Updating the Regulations
The means test
The existing means test is based on the eligibility test for Housing Benefit and was designed to target funding on ‘needy’ households. It has long been criticized for being complicated, unfair and, in recent years, out of date. There is an opportunity to adopt a version of the test used to assess entitlement for social care. There would be advantages in aligning the social care and DFG means tests, as having two different tests is extremely confusing. It would also address issues of unfairness in the present test by ignoring earned income and actual housing costs. Aligning DFG and social care eligibility also creates the potential for spend on home adaptations to be considered as part of the proposed ‘care cap’. This is the maximum amount someone must pay towards their care before a local authority takes responsibility. If it encouraged more people to invest in home adaptations and improve their independence, it would be good for the person’s own health and wellbeing and it would potentially reduce domiciliary or residential care costs.
However, aligning the two tests is not straightforward. It could make it more complex, reduce the number who could be passported, and introduce local variation. The alternative option is to update the existing test by: re-establishing the link to Housing Benefit; a new formula for housing costs based on Local Housing Allowance; and updating the passporting benefits.
The option selected will largely depend upon the changes to social care finance in the 2018 Social Care Green Paper. Regardless of which test is used, there is a case for exempting applications for stair lifts and palliative care from means testing entirely due to the savings in health costs associated with preventing falls on stairs and by enabling end of life care at home.
The upper limit
Most local authorities only deal with a handful of large and complex adaptations every year (where the cost of fully meeting the needs of the disabled person exceeds the current limit of £30,000). Though small in number, the time taken to support these cases and find the extra funding can be considerable.
We recommend that the current £30,000 limit be increased in line with inflation, but also recognise that the significant variation in building costs across the country should be factored in. The benefit of proper professional support in successfully delivering these difficult building projects should also be recognised.
But simply increasing the upper limit isn’t enough. There will always be cases that cost more, but which will also deliver better outcomes and return on investment than the DFG alone could be expected to provide. It is crucial that health and social care recognise their responsibilities and jointly fund and develop the best solutions. There is also scope to use personal budgets to provide more tailored solutions.
There is also a need to rectify anomalies in VAT which is charged on ground floor extensions containing bedrooms and kitchens but not on bathrooms.
Services and charges
The DFG is currently used to pay for adaptations to an existing home, often with little consideration about whether a move to a more suitable property would lead to a better outcome. Providing support with the expense of moving can be cost effective and should be included within the list of services and charges that the DFG can support.
- Subject to what is included in the Social Care Green Paper - the DFG means test aligned with that for social care eligibility, but if not, the existing test of resources updated.
- Stair lifts and palliative care cases removed from means testing entirely.
- That the maximum amount of the DFG is raised in line with inflation, with a regional weighting based on building costs and an amount for professional fees.
- That risk-share funds are set up to deal with uneven demand for grants, and that very expensive adaptations are jointly funded by housing, health and social care.
- That the VAT rules are revisited for major adaptations.
- That the guidance is fully revised to reflect new integrated services, the expectations for local authorities and the rights of the disabled person.