTB (Consequential Provisions) Regulations 2006.” In other words the term “support” does not necessarily have the same meaning within each of those separate regulations, such that “support” within the meaning of “general counselling or..any other support services” is not eligible to funded by Housing Benefit, but that “support” within the definition of exempt accommodation (i.e. “care, support and supervision”) may be eligible, depending upon what that support is.
If you are seeking Enhanced Housing Benefit for Intensive Housing Management you should be an existing, qualifying supported housing provider. If you are a new supported housing provider you should have established referral pathways and be acting with the specific approval of commissioners.
You might be an excellent supported housing provider that provides excellent services to people with additional needs. This doesn’t guarantee that a local authority will agree to pay you Enhanced Housing Benefit, but we can help you in the construction, submission and negotiation of claims.
Intensive Housing Management that is routinely eligible for Enhanced Housing Benefit is split into two broad areas and includes both staff and non-staff costs:
- General needs housing management and maintenance functions that are more intensively provided as a consequence of the additional needs of supported housing residents
- Additional or intensive housing management and maintenance functions and tasks that would not be provided in general needs accommodation where no additional needs exist. Such tasks and functions include but are not limited to:
Intensive Housing Management List
- The provision of an alarm (even though alarms are not HB eligible) or the Housing Proactive system (which is HB eligible. Please ask us about this)
- Controlling access to the premises
- Ensuring rent is paid regularly and on time.
- Explaining the occupancy agreement and assisting people to understand their rights and responsibilities in relation to it
- The additional costs of property maintenance and repair, housing services, furniture, fittings and equipment where the furniture fixtures and fittings do not become the property of the resident
- Offering advice and guidance on keeping property to a reasonable standard of hygiene.
- Liaising with all relevant agencies, both statutory and voluntary, on the tenant’s behalf to the extent that it concerns their ability to maintain/develop independence in relation to their housing.
- Assisting people to reduce rent arrears.
- Dealing with nuisance issues.
- Ensuring that people know how to use equipment safely.
- Providing people with advice and facilitating a move to alternative accommodation as required.
- Assisting people to claim the housing component of Universal Credit
- Helping to keep people safe by monitoring visitors, including contractors and professionals, and by carrying out health and safety, maintenance and risk assessments of property.
- Internet access within sheltered and supported housing.
- Support/IHM worker, concierge, caretaker or warden staff – only allow the proportion of the charge for the time they are providing HB eligible accommodation-related services
- The overhead costs of providing HB eligible services (office costs, IT, travel, telephones, stationary etc)
- Refuse removal of communal bins
- External cleaning of tenant’s windows where the tenant does not live on the ground floor
- Ongoing maintenance (including repair, cleaning and utility) of:
- communal grounds (including basic gardening and lighting for areas of external access)
- communal laundry facilities
- internal communal areas
- cleaning of windows in communal areas and of individual’s accommodation above ground floor level where they are unable to do it
- communal lifts
- communal telephone (excluding the cost of calls)
- secure building access, including entry phones, key-cards and keypad door locking mechanisms
If you do any or all of the above in sheltered and/or supported housing on a “more than minimal” basis and you are an eligible provider (see paragraphs 4 and 8 above) then you should be eligible to claim Enhanced Housing Benefit
If you are a local authority approved supported housing provider and you want advice and assistance in claiming Enhanced Housing Benefit please get in touch.