Annex B
Household Support Fund (1 April 2022 – 30 September 2022): – Draft Guidance for County Councils and Unitary Authorities in England
Introduction
1. £421 million has been made available to County Councils and Unitary Authorities in England to support those most in need to help with significantly rising living costs. This funding covers the period 01 April 2022 to 30 September 2022 inclusive. Local Authorities have discretion on exactly how this funding is used within the scope set out in the accompanying grant determination and this guidance. The expectation is that it should primarily be used to support households in the most need particularly those including children and pensioners who would otherwise struggled with energy bills, food and water bills. Energy bills may be of particular concern to low income households during the period of the scheme and Local Authorities should especially consider how they can support households with the cost of energy. It can also be used to support households with essential costs related to those items and with wider essential costs. In exceptional cases of genuine emergency it can additionally be used to support housing costs where existing housing support schemes do not meet this exceptional need.
2. The Department for Work and Pensions (DWP) is providing funding to County Councils and Unitary Authorities (including Metropolitan Councils and London Boroughs), under section 31 of the Local Government Act 2003, to administer the scheme and provide assistance to households most in need. It is important to stress this covers a wide range of low income households in need including families with children of all ages, pensioners, and other low income households, particularly those who cannot increase their income through work, to prevent escalation of problems. Note: County Councils and Unitary Authorities will be referred to as ‘Authorities’ throughout the remainder of this guidance.
3. Authorities have the ability to deliver the scheme through a variety of routes including providing vouchers to households, making direct provision of food or goods, or issuing grants to third parties (with the exception of grants for advice provision). Authorities have the local ties and knowledge, making them best placed to identify and help those most in need. Authorities must work together with District Councils to ensure the funding meets its objectives by identifying those most in need.
4. This guidance sets out the required collaboration between DWP, Authorities, including their delivery partners, including District Councils as well as any charitable organisations etc, to successfully meet the policy intent within the agreed framework. It also provides the constraints that Authorities need to work within and the distribution of funding and reporting arrangements.
5. Rather than focus on one specific vulnerable group, Authorities should use the wide range of data and sources of information at their disposal to identify and provide support to a broad cross section of vulnerable households to prevent escalation of problems. Authorities should particularly consider how they can support low income households that cannot increase their income through work, such as pensioners, people with disabilities, unpaid carers and parents of very young children in their area. Authorities have access to DWP’s Searchlight portal which provides information on individual citizens’ entitlement to (and confirms receipt of) DWP welfare benefits. Since June 2021 we have provided Authorities with information relating to Universal Credit (UC) claims with limited capability for work or earnings below the free school meals and free prescription thresholds in their area. Authorities may find this information useful in identifying those most in need. DWP will be establishing a further data share covering people receiving the Guarantee Credit and/or Savings Credit elements of Pension Credit.
6. However, support is not restricted to vulnerable households in receipt of benefits. Therefore, Authorities should also use other sources of information to identify vulnerable households, including advice from professionals who come into contact with vulnerable households such as social workers and Supporting Families advisors.
7. This guidance applies to Authorities in England only and should be read in conjunction with the Household Support Fund Grant Determination issued alongside it.
Communication
8. The Authority must, as appropriate and practical, reference that the grant is funded by the Department for Work and Pensions or the UK Government in any publicity material, including online channels and media releases.
Objective and key principles
9. The objective of the Household Support Fund is to provide support to vulnerable households in most need of support to help with signficantly rising living costs.
10. Although this is an extension to the original Household Support Fund, it is a new grant subject to its own grant conditions as set out in the Grant Determination letter. Any underspends from the previous scheme cannot be carried forward.
11. Funds should be spent or committed before 30 September 2022 and cannot be held over for future usage.
12. When administering this scheme, you are encouraged to adopt the following principles:
· use discretion on how to identify and support those most in need, taking into account a wide range of information;
· use the funding from 01 April 2022 to 30 September 2022 to meet immediate needs and help those who are struggling to afford energy, food and water bills, and other related essentials. You can also use the funding to support households who are struggling to afford wider essentials;
· In exceptional cases of genuine emergency, the funding can additionally be used to support housing costs where existing housing support schemes do not meet this exceptional need, subject to the provisions at paragraph 17 below.
· This includes payments made, or committed to, by the Authority or any person acting on behalf of the Authority, from 01 April 2022 to 30 September 2022. For example, this would allow any vouchers issued before the end of the funding period to be redeemed in October 2022. All authorities are encouraged to ensure that any vouchers issued are redeemed before the end of the scheme, or shortly thereafter, or consider recycling unused vouchers;
· work together with District Councils including, where necessary and appropriate, other local services, such as social and care workers to help identify and support households within the scope of the scheme.
13. When deciding how to help people, you should consider:
· how you plan to provide support to vulnerable households, i.e. paying into bank accounts, use of cash and vouchers;
· any risks associated with these payment methods – see section Managing the risk of fraud.
Working with other organisations
14. Authorities should develop a ‘local eligibility framework and approach’ to enable them to distribute grant funding that best supports households most in need. At least one third of the funding is for vulnerable households with children (see the definition of a child under paragraph 22 below and paragraph 5(a) of the Grant Conditions). At least one third of of the funding is for pensioners. The remainder of the funding (up to one third) is available for other vulnerable households (without children or pensioners including individuals).
15. Authorities have flexibility to develop a local delivery approach that best fits the scheme’s objectives. Where Authorities choose to work with multiple organisations to provide a local delivery network or where Authorities engage with District Councils to deliver this grant on their behalf, detailed arrangements and funding should be made available to those organisations as soon as possible so that support for vulnerable households can be provided as soon as is practically possible.
16. Authorities must work collaboratively with District Councils and other organisations in their area who may come into contact with those households who are eligible and would benefit from this grant. Authorities that do not have the mechanisms in place to administer this grant should consider whether District Councils are better placed to do so on their behalf. If Authorities decide to engage with District Councils in this way they are encouraged to do so as quickly as possible to ensure roles, responsibilities and effective arrangements are put in place to deliver the scheme promptly and efficiently. Where Authorities are working with Third Party Organisations (TPOs), this should be done on an objectively fair, transparent and non-discriminatory basis, having regard to the time available to deliver the scheme.
Establishing eligibility
17. Authorities have the flexibility within the scheme to identify which vulnerable households are in most need of support and apply their own discretion when identifying eligibility. In doing so they should particularly consider households who cannot increase their income through work. Authorities can request applications for support or can proactively identify households who may benefit or can take a mixture of the two approaches. Where Authorities are proactively identifying households they should consider how they can ensure that they are focusing on those in the most need to prevent escalation of problems. There is no requirement for Authorities to undertake a means test or conduct a benefit check unless this specifically forms part of the Authority’s local eligibility criteria. However, in relation to housing costs, Authorities must establish whether other forms of support are available to the household, such as Discretionary Housing Payments (DHPs). In accordance with their general legal duties, Authorities must have a clear rationale or documented policy/framework outlining their approach including how they are defining eligibility and how households access the scheme. We expect Authorities to review any existing approach and to have a strong rationale for their targeting so that funding is available to the households who most need it.
18. Awards must be based on the following framework:
· at least one third of the total funding will be ring-fenced to support households with children, at least one third of the total funding will be ring fenced to support pensioners with up to one third of the total funding to other households genuinely in need of support. This may include households not currently in receipt of DWP welfare benefits;
· Eligible spend includes:
o Energy and water. The Fund should primarily be used to support with energy bills for any form of fuel that is used for the purpose of domestic heating, cooking or lighting, including oil or portable gas cylinders. It can also be used to support with water bills including for drinking, washing, cooking, and sanitary purposes and sewerage.
o Food. The Fund should also primarily be used to provide support with food whether in kind or through vouchers or cash.
o Essentials linked to energy and water. The Fund can be used to provide support with essentials linked to energy and water (including sanitary products, warm clothing, soap, blankets, boiler service/repair, purchase of equipment including fridges, freezers, ovens, etc.), in recognition that a range of costs may arise which directly affect a household’s ability to afford or access energy , food and water.
o Wider essentials. The Fund can be used to support with wider essential needs not linked to energy and water should Authorities consider this appropriate in their area. These may include, but are not limited to, support with other bills including broadband or phone bills, clothing, and essential transport-related costs such as repairing a car, buying a bicycle or paying for fuel. This list is not exhaustive.
o Housing Costs. In exceptional cases of genuine emergency where existing housing support schemes do not meet this exceptional need, the Fund can be used to support housing costs. Where eligible, ongoing housing support for rent must be provided through the housing cost element of Universal Credit (UC) and Housing Benefit (HB) rather than the Household Support Fund. In addition, eligibility for DHPs must first be considered before emergency housing support is offered through the Household Support Fund. The Authority must also first consider whether the claimant is at statutory risk of homelessness and therefore owed a duty of support through the Homelessness Prevention Grant (HPG).
§ In exceptional cases of genuine emergency, households in receipt of HB, UC, or DHPs can still receive housing cost support through the Household Support Fund if it is deemed necessary by their Authority. However, the Fund should not be used to provide housing support on an ongoing basis or to support unsustainable tenancies.
§ Individuals in receipt of some other form of housing support could still qualify for the other elements of the Household Support Fund, such as food, energy, water, essentials linked to energy and water and wider essentials.
§ The Fund cannot be used to provide mortgage support, though homeowners could still qualify for the other elements of the Fund (such as energy, food, water, essentials linked to energy and water and wider essentials). Where a homeowner is having difficulty with their mortgage payments, they should contact their lender as soon as possible to discuss their circumstances as lenders will have a set procedure to assist.
§ The Fund can exceptionally and in genuine emergency be used to provide support for historic rent arrears built up prior to an existing benefit claim for households already in receipt of Universal Credit and Housing Benefit. This is because these arrears are excluded from the criteria for DHPs. However, support with rent arrears is not the primary intent of the fund and should not be the focus of spend.
o Reasonable administrative costs. This includes reasonable costs incurred administering the scheme. These include for example:
§ staff costs
§ advertising and publicity to raise awareness of the scheme
§ web page design
§ printing application forms
§ small IT changes, for example, to facilitate MI production
· Eligible spend does not include:
o Advice services including debt advice;
o Mortgage costs.
· It is expected that the focus of support should be on bills and food and that support for housing costs should only be given in exceptional cases of genuine emergency. Beyond this, Authorities have discretion to determine the most appropriate scheme for their area, based on their understanding of local need and with due regard to equality considerations.
· Individual awards can be whatever type and amount is deemed appropriate by Authorities for the receiving household, bearing in mind the overall spend eligibility priorities listed above and the risk of fraud and error. Awards to any given household can either cover only one of the spend eligibility categories listed above, or can cover several.
· Authorities should not make Household Support Fund eligibility conditional on being employed or self-employed, or directly linked to a loss of earnings from employment or self-employment. This will ensure that there is no National Insurance Contribution liability payable on any payments by either the claimant, the Authority or employer.
Funding overlap
19. Authorities should consider household circumstances when making a decision to spend this grant. Households may be receiving other forms of support, and this should be taken into account to avoid duplicating provision where possible. However, families receiving other forms of assistance are not excluded from receiving support through this grant.
Individuals with No Recourse to Public Funds
20. Authorities can provide a basic safety net support to an individual, regardless of their immigration status, if there is a genuine care need that does not arise solely from destitution, for example if:
· there are community care needs
· they have serious health problems
· there is a risk to a child’s wellbeing
21. The rules around immigration status have not changed. Authorities must use their judgement to decide what legal powers and funding can be used to support individuals who are ineligible for public funds or statutory housing assistance.
Definitions
22. For the purpose of this grant (and without prejudice to other schemes):
· The definition of a household with a child is a household containing any person:
o who will be under the age of 19 as at 30 September 2022 or
o a person aged 19 or over in respect of whom a child-related benefit (for example, Child Benefit) is paid or free school meals are provided.
· Where an eligible child lives on his or her own, they are a household that includes a child covered in the one third allocation for households with children.
· The definition of a household with a pensioner is any household containing any person:
o who has reached state pension age by 30th September 2022 (and no eligible children as defined above are resident)
23. Households which include a person aged 19 to 25 with special educational needs and disability (SEND) and/or care leavers may still be eligible for grant support however that support falls within the one third allocation to other households (without children or pensioners).
24. There is no prescriptive definition of essentials. Authorities have discretion to assess what is reasonable to assist those in genuine need this winter with regard to the examples above.
25.Third party organisations may include but are not limited to:
o Registered charities and voluntary organisations
o Schools
o Food banks
o General Practitioners
o Care organisations
Access to data
26. The Household Support Fund is being classified as Local Welfare Provision (LWP). The provision of DWP data to LAs is under the terms of the Memorandum of Understanding (MoU) ‘Department for Work and Pensions and local authorities (Access, handling, exchange and protection of Department for Work and Pensions’ and HM Revenue and Customs’ data)’.
27. Local authorities who have signed and returned the relevant section (Annex C) of the current DWP/LA MoU have legal permission to access DWP’s Searchlight portal and specific UC data via a monthly data share for the purpose of this grant.
28. LAs will need to ensure they sign future iterations of the MoU and the appropriate Annex to continue to have the legal permission to access the below data sources for Local Welfare Provision.
29. Staff accessing Searchlight will need to be registered with the Employee Authentication System (EAS). Further information on Searchlight can be found in the local authority Searchlight Training Pack available in the Searchlight folder on Glasscubes (the LA/DWP online collaboration tool). If your Authority needs to discuss access to Glasscubes, contact DWP at LAWELFARE.LASUPPORT@DWP.GOV.UK
DWP Searchlight
30. This portal provides information on individual citizens’ entitlement to (and confirms receipt of) DWP welfare benefits. Therefore, this data can be used to help Authorities identify those families and individuals to whom to target this support. Authorities may also wish to establish if other forms of support are available to the household. In relation to housing costs they must do so including by checking whether the household could receive Discretionary Housing Payments The Authority must also first consider if the claimant is at statutory risk of homelessness and therefore owed a duty of support through the Homelessness Prevention Grant (HPG).
31. Authorities do not have permission for the purposes of this scheme to access the ‘Income’ data provided on Searchlight for the Test and Trace Support Payment Scheme.
32. Searchlight can only be used to verify a specific individual’s DWP benefit information. Therefore, if an Authority identified a group of potential customers who may be eligible for the scheme from their own records, they can access Searchlight to verify each claimant’s DWP benefit entitlement (although benefit entitlement is not a condition of support).
UC data share
33. We are providing Authorities with details of UC claimants in their Authority whose income is below the Free School Meal and Free Prescription thresholds for both individuals and summary level by Ward. We are also providing Authorities with details of UC claimants with a limited capability for work both at individual level and summary level by Ward. The data is provided monthly via Transfer Your File.
34. We are also providing 2 UC claim data shares on a monthly basis.
File one – contains the National Insurance number of Universal Credit (UC) claimants within the LA area and:
· income below the thresholds of £7,400 per year for Free School Meals and income below the Free Prescription threshold of £935 per month as identified in their last UC assessment period;
· those with a Limited Capability for Work indicator within the last assessment period; and
· the number of children in the household.
File two – contains aggregate data showing those people at or below the:
· Free School Meal income threshold;
· Free Prescription income threshold; and
· are in the Limited Capability for Work group.
For a full breakdown of the file contents see Annex B
35. Authorities also have access to their own non-DWP data to help identify vulnerable households who may be eligible for support under this scheme.
Reporting requirements
36. Authorities are required to make two Statements of Grant Usage and management information (MI) returns – see the Grant Determination. The deadline for completing these returns is shown in the table below. Completed MI returns should be sent to LAWELFARE.PDT@DWP.GOV.UK
37. An interim MI return is required by 22 July 2022 for spend for the period 01 April 2022 to 30 June 2022. The interim MI return will be used to determine eligible spend to 30 June 2022 and an interim grant payment will be made to your LA for this period when the information in your return has been verified.
38. A final MI return is required showing total spend from 01 April 2022 to 30 September 2022 by 21 October 2022. The final MI return will be used to determine total eligible spend to 30 September 2022 and a final grant payment will be made to your Authority for this period when the information in your return has been verified.
39. Authorities should use the standard MI reporting template provided, which incorporates the Statement of Grant Usage. For the purpose of this section:
· Grant allocation – refers to the amount of grant allocated to a TPO to distribute to vulnerable households.
· Grant award or spend refers to the amount provided or paid to vulnerable households under the remit of this grant.
|
Reporting period |
Deadline |
||
|
Interim MI return |
From: 01 April 2022 |
To: 30 June 2022 |
Deadline: 22 July 2022 |
|
Final MI return |
From: 01 April 2022 |
To: 30 September 2022 |
Deadline: 21 October 2022 |
40. It is the responsibility of Authorities to provide the MI returns to DWP. Failure to return the MI by the deadline may result in a delayed payment or a payment being refused.
41. Where Authorities (including District Councils) issue awards directly to vulnerable households they should either obtain information at source or via information or data they have access to, to complete the split of spend and number of awards across the eligibility criteria. i.e. households with and without children and pensioners and food, energy bills, essentials linked to food and energy bills, wider essentials and (in exceptional circumstances) housing support. Where Authorities decide to deliver support to vulnerable households through TPOs they should use whatever information the TPO holds, or other available data, to split the level of spend and volume of awards across the eligibility criteria to the best of their ability.
The different elements of the MI template are shown below together with guidance on how to complete them.
 |
Table 1
42. Each MI return must include your Section 151 Officer’s name and email address to provide assurance on validation of funding spend. If they are the same contact, please input details in both response fields.
43. We also require you to copy your Chief Financial Officer/Section 151 Officer into the email, providing this assurance when you return the MI template to DWP. This will be checked against DWP records. By doing this you confirm that the S151 Officer has agreed the correctness of spend reported.
44. Please indicate that you have done this in row 4 of the table “Is the section 151 officer / CFO copied into the return to DWP?”If the MI is incomplete/incorrect it will be returned to the authority by the DWP for correction and re-submission which must also be copied to your Chief Financial Officer/Section 151 Officer.
Table 2
· Total Amount provided to vulnerable households – this is the total amount of the grant fund that has been paid/awarded to vulnerable households. It includes amounts paid by Authorities and by TPOs on behalf of Authorities. It should not include amounts allocated to TPOs that have not been spent during the reporting period. This cell will automatically populate from the total in table 3. Note, all cells which automatically populate are shaded grey and are protected.
· Administration costs – this includes reasonable costs incurred administering the scheme. These include for example:
o staff costs
o advertising and publicity to raise awareness of the scheme
o web page design
o printing application forms
o small IT changes, for example, to facilitate MI production
· Total Spend – this is the total of the above. It is the amount that will be used to determine the grant funding payment, from DWP to cover the full cost of administering the grant in your area. A single grant payment will be made in arrears on the receipt of a fully completed and verified MI return. This cell will automatically populate from the figures in rows a and b.
Table 3
45. Table 3 relates to grant spend and the volume of awards made in relation to families with children, pensioners and all other housholds. Rows 1 and 2 relate to grant awards made by Authorities (including District Councils) directly to vulnerable households, and grant awards to vulnerable households made by TPOs.
46. Spend (£s) - this is the amount paid/awarded to vulnerable households within the eligibility criteria. Authorities should make every effort to gather information to establish the household type. For example for Households with children whether a child resides in the household (including being the only member of the household) in order to complete the template as fully as possible. This information is important for DWP to evaluate how successful the scheme has been in providing support to households with and without children.
47. Authorities should either gather information or check existing records they hold or have access to, to establish whether the household includes a child or a pensioner (as defined above) and complete columns a b and c accordingly. Responsibility for MI reporting rests with Authorities. Where Shire Counties pass grant allocations to District Councils, District Councils should pass the information relating to columns a and b to the County Council/Unitary Authority to collate the information and send one collated template to DWP.
48. Where a household includes both a child and a pensioner, for the purpose of the MI you should count it as a household containing a child.
49. Volumes - this is the number of individual/separate payments made to vulnerable households within the eligibility criteria. If multiple awards are made to the same household throughout the period of the scheme each award should be counted separately. Where an award is made to a household with multiple children, it should be classed as a single award.
50. Reporting TPO Spend and TPO Volumes - we acknowledge that some TPOs, for example, charitable and voluntary organisations such as food banks, have limited or no access to household information and may not be in a position to provide this information to the same level of accuracy as Authorities. We are therefore asking Authorities and TPOs to report the actual level of spend and the volume of awards across the different eligibility criteria in rows 1 and 2 to the best of their ability.
Table 4
51.Table 4 relates to grant spend and the volume of awards made in relation to food, energy and water bills, essentials linked to energy and water bills, wider essentials, and (in exceptional circumstances) housing costs.
52. Spend (£s) - this is the amount paid/awarded to vulnerable households in respect of each category.
53. Volumes - this is the number of individual/separate payments made to vulnerable households within the eligibility criteria. If multiple awards are made to the same household throughout the period of the scheme each award should be counted separately.
54. Rows 1 and 2 relate to awards/payments made directly to vulnerable households by Authorities including District Councils and grant funding spent by TPOs e.g. charitable and voluntary organisations.
55. TPO Spend and TPO Volumes - we acknowledge that some TPOs, for example, charitable and voluntary organisations have limited MI and may not be in a position to provide this information to the same level of accuracy as Authorities. We are therefore asking Authorities and TPOs to provide, the level of spend and the volume of awards across the different eligibility criteria in rows 1 and 2 to the best of their ability.
56. Total - Table 3 Row 1 column c and Table 4 row 1 column e are protected and will automatically add up spend across the different headings. This figure will automatically populate Table 2 row a.
57. When allocating spend and the volume of awards across the eligibility criteria please follow the guidance below.
58. Table 3 and Table 4 ask for spend and award volumes to be recorded against two sets of criteria. Therefore, the details of each award need to be recorded twice once against one set of criteria and then a second time against the other criteria. Shown below is a worked example of how the MI template should be completed.
59. The eligibility criterion is set against the category of spend, at least one third for households with children and at least one third for pensioners. We are collecting information on food, energy and water bills, essentials linked to energy and water bills, wider essentials, and (in exceptional circumstances) housing costs to provide ministers and interested bodies (e.g. the National Audit Office) assurance over how the Household Support Fund is being spent.
60. Authorities are asked to report and manage spend in relation to both these areas. For example, if a £100 award is made to a household with children for food, you would allocate £100 to the ‘Households with children’ section in Table 3 and £100 to the ‘food’ section in Table 4. You would also allocate one award in both these sections of Table 3 and Table 4.
61. Each award needs to be allocated twice – one allocation to each of the eligibility category tables so that when you report on the total spent on family composition and the total spent on the type of support, both eligibility criteria categories will total the amount you have paid. The total volume of awards in Table 3 and Table 4 should also be the same.
Additional guidance and examples when working with TPOs
62. Please include, where possible, the amount of spend across the following categories:
· households with children, households with pensioners, other households, and
· energy and water bills, essentials linked to energy and water bills, wider essentials, and (in exceptional circumstances) housing costs.
63. For example, if you have allocated:
· grant funding to a food bank to provide food to vulnerable people, establish the amount of that allocation the food bank has spent and enter the full amount spent under food as you know that the grant allocation has been spent in respect of food, and provide the split across households with and without children to the best of your ability in accordance with the example below.
· grant funding to a charity that specialises in providing vulnerable children with clothing, establish the amount of that allocation the charity has spent and enter the full amount spent in ‘households with children’ and the full amount of the grant spent in ‘wider essentials’. This is because you know that the purpose of the grant is for children and the nature of support is clothing which comes under wider essentials.
64. The amount of MI available will vary considerably across each TPO. Please use whatever information is already available or reasonable to collect to be as accurate as possible.
65. Shown below are some examples of how to complete the template.
Example 1
66. A food bank operates on an open basis where anyone can turn up and pick up food and supplies. This is not an award made directly to vulnerable households by an Authority. The cost is picked up by a TPO, for example, the food bank. The MI template should be completed as per guidance below.
67. The total value of grant spent and the volume of awards made by the charity or voluntary organisations providing the food bank should be entered in Table 3 and Table 4. The Authority or food bank provider will need to provide the split between households with and without children to the best of their ability.
Example 2
68. The Authority directly provides vouchers to vulnerable households. These could be redeemable at a number of food outlets including supermarkets or food banks. Food voucher amounts can vary depending on how many children reside in the household. Authorities are expected to collect or verify information to establish whether the award is made to a household with or without children. The MI template should be completed as follows:
· the value of awards should be entered in Table 3 in ‘spend’ row 1 column a and row 1 column b based on the information the Authority has been capturing to split spend across these categories;
· the volume of awards should be included in Table 3 row 2 (Volumes) column a and row 2 column b based on the information the Authority has been capturing to split the volume of awards spend across these categories;
· the value of awards should be entered in Table 4 row 1 column a because it relates to food;
· the volume of awards should be included in Table 4 row 2 (Volumes) column a because it relates to food;
DWP engagement
69.LA relationship managers from DWP’s LA Partnership, Engagement and Delivery division will contact Authorities to provide support and gather information throughout the scheme. Examples where LA relationship managers will contact Authorities for initial compliance include:
· the MI templates have not been completed and returned;
· the MI templates have not been copied to the Authority’s S151 officer or CFO.
· An incorrect template has been used – MI should only be returned on the MI template provided no local versions or PDF copies are acceptable.
70. They will also contact Authorities where further clarification is needed in respect of the information provided on the MI reporting template, if for example:
· critical data is missing, or the data looks odd, or
· the Authority is reporting a high value of awards where they have not been able to establish the household composition. We may need the Authority to explain why that is the case and provide supporting evidence.
· the Authority is reporting a high value of administration costs. We may need the Authority to explain why that is the case and provide supporting evidence.
· there is a significant gap between actual and allocated spend. We may need the Authority to explain why spend was so low.
71. They will look to identify good practice and identify case studies where appropriate.
72.They will also engage with Authorities around completion of the questionnaire issued with this guidance regarding delivery plans for the grant. Please complete and return this questionnaire to DWP by 29 April 2022. At the end of the scheme we will also ask for a summary of spend against the original delivery plan.
73. DWP will also continue to engage with Authorities to respond to questions we receive via the designated inbox as quickly as possible.
74. Where Authorities work with District Councils and TPOs it is the responsibility of Authorities to collect and collate MI and complete one collated MI return and submit to DWP.
DWP funding arrangements
75. The Household Support Fund is ring-fenced to be spent as detailed in this guidance and the accompanying grant determination, including the specific condition that at least one third be spent on families with children and one third to be spent on pensioners. To ensure that the objectives of the fund are being met during the course of the grant and reduce administration costs for all concerned, including the need for DWP to recover underspend, grant payment will be made in arrears upon DWP being satisfied with the MI returns. This will enable DWP to adjust the amount of the payment based on the MI returns.
76. Payment of the grant from DWP to Authorities will be made in arrears after the interim MI return in July 2022 and the final MI return at the end of grant period in October 2022 after we have verified the MI. If an Authority feels that the payment arrangements will create significant cash flow problems please notify DWP as soon as possible with supporting evidence. Both an interim and a final MI return will be required and grant payments will be made in respect of the periods 01 April 2022 to 30 June 2022 and 01 April 2022 to 30 September 2022.
77. MI returns must be endorsed by the S151 officer in accordance with their statutory assurance responsibility in order for the grant payment to be made by copyingyour Chief Financial Officer and Section 151 Officer into the email.
78. The guidance for completion is provided on a separate tab within the MI template.
79. The definition of spend includes grant funding that has been provided to vulnerable households, within the scope of the eligibility criteria, and within the period of the scheme 01 April 2022 to 30 September 2022.
80. Spend also includes ‘committed spend’. For the purpose of this scheme committed spend relates to grant funding that has been spent and delivered to vulnerable households even though the vulnerable household may not have used their grant funding. An example would be the award of a food voucher on 30 September 2022 to a vulnerable household. It would be unreasonable to expect the family to be restricted to redeem the voucher on the day of receipt. In this example spend has been committed by the Authority, support has been provided to a vulnerable household and, therefore, should be included as eligible grant spend. It would be reasonable to expect the vulnerable household to redeem the food voucher during the month following the end of the scheme.
81. However, committed spend does not include large volumes of food vouchers, procured quite late in the scheme, which cannot be distributed to vulnerable households within the period of the scheme.
82. Authorities that plan to order vouchers in bulk should attempt to be realistic in the volumes ordered to avoid holding large stocks of unused vouchers at the end of the scheme. Alternatively, Authorities may want to consider:
· purchasing vouchers on a sale or return basis, so that they can return any unused vouchers, or
· if the Authority wants to use the vouchers after the end of the Household Support Fund scheme they should be funded through other means.
83. The definition of committed spend for the purpose of this scheme does not affect its accounting treatment in accordance with normal rules.
84. The timetable for provision of funding and MI returns is as follows:
Funding:
|
Payment |
Amount (%)
|
Date |
Notes |
|
Interim |
Actual grant spend up to 100% of grant allocation* |
August/September 2022 |
Payment made in arrears |
|
Final |
Actual grant spend up to 100% of grant allocation* |
December 2022 /January 2023 |
Payment made in arrears |
*subject to eligible spend criteria
Managing the risk of fraud
85. Fraudsters can target funds of this type.
86. As with any welfare payment to vulnerable recipients there is a risk of fraud, as recipients might appear to be eligible when they are not.
87. To help mitigate this risk, Authorities should involve District Councils and other organisations chosen to administer this scheme to help identify vulnerable families, households and individuals.
88. Authorities wishing to work with TPOs to deliver the scheme must carry out suitable due diligence checks to ensure they are viable and able to deliver the support. So, for example, ensuring all charities are registered and taking extra caution if they are new organisations.
89. Authorities are also encouraged to ensure checks are in place to verify the identity of those eligible.
90. Authorities are encouraged to ask neighbouring authorities to work together to help prevent double provision and/or no provision – especially where allocation of provision is by school in one area and by residential address in another.
91. It is for Authorities to decide how payments are made to recipients. However, when making decisions, Authorities should consider the risks involved. Although they still carry fraud risks, vouchers should be used instead of cash where possible as this helps to mitigate the risk of the money being spent by the recipient on things outside of the policy intent.
92. Authorities should ensure that they consider and put in place suitable controls when making use of vouchers as part of this scheme. Authorities may wish to consider restricting access to these vouchers; and also consider restricting usage to ensure that they cannot be spent outside the intended scope of this Scheme.
93. It is important to be vigilant to fraud and error risks in relation to housing costs, and to assure yourself that the appropriate checks are in place. Authorities should take appropriate steps to ensure they take into consideration household income and rent liability which may be requested and reviewed as set out in paragraphs 17 and 18 of the grant determination. We expect Authorities to work with district councils to ensure support is going to those with genuine need and to help minimise the risk of fraud on housing support.
94. Where possible, any payments made into a bank account should be in the same name of the person that is eligible for that payment. Authorities have access to a range of data sources, and checks can be carried out against this data to verify the identity of the recipient. Authorities are also encouraged to use existing tools at their disposal to verify personal bank accounts.
95. If the Authority has any grounds for suspecting financial irregularity in the use of any grant paid under this Determination, it must notify the department immediately, explain what steps are being taken to investigate the suspicion and keep the Department informed about the progress of the investigation. For these purposes ‘financial irregularity’ includes fraud or other impropriety, mismanagement, and the use of grant for purposes other than those for which it was provided.
96. If you suspect fraud, you should notify DWP of the:
- number of instances
- total amount lost
97. This will help DWP identify any emerging threats and share them with other Authorities, so they can take steps to prevent and detect any fraud in their schemes.
Complying with Subsidy (previously State Aid) rules
98. The funding is intended to benefit households most in need of support with food, energy bills, related essentials, wider essentials and (exceptionally) housing costs as the economy recovers this winter. The funds should not be used for any economic undertaking.
99. Whichever way you use the funding, including where you work in partnership with others, you should consider all Subsidy rules (previously state aid) issues. Check whether the ‘de minimis’ regulation exception applies. You should also follow government procurement procedures where relevant.
Administration costs
100. The Household Support Fund funding allocation includes reasonable administration costs to enable Authorities to deliver the scheme. Authorities should deduct their administration costs from the total allocation to determine the amount remaining.
101. In all cases, Authorities should keep administrative costs to a reasonable level.
102. Administration costs for each Authority will be published on www.gov.uk alongside detail of all spend related to this scheme.
Public Sector Equality Duty
103. In accordance with the public sector equality duty, DWP has had due regard for the potential equalities impacts of this grant.
104. Under the Equality Act 2010, all public authorities must comply with the Public Sector Equality Duty. For the purposes of this grant, you should consider how any support that helps people facing severe financial hardship impacts those with characteristics protected under the Equality Act.
105. When developing your local delivery frameworks, you should ensure people are not disadvantaged or treated unfairly by this scheme. For example, any application process should be easy to access and to navigate.
Questions and answers
106. Questions and answers can be found at Annex A
Contact
107. If you have any queries about the content of this guidance or use of the funding, you can contact DWP: LA-PED.LAGRANTSPROJECTTEAM@DWP.GOV.UK
108.
Annex A
Questions and answers
Q1. Why is DWP asking County Councils and Unitary Authorities to administer this instead of District Councils?
A1. County Councils and Unitary Authorities have a statutory duty regarding children and are generally responsible for Local Welfare Assistance. This is not to suggest that District Councils are not capable of delivering support. It reflects the focus of this grant and that support could take many, broad, forms and, therefore, the funding sits better with County Council and Unitary Authorities.
We require County Council and Unitary Authorities to work with their district partners, particularly in relation to any support exceptionally provided with housing costs, as well as other organisations, as appropriate, to ensure the most effective support is delivered to as many vulnerable households as possible.
Q2. Is it acceptable to use the grant funding for Free School Meals?
A2. The Household Support Fund is not intended to replicate or replace Free School Meals and Authorities should avoid duplicating provision where possible.
However, Authorities have discretion over how they use the funding within the grant framework and within the stipulated time period.
Therefore, Authorities may choose to offer awards to families in receipt of Free School Meals if they consider this to be appropriate in their area. In doing so, Authorities should take account of provision available through the Department for Education’s Holiday Activities and Food programme.
Q3. Can the Scheme be used flexibly for more strategic activity such as advice provision around financial hardship?
A3. Advice provision is not included in the scope of this scheme.
Should Authorities choose to fund advice as part of their support they must do so through means other than the Household Support Fund.
Q4. Can we make multiple awards to the same people or families?
A4. A family or individual can be supported on multiple occasions throughout the lifetime of the scheme, should an Authority deem it to be necessary. However, each award should be reported separately. Although multiple awards to the same households are possible, funding should not be used to support unsustainable tenancies. Where eligible, ongoing housing support should be provided through the housing cost element of Universal Credit and through Housing Benefit – and if needed, through Discretionary Housing Payments.
Q5. Can Searchlight information be used by Authorities to help identify suitable recipients?
A5. Searchlight can only be used to verify a specific individual’s DWP benefit information. Universal Credit award information is available on Searchlight. Therefore, if an Authority identified a group of potential claimants who may be eligible for the scheme from their own records, they can access Searchlight to verify those claimants’ DWP benefit details.
DWP is sharing UC data with LAs each month which LAs can use to identify vulnerable households eligible for payments under the Household Support Fund.
Q6. Does there need to be a complaints and appeals process?
A6. The appeals process falls within each Authority’s normal complaints and appeals process. Authorities will be responsible for making determinations on eligibility and as such will need to decide how they administer any complaints or appeals.
Q7. Are there any other sources of guidance?
A7. DWP will continue to update a comprehensive Q&A log based on questions raised by Authorities. This will be reissued in due course.
Q8. Why can’t we carry over funding from the previous Household Support Fund?
A8. DWP’s funding for the original Household Support Fund was a separate grant and the grant period for that grant ended on 31 March 2022. Funding cannot be carried forward into the new grant period.
Q9. How should Authorities reporting funding which goes to a household that includes a child and a pensioner?
A9. This funding should be reported under ‘Households with Children’.
Q10. Can more than one third of funding be spent on households that include a child or on households that include a pensioner?
A10. Yes, at least one third should be spent on each of these groups, but more than this proportion can go to these groups if necessary.
Annex B
* Please note that the Data Share Field Definitions document will be updated and circulated when the new data items are confirmed.