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Managing Service User Finances Policy

1. Purpose

The purpose of this policy is to establish clear, transparent, and ethical procedures for managing the finances of the people we support, ensuring that they:

• Retain control over their own finances wherever possible.
• Receive support in a way that promotes dignity, independence, and best interests.
• Are safeguarded from financial abuse, fraud, and mismanagement.
• Have their money, property, and financial affairs managed lawfully and in compliance with CQC and legal regulations.

This policy supports compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (as amended), in particular Regulation 13 (Safeguarding service users from abuse and improper treatment) and Regulation 17 (Good governance), and with CQC statutory notification requirements.

2. Scope

This policy applies to:

• All staff who support people in managing their money.
• The people we support, their family members, legal representatives, and advocates.
• Registered Manager, Deputy Manager, and Finance Officers.

It covers:

• Assistance with budgeting and payments.
• Safeguarding money from financial abuse.
• Recording and auditing financial transactions.
• Compliance with legal frameworks, including the Mental Capacity Act 2005.

3. Legal and Regulatory Framework

This policy aligns with the following legal and regulatory requirements (as amended from time to time):

• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Regulation 9 (person-centred care), Regulation 10 (dignity and respect), Regulation 11 (need for consent), Regulation 13 (safeguarding from abuse and improper treatment, including financial abuse) and Regulation 17 (good governance and accurate records).
• Care Quality Commission (Registration) Regulations 2009: Regulation 18 (notification of other incidents), including allegations of abuse / safeguarding notifications to CQC without delay.
  • Mental Capacity Act 2005 (and Code of Practice): decision-specific capacity assessment, best interests decision-making and least restrictive practice.
• Care Act 2014: adult safeguarding duties and local safeguarding procedures.
• Data Protection Act 2018 and UK GDPR: secure handling, access control and lawful processing of personal financial information and records.

4. Principles of Financial Management

4.1 Promoting Independence and Choice

• People we support must be encouraged to manage their own finances where possible.
• Support must be proportionate to the individual’s needs and preferences.
• Assistance with finances must be requested by the individual or authorised by a legal representative.

4.2 Mental Capacity and Financial Decision-Making

• Staff must always assume capacity unless proven otherwise.
• If a person lacks capacity, financial decisions must be made in their best interests, following the Mental Capacity Act 2005.
• If a Deputy (Court of Protection) or Lasting Power of Attorney (LPA) is appointed, staff must ensure they only act within their legal limits.
• A financial capacity assessment must be documented before assuming control over an individual’s finances.

4.3 Safeguarding Against Financial Abuse

• Staff must be vigilant in identifying signs of financial abuse, such as:
  • Sudden unexplained withdrawals or missing money.
  • Changes in spending patterns.
  • Unpaid bills when there are sufficient funds.
  • A person being pressured into financial decisions.
• Any suspected financial abuse must be reported immediately to the Safeguarding Lead ({{org_field_safeguarding_lead_name}}).
• Access to financial records must be limited to authorised personnel.

4.4 Secure Handling of Money and Valuables

• A secure, locked storage system must be in place for individuals who require assistance with cash storage.
• All valuables must be logged and signed for.
• Receipts must be obtained for all transactions.
• Two staff signatures must be obtained for all cash withdrawals, all transfers of money into/out of the home’s custody, and any purchase/transaction made by staff on a person’s behalf, unless the person completes the transaction independently. Where the person has capacity and chooses to complete their own transaction, staff should record the support given (if any) but must not countersign as a ‘witness’ to the person’s private spending decision.

4.5 Record-Keeping and Transparency

• All financial transactions must be recorded in an individual’s Financial Record Log.
• Receipts, bank statements, and other financial documents must be securely stored and available for auditing.
• Regular financial audits must be conducted to prevent errors or fraud.

4.6 Managing Bank Accounts and Benefits

• Staff must not open, close, or change bank accounts on behalf of a person without legal authority.
• If a person is unable to manage their bank account, the Court of Protection or a legal deputy must be involved.
• State benefits must be received directly by the individual or their appointed financial representative.

4.7 Verifying Legal Authority to Manage Money

Before staff handle money beyond day-to-day support, the Registered Manager must confirm and record who has legal authority (e.g., DWP Appointee, Court of Protection Deputy, Lasting Power of Attorney). Copies of relevant documents must be held securely. Staff must only act within the scope of the authority provided and must escalate any uncertainty to the Registered Manager before proceeding.

4.8 Handling Cash and Personal Spending

• If individuals require cash handling support:
  • A limit must be set on the cash held on their behalf.
  • Spending must be tracked and recorded daily.
  • Any unused cash must be stored securely.
• People should be encouraged to make contactless payments where possible to enhance financial security.

4.9 Bank Cards, PINs and Digital Payments

Staff must not request, record, or retain a person’s PIN. Where a person chooses to use a card/contactless payment with staff support, the person should complete the payment wherever possible. If staff are required to hold a bank card temporarily for a planned purchase, this must be recorded, stored securely, time-limited, and auditable, with receipts retained.

5. Staff Training and Responsibilities

5.1 Staff Responsibilities

• Staff must never borrow, lend, or take money from a person they support.
• Personal relationships must not influence financial transactions.
• Staff must ensure that individuals receive value for money in their purchases.
• Financial decisions must always align with the individual’s care plan and best interests.

5.2 Training Requirements

All staff involved in financial management must receive training in:

• Mental Capacity Act and financial decision-making.
• Fraud prevention and financial abuse safeguarding.
• Proper recording and auditing of transactions.
• Ethical money management and best practices.

6. Safeguarding and Reporting Financial Concerns

• Any suspicion of financial abuse must be reported immediately to the Safeguarding Lead ({{org_field_safeguarding_lead_name}}).
• The incident must be recorded in a financial concern log and investigated.
• Where financial abuse is suspected or alleged, staff must follow local authority safeguarding procedures and the Registered Manager (or delegate) must submit a CQC statutory notification for ‘Allegations of abuse (safeguarding)’ without delay, using the CQC provider portal (preferred) or the current CQC notification email route. The home must record the notification reference/ID in the incident record.

7. Monitoring and Compliance

To ensure high standards in financial management, the care home will:

• Conduct monthly financial audits of service user accounts.
• Ensure CQC compliance checks are conducted during internal reviews.
• Monitor staff compliance through spot-checks and supervisory reviews.
• Seek regular feedback from service users and families regarding financial handling.

8. Related Policies

This policy should be read alongside:

• CH07 – Person-Centred Care Policy
• CH08 – Dignity and Respect Policy
• CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• CH17 – Infection Prevention and Control Policy
• CH18 – Risk Management and Assessment Policy
• CH35 – Duty of Candour Policy

9. Policy Review

This policy will be reviewed annually or sooner if legislative, regulatory, or operational changes occur. The Registered Manager is responsible for ensuring that all staff adhere to the latest financial management guidelines and maintain best practices.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
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