Managing Housing Benefit Claims in Supported Housing | Part E: Tools and Appendices
This appendix turns Chapter 13 into two working checklists:
- Part A, the provider version: what to put in a scheme evidence pack before the first claim at a scheme.
- Part B, the council version: the questions the Housing Benefit team answers from that pack, where to look first, and what a proportionate answer looks like.
Part C is a one-page record sheet for the council’s scheme file. Both parties can use the same item numbers, so that “complete” means the same thing to each.
How to use the checklists.
- Once, then reviewed. Scheme evidence is provided once, kept on the scheme file and reviewed annually or when something changes. It should not be requested again with every claim (Chapter 13).
- Reasonably required. Every request is made under regulation 86(1) and must be “reasonably required” (Chapter 12, 12.1). The checklists are a menu, not a minimum: ask only for what the scheme’s facts make relevant.
- Council records first. Information the council can find for itself, on public registers or from its own commissioning and housing options teams, should not be counted against the claimant (Kerr v Department for Social Development [2004] UKHL 23, para 63).
- No single item decides entitlement. A missing item is a reason to ask, not a reason to refuse. Each claim is still decided on its own facts (DWP guidance, para 210).
- Confidentiality. Lease and financial information can be commercially sensitive. Councils should hold it securely and limit who sees it, in line with the UK GDPR and the council’s records policy (Chapter 12, 12.6).
- SHP’s position. One agreed pack, shared once and reviewed together, is the most effective way for councils and providers to reduce delay, cost and dispute. It is a tool for agreement, not a test to be passed.
Part A: Provider version (scheme evidence pack)
Tick each item as it is added to the pack. Mark items that do not apply “N/A” with a short reason. Send changes without waiting to be asked.
A1. The landlord and its governance
| No. | Item | What to include | Review | Done |
|---|---|---|---|---|
| A1.1 | Register entries | Links to the landlord’s entry on the RSH list of registered providers, the Charity Commission or OSCR register, Companies House or the FCA mutuals register, as applicable | Annually | ☐ |
| A1.2 | Constitution or articles | Current version, highlighting objects, the asset lock and any restriction on distributing profits | On change | ☐ |
| A1.3 | Accounts | Latest filed accounts, or a summary for smaller bodies; a scheme budget for a new provider | Annually | ☐ |
| A1.4 | Related-party statement | Payments to directors, trustees and connected parties, and how they are approved | Annually | ☐ |
| A1.5 | Governance statement | Board members, relevant skills, how conflicts are managed, and any regulatory findings or notices (one or two pages) | Annually | ☐ |
| A1.6 | Why not registered | For an unregistered housing association only: a short explanation (DWP guidance, para 98) | On change | ☐ |
A2. The property and lease arrangements
| No. | Item | What to include | Review | Done |
|---|---|---|---|---|
| A2.1 | Property schedule | Each address, number of units or bedspaces, shared facilities, and the owner of each property | On change | ☐ |
| A2.2 | Lease schedule | For each lease: start date, length, rent, uplift basis, repairing obligations and break clauses | On change | ☐ |
| A2.3 | Representative lease | A copy of a typical lease, plus each lease whose terms differ materially | On renewal | ☐ |
| A2.4 | Connected parties statement | Any connection between the landlord and the owner or its directors, and how conflicts are managed (para 131) | On change | ☐ |
| A2.5 | Management agreement | Where a managing agent is involved: a copy, showing that the landlord keeps control, including over setting rents (para 132) | On change | ☐ |
| A2.6 | Tenancy or licence | The standard agreement used at the scheme, showing liability for rent and each service charge | On change | ☐ |
A3. Care, support or supervision
| No. | Item | What to include | Review | Done |
|---|---|---|---|---|
| A3.1 | Client group and referral routes | Who the scheme is for, typical needs, and how tenants are referred and assessed | Annually | ☐ |
| A3.2 | Referrals framework | Confirmation that the scheme works within the council-approved referrals framework, including emergency and self-referral routes (Chapter 14) | Annually | ☐ |
| A3.3 | Service description | What care, support or supervision is provided, by whom, how often and how it is linked to the accommodation, including intensive housing management and maintenance where relied on (Chapter 7) | Annually | ☐ |
| A3.4 | Staffing | Roles, numbers, hours, training and qualifications (para 154), and how time is split between eligible and ineligible activities (Chapter 9, 9.3) | Annually | ☐ |
| A3.5 | On-call and out-of-hours | What cover is provided and how quickly staff respond. This is supervision (Chapter 6, 6.6) | Annually | ☐ |
| A3.6 | Third-party support agreement | Where another body provides support on the landlord’s behalf: the contract or service level agreement and how it is monitored (para 139) | On renewal | ☐ |
| A3.7 | Funding of ineligible support | Where any ineligible care or personal support is provided: who funds it and how (paras 160 to 162 and 187). If none is provided, say so | Annually | ☐ |
| A3.8 | Support records format | A blank copy of the needs assessment, support plan and activity log used at the scheme (Appendices 6 and 7) | On change | ☐ |
A4. Rent and service charges
| No. | Item | What to include | Review | Done |
|---|---|---|---|---|
| A4.1 | Rent and service charge build-up | The Appendix 8 template, from actual or budgeted scheme costs, separating core rent from each service charge (para 168) | On increase, annually | ☐ |
| A4.2 | Eligibility schedule | Each service charge marked eligible or ineligible, with the reason (Chapter 9) | On change | ☐ |
| A4.3 | Apportionment method | How mixed costs, usually staff time, are split, and evidence that the method is applied consistently (Chapter 9, 9.3) | Annually | ☐ |
| A4.4 | Year-on-year comparison | On a rent increase: what has changed since last year and why (para 238) | On increase | ☐ |
| A4.5 | Comparators | Optional: any comparable schemes the provider relies on, with what makes them comparable (Chapter 10) | On increase | ☐ |
A5. Commissioning and local fit
| No. | Item | What to include | Review | Done |
|---|---|---|---|---|
| A5.1 | Commissioning agreements | Any contract, grant or service level agreement with a council, NHS body, probation or other commissioner. Commissioning is helpful, not required | On renewal | ☐ |
| A5.2 | Referral or nomination agreements | Agreements with housing options or other referral agencies | On renewal | ☐ |
| A5.3 | Local strategy | How the scheme meets local need, for example under a temporary accommodation to exempt accommodation strategy or the local supported housing strategy | Annually | ☐ |
| A5.4 | Letters of support | Optional: from a council team or partner agency | On change | ☐ |
A6. Property compliance
| No. | Item | What to include | Review | Done |
|---|---|---|---|---|
| A6.1 | Compliance schedule | For each property: gas safety record, electrical installation report, fire risk assessment, alarms, and HMO licence where required, with dates. Copies on request | Annually | ☐ |
| A6.2 | Licensing and standards | When in force: supported housing licence number or application date, and how the scheme meets the National Supported Housing Standards (Chapter 13, 13.7) | On change | ☐ |
Covering note. Send the pack with a short covering note that lists the schemes covered, names a contact, and confirms that the provider will notify the council of material changes. State which items are commercially sensitive.
Part B: Council version (scheme file review)
Work through the questions in order. Record the outcome as Met, Query (with the question raised) or N/A. Where the answer is Query, use a single consolidated request (Chapter 12, 12.4 and Appendix 9) rather than separate requests.
B1. Is the landlord a qualifying body? (Chapter 5)
| Ref | Question | Look first | Pack items | Outcome |
|---|---|---|---|---|
| B1.1 | Which category of landlord is it: council, registered housing association, unregistered housing association, registered charity or voluntary organisation? It only needs to fall within one (para 107) | Public registers (paras 97, 99, 104 and 112) | A1.1 | |
| B1.2 | If a housing association or voluntary organisation, is it not-for-profit? Look for an asset lock, no dividends and no disguised payments of profit (para 105). Registration does not guarantee it (para 106) | Companies House filings; Charity Commission accounts | A1.2 to A1.4, A1.6 | |
| B1.3 | Are bona fide commercial arrangements with third parties being mistaken for profit-making by the landlord? They do not defeat the test (Wirral BC v MF) | Accounts | A1.3, A1.4 |
B2. Does the landlord provide the accommodation and control it? (Chapters 5 and 11)
| Ref | Question | Look first | Pack items | Outcome |
|---|---|---|---|---|
| B2.1 | Does the landlord have the legal relationship with the tenant, as owner or leaseholder (paras 89 to 90)? | Tenancy or licence | A2.1, A2.6 | |
| B2.2 | Does the landlord keep a landlord’s usual control, including setting its own rents, or does the owner exert excessive influence (para 132)? | Lease and management agreement | A2.2, A2.3, A2.5 | |
| B2.3 | Are there connected parties, and are conflicts managed (para 131)? | Companies House | A2.4 | |
| B2.4 | Is the lease-based model being used in a way that raises genuine concern, judged on its terms, not its label (FYE, para 11)? | Lease schedule | A2.2, A2.3 |
B3. Is care, support or supervision provided by or on behalf of the landlord? (Chapters 6 to 8)
| Ref | Question | Look first | Pack items | Outcome |
|---|---|---|---|---|
| B3.1 | What care, support or supervision is provided, including housing-related support, supervision, on-call cover, and intensive housing management and maintenance? | Service description | A3.3, A3.5 | |
| B3.2 | Is it provided by the landlord or by a third party engaged by the landlord, not merely a joint venture (para 140; R(H) 2/07)? | Contract or SLA | A3.6 | |
| B3.3 | At scheme level, is the support more than minimal, judged on its substance, with no set number of hours (para 151)? Claimant-level need and receipt are checked under Chapter 14 | Service description and staffing | A3.3 to A3.5 | |
| B3.4 | Are tenants referred and assessed within the council-approved referrals framework, with self-referrals limited to emergencies and hard to reach cohorts? | Council’s housing options and commissioning teams | A3.1, A3.2 | |
| B3.5 | Is any ineligible care or personal support provided and, if so, how is it funded (paras 160 to 162)? No notional deduction applies where the support relied on is eligible intensive housing management and supervision (Chapter 3, 3.4.1) | Commissioning records | A3.7 |
B4. Are the rent and service charges eligible and reasonable? (Chapters 9 and 10)
| Ref | Question | Look first | Pack items | Outcome |
|---|---|---|---|---|
| B4.1 | Is there a current build-up separating core rent from each service charge (para 168)? | Scheme file | A4.1 | |
| B4.2 | Is each charge correctly classed as eligible or ineligible under Schedule 1, including housing-related support, supervision and help with Housing Benefit as eligible (Chapter 9)? | Build-up | A4.2 | |
| B4.3 | Is the apportionment method reasonable and consistently applied (Chapter 9, 9.3)? | Build-up | A4.3 | |
| B4.4 | Is any eligible charge excessive, judged on evidence rather than on the absence of comparables (ET v Rossendale)? | Build-up and any comparators | A4.1, A4.5 | |
| B4.5 | Is the rent unreasonably high compared with suitable alternative accommodation, using true comparators, with local indicators used as triggers, not caps (Chapter 10)? | Council’s comparator evidence | A4.1, A4.5 | |
| B4.6 | On an increase, is it justified on the year-on-year comparison, judged in cash terms, and has a lesser increase been considered (para 238; BM)? | Previous year’s build-up | A4.4 |
B5. Commissioning, local fit and compliance (Chapters 13 and 22)
| Ref | Question | Look first | Pack items | Outcome |
|---|---|---|---|---|
| B5.1 | What does the council already know about the scheme from commissioning, housing options and licensing colleagues (paras 149 and 209)? | Internal teams | A5.1 to A5.3 | |
| B5.2 | Is a compliance schedule in place? Concerns go to private sector housing or environmental health, not into the entitlement decision (Chapter 22, 22.3) | Council’s licensing and HMO records | A6.1 | |
| B5.3 | When licensing is in force: is the scheme licensed or covered by a valid application (Chapter 13, 13.7)? | Licensing register | A6.2 |
What the council should not ask for. None of the following is a legal requirement, and none should hold up a scheme file:
- proof that support is commissioned or funded from outside Housing Benefit
- a minimum number of support hours, or on-site staff
- a full copy of every lease where a schedule and a representative lease answer the question
- the full scheme pack again with each new claim, unless something has changed
- documents the council already holds or can find on a public register
Part C: Scheme file record sheet
The council completes this sheet and shares a copy with the provider, so that both hold the same record of what has been agreed.
| Field | Entry |
|---|---|
| Scheme name and provider | |
| Addresses and number of units | |
| Client group | |
| Provider contact | |
| Council named officer | |
| Date pack received | |
| Items outstanding (Part A numbers) | |
| Queries raised (Part B references) and date | |
| Date scheme file accepted | |
| Agreed position: landlord status, care, support or supervision, eligible charges, rent | |
| Commercially sensitive items and who may see them | |
| Next review date, or trigger (rent increase, new property, change of model) |
Recording the agreed position. Once the scheme file is accepted, later claims at the scheme start from the agreed position. The council can still depart from it on new evidence, but should say what has changed (Chapter 19).
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Next: Appendix 5: Claimant Evidence Checklist
This template is licensed under CC BY 4.0: you can adapt it, with credit to SHP. See Rights and licence. Supported Housing People Ltd, Version 1.0, October 2026.