{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

---

Managing Service User Finances Policy

1. Purpose

The purpose of this policy is to ensure that service users’ financial affairs are managed responsibly, transparently, and in their best interests at {{org_field_name}}. This policy outlines how we safeguard service users from financial exploitation, ensure compliance with legal and regulatory requirements, and promote financial independence wherever possible.

This policy aligns with and must be read alongside:

• The Regulation and Inspection of Social Care (Wales) Act 2016.
• The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, in particular Regulation 28 (Supporting individuals to manage their money), together with related requirements on safeguarding, records, complaints and notifications.
• Welsh Government statutory guidance for providers and responsible individuals of care home and domiciliary support services, last updated 27 March 2024.
• The Social Services and Well-being (Wales) Act 2014 and the relevant Welsh safeguarding and advocacy framework.
• The Mental Capacity Act 2005, its Code of Practice, and where applicable Deprivation of Liberty Safeguards.
• Wales Safeguarding Procedures and any local safeguarding arrangements in force.
• Current Care Inspectorate Wales (CIW) requirements, including notification, inspection, annual return and records expectations.

2. Scope

This policy applies to:

• All staff members, including care staff, administrators, and finance personnel.
• Service users, ensuring their financial rights, independence, and safeguarding.
• Service users’ representatives, including family members, advocates, and legal appointees.
• External agencies, including local authorities, the Office of the Public Guardian, and CIW.

The policy covers:

• Management of service user finances, including safeguarding and best interests.
• Access and security of funds, including bank accounts and petty cash.
• Financial decision-making and mental capacity considerations.

• The lawful basis on which the service may support, hold, record or oversee a service user’s money, property or valuables.
• How financial support is reflected in the individual’s personal plan, risk assessments and safeguarding arrangements.
• The keeping, storage, auditing, retention and handover of financial records, receipts and records of valuables held for safekeeping.
• Audit and monitoring procedures, ensuring transparency and accountability.

3. Principles of Managing Service User Finances

3.1. Promoting Financial Independence and Choice

At {{org_field_name}}, we are committed to promoting service users’ autonomy and control over their finances. This means:

• Encouraging service users to manage their own money whenever possible, providing support only where necessary.
• Respecting financial decisions made by service users who have the mental capacity to do so.
• Providing guidance and assistance to service users who require help managing their finances.

We will only support a service user with managing money where this is necessary, proportionate, in the person’s best interests where relevant, and supported by an appropriate lawful basis. This may include the service user’s informed consent, a valid Lasting Power of Attorney, deputyship, appointeeship, Court order, or other lawful authority. Where the service user has capacity to make the relevant financial decision, their choice, consent and control must be respected. Where the service user lacks capacity for a specific financial decision, the service will act in accordance with the Mental Capacity Act 2005, the least restrictive principle, and any lawful authority already in place. Staff or others working at the service must not act as an agent on behalf of a service user in relation to money, property or financial decisions unless they have clear lawful authority to do so.

3.2. Safeguarding Against Financial Abuse

Financial abuse can occur through fraud, coercion, misuse of funds, or unauthorised transactions. To prevent this, we:

• Conduct financial risk assessments for service users who need financial assistance.
• Implement strict authorisation procedures for handling service users’ money.
• Monitor financial transactions, ensuring funds are used appropriately.
• Encourage the use of independent advocates where service users require additional support.

Any suspicion, allegation or evidence of financial abuse, theft, fraud, coercion, misuse of money, undue influence, pressure in relation to property, or any other improper treatment must be responded to immediately under the Safeguarding Policy and local safeguarding procedures. Immediate action must be taken to protect the individual and others who may be at risk, preserve evidence, make appropriate referrals to the local authority and/or police where required, and maintain a full record of the concern, action taken and outcome. Notifications to CIW must be made where the matter falls within statutory notification requirements.

All staff receive mandatory training on recognising and preventing financial abuse.

3.3. Mental Capacity and Financial Decision-Making

Mental capacity is decision-specific and must never be assumed to be absent simply because a person needs support. Where there is concern about a service user’s ability to make a particular financial decision, the service will assess capacity in relation to that specific decision and at the time the decision needs to be made, in accordance with the Mental Capacity Act 2005.

Where the service user has capacity, staff will provide information and support in an accessible format so the person can make their own decision.

Where the service user lacks capacity for a specific financial decision, the service will:

• check whether there is a valid and applicable Lasting Power of Attorney, deputy, appointee or other lawful representative;
• make decisions in the person’s best interests only within the limits of the service’s lawful role and authority;
• involve the service user as far as possible;
• consult relevant representatives, advocates and professionals as appropriate; and
• keep a clear written record of the assessment, the decision, the reasons for it, who was consulted and any review date.

If the service user regains capacity in relation to the decision, they will be supported to resume control over their finances as soon as practicable.

3.4. Handling Cash and Personal Belongings

We ensure service users’ cash and valuables are stored securely by:

• Keeping small amounts of personal cash in locked safes, accessible only by authorised personnel.
• Logging all deposits and withdrawals, with two staff signatures for verification.
• Discouraging staff from handling large amounts of cash on behalf of service users.
• Providing receipts for all transactions conducted on behalf of the service user.

Any financial transactions made by staff must be authorised by the Registered Manager and recorded in the service user’s financial record.

Where the service holds a service user’s money for any purpose other than payment of agreed charges, that money must be kept in an account in the service user’s own name or in an account that enables clear demarcation of each service user’s funds. Such an account must not be used in connection with the management of the service and service user monies must never be pooled with service funds.

All money, valuables, bank cards, PIN-related information, benefit letters, financial documents, and other possessions accepted for safekeeping must be recorded on receipt, signed in and out, stored securely, and regularly checked. The record must show what was received, the date and time, the amount or description, who received it, where it is stored, and the date and manner of return or disposal.

Where staff support a service user to make a purchase, withdraw petty cash, or pay for agreed items, the transaction record must include the amount, purpose, date, receipt number where available, balance remaining, the name and signature of the staff member, and where possible the signature or confirmation of the service user or their lawful representative.

3.5. Banking and Financial Transactions

If a service user requires support with banking or routine money management, the service will promote independence and choice wherever possible. This may include support with budgeting, understanding balances, opening and operating a bank account, shopping, and making routine spending decisions.

Staff must not become signatories to a service user’s bank account and must not use a service user’s bank account, card, PIN, online banking access or financial information except where there is a clear, documented and lawful basis, a risk-assessed care arrangement, and management oversight.

Where support is provided with banking or financial transactions:

• the arrangement must be recorded in the service user’s personal plan and, where required, risk assessment;
• the extent and limits of support must be clearly defined;
• receipts and transaction records must be maintained;
• any unusual or high-value transaction must be escalated to the Registered Manager;
• the service must ensure that only staff who need to be involved are involved; and
• family members, advocates or lawful representatives should be involved where appropriate and lawful.

The service must ensure that staff who are not required to support the individual to manage their money, and any others working in or connected with the service, are precluded from involvement in the service user’s financial affairs.

3.6 Financial Auditing, Oversight and Compliance

The service will maintain effective arrangements for oversight and review of the management of service user finances. This will include routine managerial checks, regular internal audits, investigation of discrepancies, trend analysis, and action plans where improvement is required.

Audits will review, as appropriate:

• cash balances and reconciliations;
• receipts and expenditure records;
• records of valuables held for safekeeping;
• bank or account records where the service is authorised to hold or oversee funds;
• evidence that arrangements are reflected in personal plans;
• evidence of consent, lawful authority or best interests documentation;
• any incidents, complaints or safeguarding concerns relating to finances; and
• whether staff practice remains in line with this policy.

Concerns identified through audit must be acted upon promptly. Where the concern suggests abuse, neglect, theft, fraud, improper treatment or a notifiable incident, the matter will be managed under safeguarding, disciplinary, police referral and CIW notification processes as appropriate.

3.7. Service User Charges and Fees

All charges, care fees, and additional costs must be:

• Clearly explained in the service user’s contract.
• Transparent, fair, and regularly reviewed.
• Not deducted from service user funds without consent.

Any changes to charges must be communicated in writing to the service user and/or their representative.

The service agreement must clearly state what charges are payable by the service user, what they cover, any additional charges, the method of payment, any notice period for changes, and the circumstances in which the service may cease to be provided. A written estimate of likely costs and charges must be given in an accessible format so the service user, and where appropriate their representative, can make informed decisions.

3.8. Gifts, Donations, and Conflicts of Interest

To maintain ethical financial practices, we ensure:

• Staff do not accept personal gifts or money from service users.
• Service users are not pressured to give money to staff or other individuals.
• Any gifts or donations are declared and recorded, ensuring transparency.
• Any money donated to or collected specifically for the benefit of service users must be separately recorded and must not be used for routine service expenditure.

Any concerns regarding financial conflicts of interest must be reported immediately to the Registered Manager.

3.9 Personal Plans, Risk Assessments and Records

Where the service supports a service user to manage money, this must be clearly recorded in the service user’s personal plan. The personal plan must describe the nature of the support, the person’s preferences, the level of independence to be promoted, the specific risks identified, the safeguards in place, and the role of any lawful representative.

A financial risk assessment must be completed where there is a risk of financial abuse, self-neglect, exploitation, loss of money, unsafe spending, or dispute about who may support the individual.

The service will keep accurate, up-to-date and secure records of:

• money held by the service;
• money received, spent or returned on behalf of the service user;
• receipts and missing receipts;
• valuables and personal property held for safekeeping;
• capacity assessments and best interests decisions relating to finances;
• the authority of any attorney, deputy, appointee or representative;
• audits, discrepancies, investigations and outcomes; and
• any related complaint, incident, disciplinary or safeguarding action.

Records relating to adults will be retained securely for at least three years from the date of the last entry, unless a longer period is required by law or another organisational retention schedule. The service will make arrangements for the secure retention of records if the service closes.

3.10 Independent Advice, Advocacy and Financial Decision Support

Service users must be supported to access independent information, advice and advocacy concerning their financial affairs where this is required or requested. This includes support in relation to budgeting, benefits, debt, appointeeship, powers of attorney, deputyship, wills, bequests or legacies.

The service will not give legal or regulated financial advice unless properly authorised to do so. Where specialist advice is needed, the service will signpost or refer the service user, and where appropriate their representative, to an appropriate independent adviser or advocacy service.

4. Managing Service User Finances Efficiently

4.1. Leadership and Accountability

• The Registered Manager oversees compliance with all financial policies.
• The Responsible Individual will receive assurance through governance, audit and quality review processes that service users’ finances are managed lawfully, safely and transparently, and that learning from discrepancies, complaints and safeguarding concerns is used to improve the service.
• Finance staff and care teams follow procedures for managing service users’ money.
• Regular team meetings and supervision ensure staff are confident in financial procedures.

4.2. Staff Training and Awareness

• Staff whose role includes supporting service users with money, valuables or financial records will receive role-appropriate training in financial safeguarding, fraud awareness, the Mental Capacity Act 2005, consent and lawful authority, record keeping, receipts and reconciliations, confidentiality and data protection, whistleblowing, and escalation of concerns.
• Refresher courses ensure staff remain up to date with legal and policy changes.
• Case studies and real-life scenarios help staff recognise financial risks and abuse.

4.3. Monitoring and Continuous Improvement

• Quarterly audits identify trends, discrepancies, or risks.
• Incident trends are reviewed to identify areas for improvement.
• Service user and family feedback is used to refine procedures and enhance financial safeguards.
• CIW inspections and external audits provide additional oversight​.

The service will also review complaints, safeguarding concerns, incidents, disciplinary matters and notifications connected with service user finances to identify themes, reduce risk and improve practice.

5. Related Policies

This policy is supported by:

• CHW11 – Safe Care and Treatment Policy
• CHW13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• CHW16 – Health and Safety at Work Policy
• CHW18 – Risk Management and Assessment Policy
• CHW24 – Management of Accidents, Incidents, and Near Misses Policy
• CHW27 – Staff Supervision, Training, and Development Policy

6. Policy Review

This policy will be reviewed at least annually and sooner where there is any change to legislation, Welsh Government statutory guidance, CIW requirements, safeguarding procedures, inspection findings, learning from incidents or complaints, or any identified risk in the management of service user finances.

---

Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.