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9.1.9 Provider Services - Management of Service Users Money, Valuables and Financial Affairs

POLICY

To ensure that Residential Provider Services, Learning Disability Accommodation Services, and Independence at Home have procedures in place to assist and support service users who may need help in managing their financial affairs including having access to money as required.

DELEGATION

  • The responsibility for deciding if staff should become involved with a service user's finances will be agreed as part of a person's support plan in discussion with them, their representative, Care Manager/Care Support Manager and the Resource Officer, Operations Manager. The responsibility for checking documentation is with the Unit Manager or delegated Senior Care Officer/Care Support Manager;
  • The responsibility for declining personal gifts and bequests, and for disclosing details of any bequests or gifts, is with all staff - see Gifts to Staff Procedure.

AUTHORITY TO VARY THESE INSTRUCTIONS IN INDIVIDUAL CASES ONLY

  • The authority to vary these instructions in individual cases only is with a Head of Service.

AMENDMENT

This chapter was amended throughout in December 2014 as a result of local review and should be re-read in its entirety.


Contents

  1. Initial Considerations
  2. Procedures
  3. Dos and Don'ts

    Appendix 1: Dealing with Service Users Finances (Service Variation)

    Appendix 2: Financial Profile (Non-LD)

    Appendix 3: Financial Care Plan (LD)

    Appendix 4: Financial Care Plan (Independence at Home)

    Appendix 5: Service User Money Request Form (LD)


1. Initial Considerations

1.1

Introduction

  Whenever possible service users should be encouraged to manage their own finances. It is recognised that some service users will need support to do this. Their needs can vary from a person needing assistance to get to and from bank / post office to a person lacking capacity to deal with any financial transactions. For people living in the community supported by Independence at Home, service users (or their relatives) typically manage their own money, and support from workers is limited to providing practical support when they are unable to go out to shop or do other transactions in person (e.g. HCSW take custody of cash to go shopping, pay bills etc and then returning change, or bring back money from cashed cheques.)

1.2

Capacity

  It should always be assumed that a service user has capacity to manage their own finances, and they have the right to make unwise decisions regarding money. However, consideration should be given to a person's mental capacity to manage their own finances. If there are concerns, the person should be assessed in line with Mental Capacity Act principles, and appropriate action taken to minimise any risks.
  If it is assessed that somebody lacks capacity to deal with financial transactions and there is not an Enduring/Lasting Power of Attorney in place, the person may need to have a court appointed Deputy. This may be a family member / friend / Solicitor, or, in some circumstances, the Council.

1.3

Options for Supporting Service Users to Manage their Finances

1.3.1

Service Users With Capacity

A normal bank account in the service users name Service Users would need to have capacity to manage their own bank account. This would be assessed (informally) by the bank when they go in to open an account.
  Service Users could authorise for other signatories on their account. This can be useful where Service Users may be unable to get to the bank due to illness.
1.3.2

Money Advice and Case Work Services (MACS)

Service users living in the community in rented accommodation (e.g. extra care housing at New Larchwood), may be able to access support with their finances through the MACS (Supporting People Contract).
1.3.3

Service Users Without Capacity

Bank account with Managers as authorised signatures

Though this is historically in place for many services most banks will not open an account using this system anymore based upon the fact that an individual should have capacity to open a bank account, in which case the account would be in their name and managed by them as described above.

  If the bank does agree to setting up this type account it must have 2 authorised signatories on the account and be managed in accordance with LDAS Finance policy.
1.3.4

An Appointeeship (for Benefits)

This is where someone is an appointee on behalf of the Service User and the money they receive in benefits. An appointee can be a relative and/or the council. An appointee only has formal authority to deal a person's benefits, and not any other income, accounts or property.
  In order to create an appointee, an application (Form - BF56) needs to be made to Department of Work and Pensions (DWP). Once agreed, the individual’s benefits can then paid into a nominated account that the appointee accesses on behalf of the individual. This account does not have to be in the Service Users name, it could be in their relatives name but it must be managed separately from the relatives own funds. For a relative to become an appointee the DWP usually undertake a home visit.
  Where there is no other person willing or able to become Appointee, and the person is resident in a care home, the Council will act as a Corporate Appointee. The (residential) Financial Assessment team arrange for Angie Emerson or another team member to sign the BF56 form on behalf of the council.
  When the Council is the corporate appointee a personal code will be set up in the council’s accounting system (Authority Financials) and the person's benefits will be paid by DWP into the council's bank account and into the personal code. The person will have access to their weekly personal allowance via the Safe Custody Account. There is no charge for these accounts, but the account does not receive interest.
 

When spending money from a Safe Custody Account, items can be coded via the imprest account to the account where petty cash money is used. Invoices can also be paid against the account using authority financials creditors system. Care charges can be charged to the account by the finance team. If the person requires additional monies from their safe custody account, cash can be requested via the creditors team who will release up to £400 per month and arrange for it to be delivered by courier service with 5-7 days notice.

Expenditure from the safe custody account can be looked up on authority financials. However, services should keep their own records of monies spent and received.
  If the service user is living in registered care they will have a nominated financial assessment officer who will assist with the management of the account. Those in supported living will not have a nominated assessment officer.
1.3.5

Deputy

This is used when individuals have money in an account that cannot be accessed for whatever reason. It requires an individual to apply to be the Deputy to then be able to access the funds. An alternative option in this case is applying for an order via the Court of Protection to release the funds.
1.3.6

Power of attorney

An individual can apply for Lasting Power of Attorney on behalf of someone where that individual has other income or assets in addition to state benefits just benefits. The person needs to have capacity to sign the document to agree to someone taking over power of attorney.
1.3.7

Service Involvement

The responsibility for deciding if staff should become involved with a service user's finances lies with the Resource Officer/ Operations Manager in conjunction with the Service User, their family or representative and Social Worker/Care Manager. Staff should always attempt to maximise financial independence for all service users.
  For Independence at Home service users, staff should explore fully whether there are means of supporting the service user other than the Manager or Home Care Support Worker becoming involved with their financial matters (e.g. where appropriate input from family members, use of standing orders and direct debits. MACS money advice service can provide a service to support service users who have capacity to maintain and manage their finances.)
  Most financial dealings for service users will be undertaken by their key worker but it is recognised that there will be times when other staff also need to support service users with day-to-day financial transactions.
  All staff (including relief and agency staff if they are to have any dealings with service user's finances) will be asked to sign a declaration appropriate to their service 'Dealing with Service Users Finances' regarding present or future involvement in service user's finances. (Appendix 1: Dealing with Service Users Finances (Service Variation))


2. Procedures

2.1

General

  As part of the admission procedure to a residential or accommodation service, there should be a discussion with the Service User about how they wish to manage their financial affairs including shopping for personal items, access to bank accounts and whether they wish to have a safe custody account or money held in the safe.
  Service Users should be informed that the Council does not take responsibility for any money they choose to hold on their person. Service Users should be given access to a locked drawer and encouraged to use this. They should also be informed that items such as cheque books, building society books and bank cards can be placed in the safe where they can access them during normal office hours.

2.2

Contributions

There are different sorts of contributions for different types of services:

  • Residential service (non-LD) users should be asked to sign ‘Terms and Conditions of Residency’ which should clearly identify the amount the person is contributing towards their care and what is included in this fee;
  • Learning Disability service users living as tenants in Supported Living Services will be assessed for a ‘non-residential’ charge which contributes towards household items and bills. The details of these arrangements are set out in LD Accommodation Services – Service User Contributions;
  • Learning Disability service users living in Registered Care Services will be assessed for a weekly “residential charge”, which will contribute to their support costs. The details of these arrangements are set out in LD Accommodation Services – Service User Contributions.

2.3

Care Plans and Financial Profile

All care plans should have a section regarding finances - decisions made should be recorded and form part of the service users care plan. Any risks identified should be recorded on a risk assessment with actions agreed. It may also be necessary to complete restrictive practice documentation, if, for example, a person receives their personal allowance split during the week to ensure they manage their finances.
  If a service user does not have capacity, the care plan should record who will deal with financial matters - this could be more than one person but evidence of Enduring or Lasting Power of Attorney should be seen by the Resource Officer/Operations Manager / Delegated Senior Care Officer before discussion are held.
 

Additional planning or profiling documentation is required in the following situations:

2.4

Transactions

No member of staff should make a financial transaction that is not set out in the service user’s care plan, or has not been previously agreed by their line manager.

  • Transaction Limits – General - Staff must not enter into a financial transaction for a service user, which involves more than £50 in cash without prior agreement of a line manager. If a request is made by the service user to do this, the matter should be referred to the line manager. Any amount over £250 must be agreed at Resource Officer/ Operations Manager Level or above. (For LD services, the request and approval should be documented through Appendix 5: Service User Money Request Form (LD)) No member of staff should carry more than a total of £250 in cash at any one time;
  • Transaction Limits - Independence at Home staff must not enter into a financial transaction for a service user, which involves more that £250 in cash. If a request is made by the service user to do this, the matter should be referred to the line manager. No member of staff should carry more than a total of £250 in cash at any one time.
  Where staff are dealing with money directly with a Service User they should record details of all transactions in a cash record /duplicate book.

2.5

Operation of Safe Custody Accounts (Residential Centres)

  The managing of safe custody accounts should be explained to any service users who may wish to use this service. There is not a charge for the administration of a safe custody account, but also service users do not receive interest on money held for them. Therefore it is recommended that money is not allowed to build up in the account. Service Users should be encouraged to move any build up of money to an interest producing account. (Service Users should be given the information sheet 'Safe Custody Accounts').
  For those Service Users in who have a Safe Custody Account, they are able to access money via the centres Petty Cash System - All transactions will be clearly recorded and Service Users will be asked to sign a Petty Cash Voucher when receiving cash.
  If a Staff Member shops for a Service User using money held for them they will be asked to sign a Petty Cash Voucher.
  If Service Users who hold their money within a safe custody account wish to purchase large items above £100 such as televisions, this will need to be purchased through the council's purchasing system.
  Each month the Team Administrator will detail all expenditure for the month for each Service User who will then be asked to sign agreeing the information as being accurate. Any discrepancies should be reported to the Resource Officer/Operations Manager who will need to investigate.
  If a Service User is unable to sign or does not have the capacity to understand the expenditure it may be appropriate for a family member to agree. In circumstances where there is no other person the Resource Officer/ Operations Manager should sign the monthly expenditure record.

2.6

Operation of Safe Custody Accounts (LD Accommodation Services)

  The principles of safe custody accounts set out above similarly apply to LD accommodation services. However, in smaller services, where there is no administrative support, service users’ access to money from their safe custody account is organised and managed by the unit manager.
  When money is needed by a service user, the unit manager should request an appropriate sum for the service user from Central Finance quoting their personal reference code. If the amount is greater than £250, the request must also be authorised by an operations manager. The money will then be delivered to the home. For routine expenditure, these requests are normally made on a monthly basis.
  On receipt of the new monies, the manager should add the money to the individual’s ‘main cash tin’, and record the transaction in the service users accounting book. The tin and the accounting book must be kept in the main safe, which is only accessible by the unit manager/operations managers.
  Smaller amount of money should then be regularly (e.g. weekly) transferred to the service users “daily tin” to cover daily expenses and transactions. Each of these transfers to the “daily tin” must be recorded in the main cash tin accounting book. (Also see below LD - Individual Petty Cash Tins (Daily Expenses Tin)).
  Unit managers must also regularly request statements for the safe custody accounts from the Finance Team, so that they can monitor the balance and ensure that other transactions or charges they have authorised on behalf of the service user been correctly applied. The Manager must reconcile the account, the transaction records, and cash in main tin, and sign the monthly expenditure record.

2.7

Learning Disability Services – Individual Petty Cash Tins (Daily Expenses Tins)

  Learning Disability (LD) Service users who cannot manage their own finances should have an individual petty cash tin for their daily expenditure with an individual cash record book in which all transactions are recorded and signed against.
  The cash in individual service user’s tins should be checked against the written balance at each shift handover period and double signed to show this has been done. All receipts for purchases must be kept regardless of the amount, with the exception of trivial amounts where it would be difficult or demeaning for the service user (e.g. buying an ice cream). See retention schedule for details on timescales. Staff have the initial responsibility to resolve any discrepancies, and if they are unable to do so, report the situation to their line manager at the earliest possible opportunity. All money must be kept in a safe that is not removable (large and heavy, or small and fixed to the building). The safe must be registered with the insurance team. The total money kept in it should not exceed the amount that the particular safe is insured for.

2.8

LD Services – Building Society Accounts/Bank Books Operated by Staff

  All building society books, bank books etc operated by staff on behalf of service users should be locked in a secure place such as the unit safe and a separate record kept of the account details in case books are lost.
  Operation of building society accounts/ bank books requires two signatories one of whom should be the unit manager.

2.9

LD Services – Checking Arrangements

  The Resource Officer/ House Manager will check the service user’s financial records and cash balance at least monthly and undertake a three monthly check of the financial plan.

2.10

Independence at Home (Homecare): Operation of Duplicate Books

  All staff are issued with a Duplicate Book in which to record all financial transactions for service users. The service users signature must be obtained when any money, pension cheque, account book or bank cheque is given to staff at the beginning and end of the individual transaction, and then countersigned by that member of staff. If a service user is unwilling, or unable, for any reason to sign the Duplicate Book the matter should be raised immediately with the line manager.
  The top copy in the Duplicate Book should be given with the receipt(s) to the service user. The second copy should be retained in the book for checking by the line manager.
  Staff must sign for each Duplicate Book issued, and their line manager will check each book at every six week supervision, or when complete, whichever is the sooner. The line manager must record the check in the supervision notes and on the monitor form staff member’s file.
  Duplicate books must be kept securely in locked storage when not in use.
  If a Duplicate Book is lost, stolen or mislaid, staff should inform their line manager immediately.

2.11

Checking and Retention Arrangements: Duplicate Books

  Managers should check Duplicate Books by reviewing and signing each page. They should keep a separate record of the issue of a book, their checks and the return of each book. Returned Duplicate Books should be retained in the office for a period of four years in a locked cupboard or filling cabinet.
  Any discrepancies should be discussed with the Service Manager immediately.

2.12

Staff no longer assigned to the service user: Duplicate Books

  The procedures set out apply equally to staff who are no longer assigned to the service user.
  When staff leave the Independence at Home Service they should return their duplicate book to their line manager, who should complete final checks before storing it for the retention period.

2.13

Extra Care Housing - Money Advice Service (MACS)

  Finances for service users are dealt with by Money Advice and Casework Service (MACS). MACS visit New Larchwood on Tuesday mornings at 10.00am. A Care Support Manager (CSM) accompanies the MACS representative to Service User’s flat and the service user signs for his or her money which is put into the individual safe in the service user’s flat. The CSM adds the amount to the transaction sheet and amends the running total. Each service user has an individual number for the safe and the number is only known to the CSM team and the Operations Managers.
  When money is needed for shopping, it is signed out by the SCO in agreement with the service user and the amount recorded on both the transaction sheet in the safe and the HCSW’s receipt book, counter signed by the SCO. To return the change, the HCSW and SCO agree the change with the service user; records on the transaction sheet the monies returned, (taking into account any change that may have been given to the service user to keep out of the safe) and adjusts the running total.
  If service users are awaiting the MACS service, SCO’s will encourage them to buy and use their own safe in readiness for the service start.

2.14

Cases Causing Concern – Discrepancy/Irregularities

  If a member of staff has concerns about any aspect of a service users finances they must discuss these with their line manager at the earliest possible opportunity.
  Any unresolved discrepancies in service user finances should be reported on an incident form, discussed with the Operations Manager, and investigated appropriately.
  In cases of concern regarding possible financial abuse of a service user the manager should contact the assessment team and consider whether a Safe Guarding Referral needs to be made.

2.15

Cases causing concern - Vulnerability in the Community

  An assessment of a person’s ability to manage their own money is made at the start of their service, but their ability to manage may vary over time. If a member of staff has a concern regarding a service user’s vulnerability with money. For example, impaired memory retention or confusion or amounts of cash remaining in the home in excess of day-to-day requirements, it is vital that these concerns are passed on to managers.
 

The following action may be appropriate:

  • Formally highlighting these concerns with the service user/relative/carer;
  • The exploration of an external party undertaking power of attorney responsibilities;
  • Referral to the Money Advice and Casework Service under contract to the Supporting People team.
In any cases of potential financial abuse or irregularity, services should first consider whether to raise a Safeguarding alert.


3. Dos and Don'ts

3.1 What Staff should not do

Staff should never:
  • Carry service user's money with them other than on the day of transaction;
  • Carry more than £250;
  • Borrow service user's money;
  • Hold service user’s pension cheques in their own name;
  • Plan, cash or keep service user’s money in an account of their own;
  • Take on legal responsibilities for service user's finances e.g. power of attorney;
  • Have access to any person's PIN numbers - for example bank. building society, post office and internet;
  • Use their own Reward Cards e.g. Tesco Clubcard when shopping for someone else. A service user's own Reward card can be used;
  • Use their own credit or debit cards to buy items for service users and claim money back;
  • Take personal advantage of any promotional schemes i.e. buy-one-get-one free. service user must be made aware of these promotions;
  • Sign cheque's on service user's behalf;
  • Benefit from a service user’s lottery ticket win;
  • Accept money or gifts from a service user or his/her family - see Gifts to Staff Procedure.

3.2 What Staff should always do

Staff should always:
  • Leave property belonging to a service user in that person's home or in the office safe, it should never be kept by any member of staff unless agreed by their manager;
  • Inform their manager of any change or concerns that you may have regarding the service user's financial circumstances;
  • If staff are in any doubt they should consult their line manager.

3.3 Confidentiality

Staff must be aware at all times of the confidentiality of information concerning service user’s finances and the importance of such information not being disclosed to a third party (see Confidentiality Policy)


Appendices

Appendix 1: Dealing with Service Users Finances (Service Variation)

Appendix 2: Financial Profile (Non-LD)

Appendix 3: Financial Care Plan (LD)

Appendix 4: Financial Care Plan (Independence at Home)

Appendix 5: Service User Money Request Form (LD)

End