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Purpose

This briefing and Housing Assistance Policy (HAP) template (insert link) has been produced by Foundations for use by local authority staff at both local housing authorities (district councils, London boroughs and other unitary councils) and authorities responsible for the provision of social care services (county councils, London boroughs and other unitary councils) to help them write a local Housing Assistance Policy.

The HAP template sets out each of the headings that will be needed to compose and build the content for your local Housing Assistance Policy.

The template sets out several section headings in line with the government guidance to achieve a best practice Housing Assistance Policy. You will find below information to help the author of the Housing Assistance Policy develop and write the content for each section heading.  There are also links which will provide further guidance and good practice examples on some of the sections.

Title of the Policy

The Independent Review of the DFG noted that housing assistance and particularly the DFG was largely a hidden benefit. Local Authorities call their policy under which it is made available a variety of things such as Regulatory Reform Order Policy, Discretionary and Disabled Facilities Grant Policy and Private Sector Housing Policy to name a few. This only serves to obscure access to the benefit further.

The policy needs a clear title with as few words as possible, so it is easy for all readers to understand.  We therefore suggest local authorities adopt the consistent use of the words Housing Assistance Policy used in government guidance.

Before you Start

A good policy must also be an effective policy

Your Housing Assistance Policy will only be as good as the outcomes it generates and the efficiency of the processes it underpins.

This template is to provide you with an understanding how you can link your local Housing Assistance Policy to the strategic outcomes your authority is committed to on the one hand and most effective and efficient delivery of the policy benefits on the other.

Public Sector Equalities Duties

Equality Act 2010

Adopting a local housing policy must be accompanied by consideration of how the policy will affect different sections of your community. Such policies explicitly target older and disabled people and may therefore deemed to have a positive effect on older and disabled people. This does not mean the policy is neutral on other protected characteristics such as ethnicity, cultural background, sexuality, and gender identities.

  • The experience of ageing and disability is different for different sections of your community.
  • The patterns of tenure, the way people view and use their home and the quality of housing is different for different sections of your community.
  • Access to services and appropriate housing is different for different sections of your community.

It is therefore important to carry out an equality impact assessment (EIA) early in the process of reviewing and redrafting your Housing Assistance Policy before a new or adopted policy goes live or is implemented.

1. Introduction

Tell the reader why the Policy has been developed:

  • To detail the application and approval process for DFGs (Disabled Facilities Grant) in accordance with the Housing Grants, Construction and Regeneration Act 1996 (the 1996 Act).
  • To detail the application and approval process and provide flexible and streamlined housing assistance in accordance with RRO (Regulatory Reform Order) powers.
  • To achieve consistency across your area of operation so that the level of assistance is not based on the postcode of where the household lives.
  • If agreed to use a portion of the DFG funding for other social care capital funding purposes (as locally agreed with district councils in two-tier areas)
  • To set out the nature and extent of housing assistance based on the need established priorities and strategic context.

Describe who has developed the policy and the geographical area it will cover:

  • A single authority and if the policy is applicable across the boundaries of the authority; or
  • A partnership of authorities and the policy applies across the geographical area of all the authorities.

Describe what it will achieve:

  • Improve living conditions and enable independent living by the local authority or through a Home Improvement Agency.
  • Provide procedures that are transparent, fair, and efficient mitigating against legal challenges or allegations of maladministration
  • Provide best value for public funds through the operation of customer focused, cost effective and efficient service delivery.

This is the opening section of the policy and should orientate the user to the scope and purpose of the policy.

2. Strategic Alignment

Describe how the policy will contribute towards the fulfilment of the strategic aims, objectives, and priorities for the:

  • local authority – corporate plan priorities,
  • relevant local social and health care strategies and plans,
  • Better Care Fund Plan priorities
  • local voluntary and community sector partners (complementary formal and informal advice and advocacy services).
  • relevant national strategies – National Disability Strategy, White Papers etc.
Describe how the Housing Assistance Policy strategically aligns

The policy needs to be strategic and link to other corporate aims and objectives.

The Foundations Regional Advisors meet regularly with Better Care Fund Managers and are part of the team reviewing the BCF (Better Care Fund) plans. At a local level it is important to establish a joint working relationship and approach to health social care and housing support to improve outcomes for residents through your Housing Assistance Policy and enable the flexibility within the RRO to be used in the best way.

3. Evidence of Need

 

details of the prevailing social and economic conditions, including fuel poverty. Data that provides income, education, employment, community safety and social support e.g., Economic Plans
profiles of the age and health of the local population. Joint Strategic Needs Assessments (JSNA)
data indicating demographic changes and trends. Census
knowledge and understanding of the local housing market. Housing Market Assessments and Local Delivery Plans
stock condition data, including energy efficiency Private Sector Stock Condition Surveys, Home Energy Conservation Act returns, JSNA
complaint data, and customer satisfaction surveys among existing home adaptation clients Your local data
Equality data Equality data will be monitored and collected by most organisations.
Issues of concern raised by partner organisations and other stakeholders Your local intelligence

Consider the following:

  • An analysis of housing markets including any mis-match between supply and demand and questions of affordability;
  • the condition of the housing stock in relation to fitness, decent homes and energy efficiency;
  • the role of housing in community cohesion and the needs of particular sections of the community;
  • other key issues such as anti-social behaviour, neighbourhood renewal, regeneration and low demand and abandonment.
Detail the evidence used to inform the types of assistance in the policy

This section should show what evidence has been used to define the priorities and the type of assistance being used to meet this need.

4. Policy Priorities

For example:

  • Best use of Better Care Fund and Disabled Facilities Grant Funds
  • Improved Housing Stock Conditions
  • Enable Accessibility, Independence, Safety and Comfort

***DIAGRAM***

Describe the policy priorities

This section should include a statement of the key policy objectives which should be narrowly defined. The strategic fit analysis will say how it fits with corporate strategies and objectives described in the strategic alignment.

The policy priorities will need to be reviewed on a regular basis involving residents and partners to make sure it is keeping up with the local situation and addressing customer need in the best way.

 

5. Funding

At the current time, an annual government BCF (DFG) allocation is received. The policy should describe this funding. It should explain the level of money has increased over the last 5 years based on the government knowing the vital role DFG’s play in person-centred integrated care, with housing, health and social care and other public services enabling older and vulnerable people to live healthy, fulfilled, independent and longer lives.

  • The amount of capital resources
  • The source and differences by tenure that will be committed to implementing the policy:
    • Central DFG (Better Care Fund) – Explain that it is an annual allocation with the last value of allocation received. Provide information on the levels of government funding received over the last 5 years and the on-going government commitment.
    • Detail of the council’s general fund committed to the delivery of the housing assistance
    • Detail of any other funding sources – specific grants from government or partners
  • Explain that Mandatory DFG’s are not reliant on funding being available.
  • Explain that the Discretionary Funding is reliant on the funding being available.

Where long-term commitments are not known, include a mechanism for reviewing and amending the policy.

Describe the funding source and amount available for the assistance provided in the policy.

In this section describe how much capital funding is being committed to the policy, and what is the source of the funding.

 

6. Summary of Assistance

Provide a description of the:

  • Types of assistance available
    • Preliminary information and advice/triage process
    • Minor Adaptations if applicable,
    • Mandatory Adaptations,
    • Discretionary,
    • Loans
    • Other
  • The circumstances in which people will be eligible for assistance
  • What the assistance will be used for:
    • purchase a new home (whether within or outside their area) where the authority either purchases their existing home or is satisfied that purchasing a new home would provide a similar benefit to adapting to their current home.
    • adapt or improve their home (including by alteration, conversion, enlargement, or installation of equipment or insulation).
    • repair their home.
    • demolish their home and build a replacement.
  • what key outcomes will be achieved by each form of assistance fulfilling corporate and the Better Care Fund outcome measures.
Give a Summary of the Types of Assistance Available

This section is a summary of the types of assistance available fulfilling one of the RRO conditions and can be included as an appendix to your policy and formatted within a table. This can be developed as the easy read version for your residents.

7. How to Apply for a Disabled Facilities Grant

describe the method of applying for mandatory assistance. It should be clearly set out, including:

  • Describing if there is an on-line and hardcopy application form – the process should not restrict applicants with no internet access or reduced literacy skills.
  • Is there advice and assistance for those who may struggle to apply and how is this accessed or who have questions about the policy or processes?
  • Give a detailed explanation of the means test that will be undertaken and any passporting arrangements.
  • Explain the two eligibility elements necessary and appropriate and reasonable and practicable that must be satisfied to apply for a DFG (Disabled Facilities Grant):

Necessary and Appropriate

Remember the DFG legislation does not specify that an Occupational Therapist needs to be used in every DFG case to assess if the adaptation is necessary and appropriate.

(Process – Link to  OT Triage Tool and Adaptations Without Delay Rachel)

 

The OT/Trusted Assessor need to consider whether adaptations:​

  • Are needed for a care plan that will enable the disabled occupant to remain living at home as independently as possible​
  • Would meet, as far as practicable, the assessed needs of the disabled person​
  • Distinguish between what is desirable and what is actually needed​

 

Housing authorities themselves must decide what action to take on the basis of that advice and therefore the type of adaptations, if any, for which grant is approved (2015 Guidance​). This is where effective joined are working process are needed and/or an integrated team to support delivery of a seamless process to the applicant.

 

“Needed” can be funded by the DFG. Desirable should also be discussed and may be possible using a discretionary grant or other funding sources.

 

Reasonable and Practicable

If the therapist/trusted assessor/other nominated person can demonstrate that it is necessary and appropriate for a customer to apply for a DFG, a referral is made to the Adaptations Team.  The Adaptations Team will then determine whether it is reasonable and practicable to proceed with the application.

There are situations where these two conditions cannot be met, and therefore the provisions of the RRO may be used to provide the needed flexibility to the traditional DFG arrangements.

  • Give any relevant timescales for the return of the application should be stated, and consequences if the application is not made in time or with the correct information
  • Describe the list of documentation that is required e.g. (Who does this quickly – RA question).

 

TABLE 2

Proof of ownership of all land and buildings pertaining to the application from a solicitor or mortgagee, or copies of the sale deeds/land certificate. Effective process – Link to good practice examples (Dan).

Question for RA

Copy of the Tenancy Agreement of License to Occupy. Effective process – Link to good practice examples (Dan).

Question for RA

Proof of occupation and or tenancy where applicable. Effective process – Link to good practice examples (Dan).

Question for RA

Proof of qualifying passporting benefits being claimed. Effective process – Link to good practice examples (Dan).

Question for RA

Where no passporting applies full financial documentation including but not limited to income received, benefits received, savings/pensions and where applicable rental income from tenants and boarders. Effective process – Link to good practice examples (Dan).

Question for RA

Where applicable permission of co-owners and landlords. Effective process – Link to good practice examples (Dan).

Question for RA

A VAT exemption form where the applicant or relevant person is registered disabled or capable of being registered. Effective process – Link to good practice examples (Dan).

Question for RA

A signed conditions form accepting the obligation to repay the assistance in the event of any breach of the relevant conditions concerning future occupation, letting or ownership. Effective process – Link to good practice examples (Dan).

Question for RA

If required, permission under any statute including but not limited to, planning permission, building regulation approval, party wall act etc. Effective process – Link to good practice examples (Dan).

Question for RA

 

  • Any relevant timescales for the return of the application should be stated, and consequences if the application is not made in time or with the correct information.
  • Any relevant timescales for the return of the application should be stated, and consequences if the application is not made in time or with the correct information.
Describe the application processes for a mandatory DFG

A good policy will need to be supported by straightforward procedure and process for it to be effective and achieve the required outcomes. The links above will provide examples where the approach to collecting the required paperwork has been done in an effective and efficient way. This can often be the longest part of the DFG (Disabled Facilities Grant) application process.

Foundations also provide a DFG Quality standard self-assessment tool. This sets out what good should look like by taking little pieces of good practice and fitting them together like a jigsaw puzzle to build the bigger picture. (Dan Insert link to the DFG Quality Standard)

8. How to Apply for Other Forms of Assistance

Clearly set out:

  • Describing if there is an on-line and hardcopy application form – the process should not restrict applicants with no internet access or reduced literacy skills.
  • Is there advice and assistance for those who may struggle to apply and how is this accessed or who have questions about the policy or processes?
  • Give a detailed explanation of the means test/process for agreeing a loan that will be undertaken and any passporting arrangements.
  • Explain how to access an Occupational Therapy/Trusted Assessor or other assessment if this is required and not integral to your service model.
  • Describe the list of documentation that is required e.g., see TABLE 2.
  • Provide details if applicants are not obliged to use the services of the council or its appointed agent and how this is dealt with and any related fee’s.
  • Any relevant timescales for the return of the application should be stated, and consequences if the application is not made in time or with the correct information.
  • Please note that the RRO imposes that before making a loan, or requiring repayment of a loan or grant, the authority must have regard to the person’s ability to afford to make a contribution or repayment. If they are not in such a position then assistance by some other means, such as grant, would be necessary.
Describe the application process for the discretionary types of assistance and loans

The policy should describe the method of applying for all types of discretionary assistance and loans.

Be mindful that a good policy does not need to be complicated with numerous different types of grants. Consider establishing either theme based or sector based discretionary assistance which is flexible to use in meeting a range of need when creating section 9 below. The new government guidance provides a good explanation of this (insert link at page X)

9. Forms of Assistance

For each type of grant include the following sub-headings with a full description within each:

  • Name of Grant
  • Purpose of Grant
  • Eligibility Criteria
  • Qualifying Criteria
  • Conditions
  • Level of Grant
  • Discretion
  • Obligation to use the service or not
  • Any relevant timescales for the applicant and the council/appointed agent

For example:

Disabled Facilities Grant
Purpose
  • Getting in and out of the property​
  • Making the property safe(r) for everyone living there​
  • Access to the living room​
  • Access to a bedroom​
  • Access to a toilet​
  • Access to a bath or shower​
  • Access to a wash basin​
  • Preparing and cooking food​
  • Improving or providing heating if needed by the disabled person​
  • Controlling power, lights and heating​
  • Access around the property to care for someone else​
  • Access to the garden​
Eligibility Criteria

Describe the circumstances in which persons will be eligible for assistance.

Qualifying Criteria

Is a referral from an Occupational Therapist or a Trusted Assessor required confirming that the works are necessary and appropriate?

Conditions

The details of conditions that will apply to the provision of assistance, how conditions will be enforced and in what circumstances they may be waived.

Maximum Amount of Assistance

The amounts of assistance that will be available to eligible persons, and how these amounts will be determined.

Discretion

The details of the discretion that will apply on cases that fall out of the grant assistance and policy.

Obligation to use the service

Describe whether the applicant is obliged to use the service or not and what this involves.

Timescales

 

 

Examples of grants offered elsewhere:

Mandatory Disabled Facilities Grant Discretionary Insulation/Health through Warmth Grant Discretionary Condition Specific Grants – Challenging Behavior/Autism Interest Bearing Repayment Loans
Waiving the means test Discretionary Palliative Care Grant Discretionary Condition Specific Grants – Dementia Interest-only Loans
Pooled Funding for Capital Projects etc. Discretionary Relocation Assistance Discretionary Condition Specific Grants – Motor Neurone Disease Zero-interest Loans
Discretionary Fast Track Adaptation Discretionary Home Safety Grant Discretionary Smart Home Kits
Comprehensive Details of the Financial Assistance

This should be split into sections covering the mandatory, discretionary and loan assistance and will be a way of carrying out your checks and balances.

 

10. General Terms and Conditions

Any person who makes an application for Assistance must;

  • Be over 18 years of age at the date of the application
  • Live in the dwelling as his/her only main residence and
  • Have an owners interest in the dwelling (other than by virtue of being a Registered Social Landlord under Part 1 of the Housing Act 1996 or being eligible for such registration) or be a tenant or licensee of the dwelling, alone or jointly with others but not being a member of the landlords family, with a tenancy or license permitting occupation of the dwelling for a minimum period of 12 months after approval of the Assistance, and
  • Have the power or duty to carry out the works and where appropriate have the owner’s consent in writing to carrying out the works, and
  • Satisfy such test(s) of resources as the council, or statute, may from time to time have in place
  • Not be ineligible, by virtue of the Housing Grants, construction and Regeneration Act 1996, regulations made under the Act or any other enactment
  • Homeowners have the primary responsibility for ensuring their homes are properly maintained and in the first instance should pursue private finance. We may assist eligible, vulnerable homeowners to make sure they have the opportunity for achieving the correct property standards.

 

Where an owner occupier has given a signed undertaking to occupy a property as his/her principle residence after completion of the assisted works for a period of time, and if they cease to do so during that time, they will repay on demand to the council the total amount of Assistance paid out.

Where a landlord (or owner) has given a signed undertaking that the property will be available for letting for a period specified after completion of the assisted works, and if the landlord ceases to make the relevant property available for letting during the specified period then the landlord will repay on demand to the council the total amount of Assistance paid out.

Where the council has the right to demand repayment but extenuating circumstances exist, the council may determine to waive the right to repayment or to demand a sum less than the full amount of Assistance paid out.

11. Fees and Charges

This section needs to include a short explanation of your fees and charges and how these will range for applicants not using all parts of the service.  Under The Housing Renewal Grants (Services and Charges) Order 1996 DFG can be used to pay for:​

  • Confirming ownership of the property​
  • Building surveys​
  • Preparing drawings​
  • Preparing specifications​
  • Help to complete forms​
  • Advice on other funding​
  • Planning and Building Regs applications​
  • Obtaining estimates​
  • Advice on contracts​
  • Supervising the works​
  • Connecting services; and​
  • Paying contractors

12. Supervision of Works

In the absence of any agency agreement with the council or its appointed Agent, the responsibility for supervision of the works rests with the applicant or with any suitably qualified and indemnified building professional or agent acting on the applicant’s behalf and not with the council.

All work must be undertaken;

  1. In accordance with manufacturers recommendations and best practice.
  2. In accordance with and to the satisfaction of the council.
  3. In accordance with building, planning and installation regulations where applicable and Health and Safety regulations.

Payment of grant/assistance will be made, in whole or by part payments, on receipt of contractor’s invoice following satisfactory completion of the eligible work as determined by the council’s Officer or its appointed Agent.

13. Decisions and Notifications

 

14. Complaints

 

This section of the policy should provide details of how any complaints about the policy can be made. Often this is through the council’s corporate complaints scheme. If the policy is being administered through a third party, like an HIA, then clear delineation about who has responsibility for the complaint may need to be considered, within the governance arrangements. Any complaint process will need to detail an applicant’s ability to approach the local government ombudsmen as the final stage.

 

15. Cases Outside of Policy

The policy will need to describe the arrangements for applications for assistance to be considered where these fall outside policy.  Councils must not fetter their discretion by creating an inflexible policy. While it is legitimate to refuse assistance to someone who clearly falls outside the policy, all applications should be considered on their merits, and there should be a provision within the policy which allows the council discretion in exceptional circumstances.

 

16. Service Standards

Describe the key service standards that will apply to the provision of assistance e.g., how long it will take to approve an application for assistance once submitted, how long it will take for assistance to be completed once approved.

 

17. Performance

This section should show the local performance indicators and targets that will be used to measure the progress made by policy implementation towards meeting the authority’s strategic aims, objectives and priorities and the fulfilment of corporate strategies.

 

18. Implementation

The final section should describe the policy’s’ implementation plan:

  • How the policy been consulted on with partners and the public
  • The formal mechanism for endorsement and date of policy commencement
  • The methodology for monitoring the policy performance and targets and how this will be reported and publicised
  • The frequency the policy will be reviewed and the circumstances that might necessitate an earlier review of the policy document.