Consultation on a Standard Financial Assessment Template
Councils in Scotland provide a range of social care services to people in their areas who
need support (see annex 1). Some of these services are free of charge as a result of
councils’ own policies or because the law requires it – as is the case with free personal
care for people aged 65 and over.
Other services provided by councils are chargeable to the service user. In the vast
majority of cases councils do not charge the full cost of providing the services and never
charge more than this amount. In order to determine how much of a contribution an
individual should make towards to cost of those services, councils will undertake a
financial assessment. This assessment considers the personal finances of the individual
in order to come to a judgement about whether they can afford to pay. People with an
income below a certain threshold will not be asked to pay.
Councils charge for non-personal care services in order to avoid serious shortfalls in the
funding needed to meet the increasing demand for community care services. Councils
nonetheless seek to develop charging policies which are fair, provide for local flexibility
and accommodate the principles of local democratic decision-making.
COSLA Charging Guidance
COSLA has a responsibility to produce national guidance on charging for non-residential
care. The guidance is revised annually and continues to evolve within the rapidly
changing social policy context. Revisions are developed through a multi-stakeholder
working group the main focus of which is on increasing the consistency of charging
policies across councils1.
A central element of the guidance comprises a set of rates and allowances which are
used in the financial assessment process. People who receive community care services
have told COSLA that a consistent approach to financial assessment is important to
them. Earlier this year, council leaders agreed to explore a proposal to use a standard
financial assessment template, the effect of which would be to ensure that service users
would be assessed in the same way across different local authorities.
To this end, and in keeping with a commitment toward partnership working, COSLA now
seeks the views of stakeholder organisations on the principles and practicalities of
introducing a standard financial assessment template. We are also exploring the cost
impact on councils’ social care budgets.
1. Do you agree with the aim to standardise the thresholds and allowances used
to calculate charges for non-residential social care services?
1
Membership of the working group includes Scottish Government, Social Work Scotland, COSLA,
Alzheimer Scotland, Scottish Consortium for Learning Disabilities, Support in Mind Scotland, Local
Authorities and others as appropriate.
A Standard Financial Assessment Template
A standard financial assessment template would consist of a set of rates and allowances
drawn from the current COSLA Charging Guidance, with each of our member councils
agreeing to align their local charging policies to the framework set out below. For further
details of these elements see the glossary at annex 3.
INCOME
Capital (Tariff Income):
Partner’s Income
Older People £1 / £500
Others
£1 / £250
YES
(a proportion of a partner’s
income can be counted)
Compensation (Care Element)
DISREGARDS
Potential Disregarded Benefits
Disability Related Expenditure (DRE)
Capital (Disregard):
YES
(see list http://tinyurl.com/nv7otjl)
Over 60
Under 60
THRESHOLDS
Capital Upper Limit(a)
(above which full charge is made)
Single Person
Single Person
Couple
Couple
YES
£10,000
£6,000
£16,000/£26,000
(level to be agreed)
Under 60
Over 60
Under 60
Over 60
£122
£173
£186
£264
(a)Currently not specified in the COSLA Charging Guidance but used by councils.
2. Do you agree that councils should align with the thresholds and allowances
set out in the COSLA guidance, as described above?
Implications for people who use services
In working towards the goal of a standardised financial assessment, some of our
member councils have indicated that alignment would result in less generous thresholds
being introduced (i.e. their thresholds are currently more generous than the COSLA
guidelines recommend). Some have indicated that they would want to make further
changes to their charging policies to ensure that the local authority does not gain
financially - at the expense of service users - from these reforms. At the same time, by
moving away from current levels of variation, it will be impossible to ensure that no
individual, whose income exceeds the minimum charging threshold, is negatively
affected.
3. In order to achieve consistency, is it acceptable that some people, who can
afford to contribute, might eventually have to pay more?
Transitional Protection
Whilst councils can ensure neutrality in terms of the income they receive, they cannot
guarantee there will be no detriment at an individual service user level. One option that
councils might want to consider is applying a system of transitional protection.
4. What form of transitional protection would be appropriate to mitigate any
financial impact?
5. How long should transitional protection last?
Conclusion
In COSLA’s work on charging for non-residential social care, it is important that we hear
from people who use services and from the organisations that represent them.
6. Do you have any other comments about the proposals or wider observations
about COSLA’s charging guidance?
Responding to this consultation
We are inviting written response to the questions set out in this consultation by 08
November 2014. Please send your responses to amanda.hogg@cosla.gov.uk. If you
have any queries please contact the Health and Social Care Team by email at
info@cosla.gov.uk. A list of consultees is set out at annex 2.
Following the closing date, all responses will be analysed and considered together with
other relevant evidence to help develop proposals for a standard financial assessment
template. Unless otherwise advised responses will be made available to the public on
the COSLA website later in 2014.
Annex 1
Chargeable council services
As it stands councils work within a legal framework which allows them to charge for the
following adult non-residential care services.












care at home
day care
lunch clubs
meals on wheels
domiciliary services
wardens in sheltered housing
community alarms and telecare
laundry services
aids and adaptations
after car services for people with a mental illness
care and support services for those who have or have had a mental illness
transport
The legal framework also sets out circumstances in which services cannot be charged
for and these include:

Services for people who are subject to Compulsion Orders under the Criminal
Procedure (Scotland) Act 2003
Nursing Care and Personal Care for people aged over 65
Annex 2
List of consultees
Age Scotland
Alzheimer Scotland - Action on Dementia
ARK Housing Association
Social Work Scotland (formerly ADSW)
Audit Scotland
Bield Housing Association
BUPA
Capability Scotland
Care Inspectorate
Clyde Contact Centre
Carers Scotland
CrossReach
Citizens Advice Scotland
Community Care Providers Scotland
Consumer Futures Scotland
Cornerstone Community Care
Crossroads Caring Scotland
ELCAP Ltd
ENABLE
Housing Support Enabling Unit
Learning Disability Alliance Scotland
MND Scotland
People First Scotland
Quarriers
RNIB Scotland
Action on Hearing Loss
Salvation Army
Scottish Care
Scottish Churches Parliamentary Office
Scottish Consortium for Learning Disabilities
Scottish Council for Voluntary Organisations
Scottish Council on Deafness
Scottish Federation of Housing Associations
Causewayside House
Scottish Parliament
Scottish Pensioners Forum
Social Work Scotland (formerly ADSW)
Support in Mind Scotland
The Abbeyfield Society for Scotland Ltd
The Scottish Housing Regulator
United Kingdom Home Care Association
UPDATE
Values into Action Scotland
Annex 3
Glossary
Capital (Tariff Income2)
This is the weekly income users are assumed to receive by virtue of capital investments
which they could hold over and above the amount of capital which the council disregards
for tariff income calculation purposes. The COSLA Charging Guidance now sets this at £1 per
£250 for people below state pension qualifying age and £1 per £500 for people of state
pension qualifying age or above. Since data related to the previous year the terminology i.e.
‘Older People’ and ‘Others’ is used as consistent with 2013/14 guidance.
Partners Income
At this time the COSLA Charging Guidance does not specify a particular approach to the
consideration of partners income as far as it might contribute to the financial means of a
person who uses community care services. What the guidance does is to establish the
principle that councils may take partners income into account. At this time councils have a
number of different approaches to how this is done.
Compensation Care Element
The Guidance currently allows for the breakdown of any compensation award in order to
identify and consider whether some elements should be included in the financial
assessment as income or capital.
Disregarded Benefits
Prior to the 2014/15 iteration of the COSLA Charging Guidance there was no standard
reference list of benefits which councils across Scotland routinely consider as potential
disregards. This meant that a comparison of the benefits disregarded by different councils
was difficult; this list is now included at Appendix C in the COSLA Charging Guidance.
Disability Related Expenditure
The 2014/15 iteration of the Guidance states that council should be proactive in establishing
any Disability Related Expenditure (DRE). In doing so, at this time councils, currently employ
a number of different approaches.
Capital (Disregard)
This currently specifies two thresholds below which no tariff income should be assumed.
The COSLA Charging Guidance sets this limit at £6,000 for people below state pension
qualifying age and at £10,000 for people of state pension qualifying age or above. The
following summary expresses this in terms of currently used age bands.
Capital Upper Limit
If a person who uses community care services has more capital than this limit they are
required to pay the full charge which the council levy’s for the services used – people in this
position are often termed ‘Self-Funders’. The full charge should not exceed, and is often less
than, the full cost to the council of providing the service. Whilst the Charging Guidance does
not specify this element, and not all councils apply a limit, they were invited to give
estimates of aligning with the two rates commonly used by councils in Scotland.
2
Income received from invested capital.
Annex 3
Charging Thresholds
A charging Threshold is the set level of personal income below which a person can receive
community care services without being required to pay a contribution toward the cost of
the service(s) they need. The Charging Guidance currently set four different thresholds
based on DWP rates which set out under the following headings.