Wandsworth Council. Adult Social Care Charging Policy. June 2016

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1 Wandsworth Council Adult Social Care Charging Policy June 2016 Version 1 Review Date June 2017 Owner DESS Finance

2 Table of Contents 1. INTRODUCTION AND LEGAL BASIS OF CHARGING NON RESIDENTIAL SERVICES... 4 CHARGING AND FINANCIAL ASSESSMENT OF NON RESIDENTIAL SERVICES... 4 CHARGEABLE SERVICES... 7 SERVICES NOT INCLUDED WITHIN THE SCOPE OF THIS NON RESIDENTIAL CARE CHARGING POLICY: 7 NON CHARGEABLE SERVICES RESIDENTIAL SERVICES... 9 CHARGING AND FINANCIAL ASSESSMENT OF RESIDENTIAL CARE SERVICES... 9 SELF FUNDERS/THOSE PAYING THE FULL COST OF THEIR SERVICES PROPERTY...11 DEFERRED PAYMENT AGREEMENTS SCHEME SHORT TERM RESIDENTIAL AND NURSING CARE (TEMPORARY/RESPITE) REABLEMENT/ENABLEMENT CARERS FINANCIAL ASSESSMENT CONSIDERATIONS METHODS OF PAYMENT AND DEBT RECOVERY APPEALS AND COMPLAINTS APPENDIX A HOUSEHOLD RELATED EXPENDITURE (HRE) WHAT IS HRE? WHAT EXPENDITURE CAN BE TAKEN INTO ACCOUNT? APPENDIX B DISABILITY RELATED EXPENDITURE (DRE) Page 2

3 1.1 Wandsworth Council s Adult Social Care Charging policy has been designed to comply with The Care Act 2014, and reflects prior charging policy decisions that are still relevant. This policy is regularly reviewed, and any changes agreed by the Council will be reflected in an updated Adult Social Care Charging Policy Document. The main aim is to produce a consistent and fair framework for charging and financial assessment for all service users who receive care and support services, following an assessment of their individual needs, and their individual financial circumstances. 1.2 For the purposes of this policy, an adult is a service user aged 18 and above. 1.3 The Care Act 2014 provides a single legal framework for charging for care and support. It enables local authorities to decide whether or not to charge a service user when it is arranging to meet a service user s care and support needs, or a carer s support needs. 1.4 Section 14 of The Care Act 2014 provides local authorities with the power to charge adults in receipt of care and support services, where the local authority is permitted to charge for the service being provided. Section 14 of The Care Act 2014 provides local authorities with the power to charge for services meeting carers needs, by providing services directly to the carer. 1.5 Section 17 of The Care Act 2014 permits local authorities to undertake an assessment of financial resources. The financial assessment will determine the level of a service user s financial resource, and the amount (if any) which the service user is considered able to pay towards the cost of meeting their needs through care and support services. 1.6 Wandsworth Council will refer to Care and Support Regulations (Statutory Instruments) and Care and Support Statutory Guidance and Annexes issued under The Care Act 2014, in all regards for specific guidance relating to charging and financial assessment, and as such, these statutory regulations form the basis of this policy. 1.7 This document reflects the Council s present policy on charging for Adult Social Care. Further, more detailed information on financial assessment calculations, including the current capital limits are contained within fact sheets, which are available on the Council s internet site (www.wandsworth.gov.uk), and on request in leaflet form. Page 3

4 2. Non Residential Services Charging and financial assessment of Non Residential Services 2.1 The Council will charge for care and support delivered in a service user s home and other community settings, for example, day services. 2.2 Service users requiring care and support in their own home or other community settings must initially satisfy an eligibility assessment for care and support. Only where a service user has an eligible care and support need will a financial assessment be required. 2.3 Service users receiving care and support that is neither temporary nor permanent in a care home will have their care and support costs administered through a personal budget. A personal budget is the amount of money that is required to meet eligible care and support needs, including the amount a service user can contribute towards that cost. The difference is the amount of funding support that the local authority will provide. Personal budgets may also contain funding towards care and support costs from the NHS. 2.4 Where a service user has an eligible on-going care and support need, the Council will calculate how much the personal budget might be, using its Resource Allocation System (RAS). This guide amount is known as the indicative budget. Once the indicative budget is calculated, the care and support planning and authorisation process, taking into account the service user s views and their agreed social care outcomes, will determine the final personal budget required. 2.5 Service users are likely to choose varied forms of care and support to meet their specific outcomes, as defined in their care and support plan. Where a service user is self funding their care they are still entitled to request that the Council arrange their services. The Council charges a one-off administration fee for brokering and arranging non-residential services for self-funding residents. In 2016/17 this charge is 125, and is payable once any new services have been arranged. 2.6 Service users who are not self funding will have the option to take a personal budget as Council commissioned services, or as a direct payment, or a combination of both. Service users who take their personal budget as a direct payment may purchase alternative types of care to meet their assessed care and support needs as defined in Sections 31 to 33 of The Care Act The Council publishes Direct Payments guidance that sets out the criteria for care and support being managed through Direct Payments, and this is available on the Council website, or on request in a leaflet format. 2.8 The Council will undertake a financial assessment to determine the amount a service user can contribute towards their care and support costs. The underlying principle of this process is that it is equitable, in addition to ensuring that service users are only required to pay what they can afford to pay (under the Council s Page 4

5 charging policy), and that the charge to the service user for services provided is no greater than the cost of the services being received. 2.9 The Council will undertake a financial assessment based, as a minimum, on income, capital, housing related expenditure (HRE), see Appendix A, and disability related expenditure (DRE), see Appendix B. Service users with savings/capital in excess of the higher capital limit will be responsible for meeting all of their care and support costs. A service user may also be self funding if their income is at a level where their financially assessed contribution matches or exceeds the total cost of their care services. Evidence will be required to substantiate fully a service user s financial circumstances. Please refer to Appendices A and B at the end of this policy document for more detailed guidance in relation to HRE and DRE If a service user declines or refuses a financial assessment they will be required to pay for the full cost of their services The financial assessment will refer to Care and Support Statutory Guidance for all disregards in respect of income and capital when making a determination of the service user s financial resources The lower Capital savings limit for residential care will apply which is currently 14,250. This will be revised in line with Department of Health advice. Capital below this limit will be disregarded in the financial assessment A higher capital limit of 25,000 will apply for non residential charging. Tariff income at the rate of 1 per 250 will be charged on savings held between the lower and higher capital limits Service users who only receive income support (i.e. who do NOT also get Attendance Allowance or Disability Living Allowance or Personal Independence Payment) will be financially assessed to pay nothing, but must inform the Council immediately if their financial circumstances change so a reassessment can be undertaken. Where a service user s financial circumstances change, which leads to them being able to pay towards their care costs, they will be liable for the relevant weekly charge from the date of the change, regardless of when the Council was informed of the change Service users who are subject to a financial assessment will be offered a welfare benefits check to ensure that they are receiving all of the income to which they are entitled, and can ask for assistance in completing the financial assessment form. This can be arranged with a Council financial assessment visiting officer, or, if preferred, through an independent advocate Where a service user has capital in excess of the higher capital limit, they can request a light-touch financial assessment. In carrying out financial assessments the Council will ensure that service users retain at least the Minimum Income Guarantee. This retained income level is designed to promote independence and social inclusion and is intended to cover basic needs such as purchasing food, and housing costs. Direct housing costs will only be considered where the service user is Page 5

6 liable for such costs, i.e. holds the tenancy agreement or is party to the mortgage. The Minimum Income Guarantee ensures that the service user retains income to the equivalent of Income Support or the Guaranteed Credit element of Pension Credit, plus a minimum buffer of 25% Following the financial assessment, the service user will be informed if they are considered as able to self-fund their care costs, or of the weekly amount they must contribute towards their care and support costs if a contribution is required based on their financial circumstances. Service users will not be charged more than the amount determined by the financial assessment, or the actual cost of their services if they can self fund their care and support costs. Contributions are normally payable from the date care commences. Service users who require services to be arranged by the Council will be invoiced in arrears for their care costs, usually quarterly Service users receiving their care and support costs through direct payments will usually receive payments every four weeks in advance. These payments will reflect the agreed cost of their services, less their financially assessed contribution. Direct Payments will not usually be made to anyone self funding their care and support costs, as in such a case the Council would be paying the Direct Payment amount, and then invoicing the service user to recover this same amount, which is administratively burdensome As a minimum, a service user s assessed contribution will be reviewed on an annual basis and advised to the service user; this date is typically in line with the increase in state benefits and is at the beginning of April each year. Changes to circumstances may also lead to a new financial assessment being undertaken. If requested, a service user s contribution can be reviewed at their request, and there is a right of appeal against the financial assessment decision. Such an appeal would need to be supported with evidence showing why the service user believes an error or omission has occurred within the financial assessment calculation The review procedure is fair and equitable and allows charges to be waived in exceptional circumstances. Service users will be given an explanation for any decisions made, and a chance to provide further information if relevant to the financial assessment. Page 6

7 Chargeable services 2.21 All non-residential community based services fall within the scope of this policy and include: Home Care Supported Living/Housing Extra Care Sitting Services Shared Lives Service Day Care services/activities, both building based and in the community Befriending Transport Respite that is not in a residential care home Reablement/Enablement service after first 6 weeks Housing related support services, housework etc. Shopping services Laundry services Direct Payments Outreach Joint funded services service users will be required to contribute towards the total cost of the services provided by the Council Services not included within the scope of this non residential care charging policy: 2.22 Frozen meals/ Meals in Day Centres a flat rate charge will be applied for those who have lunch or take frozen meals. This is outside of the scope of the financial assessment as such meals are considered a substitute for ordinary living costs. Non chargeable services 2.23 Section 14 of The Care Act 2014 instructs that local authorities are not permitted to charge for provision of the following types of care and support: 2.24 Community equipment (aids and minor adaptations): a service which consists of the provision of an aid, or minor adaptation to property, for the purposes of assisting with nursing at home or aiding daily living. An adaptation is minor if the cost of making the adaptation is 1,000 or less; 2.25 Re-ablement and Enablement, for a period of up to six weeks. Any continuation of services beyond that will be chargeable from the beginning of the seventh week (see section 5.0) 2.26 Services provided to people suffering from Creutzfeldt Jakob Disease Page 7

8 2.27 Any service or part of service which the NHS is under duty to provide. This includes intermediate care, Continuing Healthcare and the NHS contribution to Registered Nursing Care; 2.28 Assessment of needs and care planning, including the cost of the financial assessment, as these constitute meeting needs Services which local authorities have a duty to provide through other legislation, including any specific services provided as After Care Services under Section 117 of the Mental Health Act There will be occasions when chargeable services are also provided to service users who are subject to Section 117 of the Mental Health Act This is usually when a service is in place that is not specifically related to their Section 117 status. If this is the case the service user will be advised of this in writing and a financial assessment will need to be undertaken in relation to such services. Page 8

9 3. Residential Services Charging and Financial assessment of residential care services 3.1 The Council will charge for care and support delivered in a care home on a permanent basis. 3.2 Service users requiring permanent care and support in a care home must initially satisfy an eligibility assessment for care and support. Only where a service user has an eligible care and support need will a financial assessment be required. 3.3 All service users requiring permanent care and support in a care home who are seeking financial support from the Council must have a financial assessment. A service user s financial circumstances will determine whether they are eligible for financial support towards permanent care costs from the Council. 3.4 Should a service user wish to move into a care home that the Council doesn t contract with, and the weekly care home rate exceeds the usual weekly rates the Council pays for similar care homes, the Council s contribution will be based on their usual rate for a similar care home, and private arrangements will need to be put in place to fund any excess weekly amount. This usual rate is inclusive of any assessed service user contribution, and in the case of nursing care, includes the free nursing care element (FNC) paid by the NHS. In these circumstances the decision on the usual amount the Council considers appropriate will be provided to the service user/their representative in writing. 3.5 Where a service user is eligible to receive local authority funding support, but decides to reside in another local authority area, Wandsworth Council will match the local authority usual rate for such care relevant to the area where the service user decides to live. 3.6 Service users who would like to live in accommodation that costs more than the usual rate can do so providing the service user or a third party meets the additional cost. This additional cost (known as a top-up) must be sustainable and the Council has the right to refuse a service user using their assets for this purpose, if the costs cannot be met over a sustained length of time. This is to try to safeguard the resident from needing to move to another care home in the future should they no longer be able to pay the agreed top-up amount. If the Council doesn t agree to provide funding towards a more expensive care home due to concerns over the affordability of the top-up required, the service user or their representative can seek legal advice, or advice from an independent advocate. 3.7 Where a service user chooses more expensive accommodation than the local authority rate, and the top-up is to be paid by a third party, the third party must confirm they are able to meet the costs of the top-up for the duration of the agreement, including any price changes that may occur. Both they and the service user will be made aware of the cost and to whom payment is to be made, together Page 9

10 with the frequency. The agreement will be reviewed on an annual basis. The consequences of failing to maintain payment and the effect of negative changes in financial circumstances will need to be fully understood. The person taking responsibility for the top-up payment will be asked to enter into an agreement, covering all of these points. 3.8 The Council will undertake a financial assessment and benefits check for service users entering residential care on a permanent basis. This is normally done before the service user starts to receive care wherever possible. Contributions are payable from the date care commences. The Council publishes a fact sheet containing details on residential care charging, which is available on the Council s website, and in leaflet format on request. 3.9 The Financial Assessment will take into account income, capital and the value of any assets. The charging methodology will take into consideration any mandatory disregards of income, capital and property as defined in the Charging for Care and Support Statutory Guidance The financial assessment will take into account statutory amounts required to be retained by the service user from their income. These are known as Personal Expenditure Allowance (PEA) and Disposable Income Allowance (DIA). These amounts are dependent upon the service user s financial circumstances, and are reviewed annually by the Department of Health. The rates applicable for the relevant financial year (April March) are set out on the Council s website Where a service user has no income, the local authority must ensure that the service user receives a personal expenditure allowance at the statutory rate As a minimum, a service user s assessed contribution will be reviewed on an annual basis and advised to the service user; this date is typically in line with the increase in state pensions/benefits and is at the beginning of April each year. If requested, a service user s contribution can be reassessed on request where the service user s circumstances have changed, or for self funding service users, if their total savings/capital have fallen to or below the upper capital threshold. Self funders/those paying the full cost of their services 3.12 A self funder is a service user whose savings/capital exceed the higher capital threshold limit for residential care, or whose income is deemed to be sufficient to pay the weekly cost of their care in full, for example, from private pensions, investment funds, and property rental income Residential care service users in this position will need to make their own arrangements with the care home regarding their permanent residency and payment of the care fees, except in cases where they are unable to do so and there is no one else who is willing and able to act for them, in which case the Council will normally assume responsibility for making the arrangements with the care home on behalf of the service user. Wandsworth Council can however offer a range of Page 10

11 information and guidance to assist people who are self funding to find the right care for themselves If a service user s capital falls to the higher capital limit or below it, a care assessment or care review will be completed to determine eligibility for Council funding, and a financial assessment will be completed to determine the service user s financial circumstances. This information should determine from what date the service user will become eligible for financial assistance with their care fees. Property 3.15 There is a general requirement that any property owned by the service user should be included in the financial assessment unless there is a statutory disregard of the property as defined within the Charging for Care and Support Statutory Guidance. Where the property is to be included, the Council will ignore its value for the first twelve weeks of residency. This period is called the twelve week property disregard period and allows service users time to consider the options available to fund their future care costs. The value of a main residence will be disregarded when a spouse or partner continues to reside there. The Council publishes a fact sheet on its website, and on request in leaflet format, providing more details on how financial assessment calculations and charging decisions for residential and nursing home care are made. Deferred Payment Agreements Scheme 3.16 Service users who own a property or other valuable asset, over which security can be taken, may be eligible to defer some care costs against the value of the property/asset. This is known as a Deferred Payment Agreement. Wandsworth Council will make deferred payment agreements available under its Deferred Payment Agreement Scheme providing the eligibility criteria have been met. Details of deferred payment eligibility and agreements can be found within the Council s deferred payments for people in permanent residential care fact sheet, which is available on the Council s website, and in leaflet format on request. The Council charges set up costs, an annual monitoring and administration fee, termination costs, and interest on all deferred payment loans agreed from April 2015 onwards. 4. Short term residential and nursing care (temporary/respite) 4.1 The Council will charge for care and support delivered in a care home on a temporary basis. 4.2 Following an assessment of a service user s eligible care and support needs, a decision may be taken that the service user would benefit from a temporary stay in a care home. A temporary resident is defined as a service user whose need to stay in a care home is intended to last for a limited period of time, and where there is a plan to return home. The service user s stay should be unlikely to exceed 52 weeks, or in exceptional circumstances, unlikely to substantially exceed 52 weeks. Page 11

12 4.3 Service users who have a temporary stay that becomes permanent will be assessed for a permanent stay at the date permanency is confirmed and the care plan is amended. 4.4 The Council will financially assess all service users having a temporary stay in a care home, and will charge from the date of admittance. 4.5 The financial assessment for temporary stays will completely disregard the service user s main or only home where the service user intends to return to that home. This decision will be reviewed, and continuation of the property disregard will depend on the extended length of stay in a care home after 52 weeks has elapsed, and the individual circumstances affecting this. 4.6 The Council will ensure that where a spouse or partner resides in the same residence as the service user, that the spouse/partner will have an income of at least the basic level of income support or pension credit, to which they would be entitled to in their own right. 4.7 The Council will ensure that where housing benefit is paid, this is disregarded so it can continue to meet the housing costs, as intended. 4.8 The Council will ensure that payments made by the service user to keep and maintain their home, such as rent, water rates, insurance premiums are disregarded when financially assessing available income. Similarly, expenses that the service user would normally incur and would continue to pay may also be disregarded from the available income for the purposes of the financial assessment, such as disability related expenditure (DRE) e.g. community alarm services. Contributions are usually payable from the date care commences. A new financial assessment will be required in each financial year where a service user requires respite accommodation in a care home. 5. Reablement/Enablement 5.1 Reablement/Enablement services are provided free of charge for the first six weeks. Any services following enablement that are arranged by the council are chargeable in line with this charging policy document, and any enablement service still being received beyond six weeks will be chargeable from the beginning of the seventh week. 6. Carers 6.1 The Care Act 2014 provides councils with the power to charge for support for carers, where they have an eligible support need in their own right. 6.2 The support which the Council can charge the carer for must not be provided directly to the adult being cared for. The Council does not presently charge carers, Page 12

13 but will exercise its power to only provide funding the council feels is appropriate to the assessed eligible needs of the carer, and taking into account any services arranged for the cared for person. In addition, in some circumstances the Council may not agree to fund certain support requested by a carer if the Council considers these needs can be met in another, more cost effective way, for example, through relevant contracts the Council has in place, or through the voluntary sector. 7. Financial Assessment Considerations 7.1 Deprivation of income and/or assets is the disposal of income and capital (for example, property and investments) in order to avoid or reduce care charges. Disposal can take the form of transfer of ownership or conversion into a disregarded form. In all cases, it is up to the service user to prove to the Council that they no longer possess an income or an asset, and the reason for this. The Council will determine whether to conduct an investigation into whether deprivation of income or assets has occurred. Where an investigation is conducted, this will be conducted under guidance contained within the Regulation of Investigatory Powers Act Following the investigation, where the Council decides that a service user has deliberately deprived themselves of an asset or income in order to reduce a charge for care and support, the Council will charge the service user as though they still owned the asset or income. 7.2 Property owned other than the service user s main or only home will be included within the financial assessment as a capital asset. The only exception to this rule is where the service user is taking steps to occupy these premises as their permanent home. In this case the asset value will be disregarded for a maximum of 26 weeks. 7.3 The Care Act 2014 requires that financial assessments are completed for service users as individuals. Where capital is held and income is received on a joint basis, then it is assumed that each party is entitled to 50% of that capital/income. A couple is defined (for the purposes of this charging policy) as two people living together as spouses or partners. Page 13

14 8. Methods of Payment and Debt Recovery 8.1 The Care Act 2014 consolidates the Council s powers to recover money owed for arrangement and provision of care and support for a service user. These powers can be exercised where a service user refuses to pay the amount they have been assessed as being able to pay, or have been asked to pay (where the cost of care and support is less than their assessed contribution). 8.2 The powers granted to the Council for the recovery of debt also extends to the service user or their representative, where they have misrepresented or have failed to disclose (whether fraudulently or otherwise), information relevant to the financial assessment of what they can afford to pay. 8.3 The Council will approach the recovery of debt reasonably and sensitively and will only take Court action as a last resort. 8.4 The initial stage of debt recovery will involve discussing the debt with the service user or their representative. Social workers will be advised of the debt, and may become involved if appropriate to the on-going care/well-being of the service user. In all cases the desired outcome is to prevent a debt escalating and for the service user to enter into affordable repayments of the debt, as well as being able to pay ongoing costs due as they arise. 9. Appeals and Complaints 9.1 A service user may wish to make an appeal about any aspect of the financial assessment, for example, how DRE expenditure has been considered. Appeals should be directed to: Financial Assessments Team P O Box London SW18 9JS Tel: Fax: Monday to Friday 9am to 5pm Page 14

15 9.2 When an appeal is received, initially an officer, independent of the disputed financial assessment will reassess the information provided by the service user at the time of assessment. Any additional information that was omitted from the initial assessment will be considered upon submission of evidence. However, the Council is under no obligation to backdate the outcome to the date of the original assessment, but will consider the appropriate effective date for any change during the appeal process. An exception to this is where benefit income has stopped without the prior knowledge of the service user, which will always result in a backdated charging decision to coincide with the date the benefit income ceased to be payable. 9.3 Where the Council still considers that the financial assessment is correct, and the service user does not agree with this decision, any resultant complaints about the level of charge are subject to the Care and Support Complaints Procedure, as set out in The Local Authority Social Services and NHS Complaints Regulations Complaints should be addressed to. DESS Complaints Wandsworth Council Town Hall Extension 3 rd Floor Wandsworth High Street London SW18 2PU Please contact the Complaints Officer on Tel: Page 15

16 Appendix A Household Related Expenditure (HRE) What is HRE? Household related expenditure is the cost incurred by the service user in maintaining their home. For this purpose the home is the service user s main place of residence. Allowable housing costs (e.g. rent/mortgage/council tax) will only be allowed in the financial assessment where the service user is liable to pay these costs. Where the service user is not liable for these costs, but contributes towards these through a private board agreement or similar, then the service user will be expected to meet this expenditure from their guaranteed income What expenditure can be taken into account? The following items of HRE are fully taken into account in the financial assessment: Council Tax (net of Council Tax support) Rent (if payments are classed as rent for housing benefit purposes, amount taken into account is net of housing benefit if in payment) Mortgage Payments (unless paid through Income Support/Pension Credit) Ground Rent Hire purchase agreement to buy the home (e.g. caravan) Any other items of reasonable household expenditure that the service user wishes to claim for will need to be evidenced and included in the financial assessment form that is completed. If a contribution is payable towards an Independent Living Fund award, this will be included as an allowable expense in the financial assessment for as long as the Independent Living Fund continues to operate. Page 16

17 Wandsworth Charging Policy 2015/16 Appendix B Disability Related Expenditure (DRE) Disability related expenditure is the additional cost or costs incurred by the service user, as a direct result of their disability, age or medical condition. Service users who are in receipt of care, with the exception of permanent care in a care home, and are in receipt of disability benefits (Attendance Allowance/Disability Living Allowance and Personal Independence Payment) will be asked about additional costs incurred as a direct result of their disability. This is a section included within the financial assessment form. Only costs incurred by the service user will be considered as part of the assessment as allowable expenditure. The Council presently uses guide weekly disregard allowance rates for certain types of disability related expenditure, and usually these are treated as maximum amounts that can be disregarded in the financial assessment calculation. However, individual circumstances are taken into account, and reasonableness is applied during the financial assessment determination process based on the information and evidence provided. The Council has the right not to allow costs that should be met by other agencies, such as the NHS. This applies to therapies such as physiotherapy, chiropody and incontinence pads. The Council will consider the following DRE within the financial assessment calculation: payment for any community alarm system; excessive laundry costs, bedding etc. due to incontinence. However, the Council will not make allowances at a higher rate where a reasonable alternative is available at a lower cost; heating or metered water costs, above average levels for the area and housing type, occasioned by age, medical condition or disability; special clothing and footwear; special dietary needs; reasonable costs of basic garden maintenance, cleaning or domestic help, if such is necessitated by the service user s disability and is not already met; reasonable costs paid to a personal assistant (not a household member) who carries out necessary tasks, for example, around the house; purchase, maintenance and repair of disability related equipment, including equipment or transport needed to enter or remain in work; this may include, for example, IT costs, where necessitated by the disability; specialist internet access, for example, for blind and partially sighted people; transport costs necessitated by illness or disability, including costs of transport to day centres, over and above the mobility component of DLA Page 17

18 Wandsworth Charging Policy 2015/16 or PIP, if in payment. Where the Council provides transport and the service user wishes to use alternative transport at a higher cost, the cost of Council provision will be used to determine any allowance. All other expenditure will usually be assessed as either an everyday living cost, or will be reviewed as a specific need against the service users care and support plan, taking individual circumstances into account. Page 18

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