Registration Number: {{org_field_registration_no}}

Managing Service User Finances Policy

1. Purpose

The purpose of this policy is to outline {{org_field_name}}’s approach to managing and safeguarding service users’ finances. Our objective is to ensure that financial transactions involving service users are conducted with transparency, integrity, and accountability, while protecting service users from financial abuse, fraud, and mismanagement.

This policy ensures that all financial support provided by staff complies with the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (Fundamental Standards), including Regulation 9 (person-centred care), Regulation 10 (dignity and respect), Regulation 11 (need for consent), Regulation 12 (safe care and treatment), Regulation 13 (safeguarding service users from abuse and improper treatment), Regulation 16 (receiving and acting on complaints), Regulation 17 (good governance), Regulation 18 (staffing), Regulation 19 (fit and proper persons employed) and Regulation 20 (duty of candour), as well as the Care Act 2014, the Mental Capacity Act 2005 and other relevant legal and regulatory frameworks.

2. Scope

This policy applies to:

All domiciliary care staff, including care workers, coordinators, and management.
Service users receiving financial assistance or oversight from staff.
Families, legal representatives, and advocates involved in financial decision-making.
External bodies, including local authorities, social workers, and regulatory agencies.

It covers:

Roles and responsibilities in financial management.
Consent, capacity, and decision-making authority.
Handling of service user finances.
Prevention of financial abuse.
Record-keeping and audit processes.
Staff training and compliance.

3. Legal and Regulatory Framework

This policy aligns with, and should be read alongside, the following legislation, regulations and guidance:

Health and Social Care Act 2008 and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (Fundamental Standards) – setting out CQC’s regulatory framework for safe, effective and person-centred care, including safeguarding, good governance and duty of candour requirements.
Care Act 2014 and Care and Support Statutory Guidance (particularly Chapter 14 – Safeguarding adults at risk of abuse or neglect) – which define financial abuse and place duties on local authorities and partners to prevent and respond to abuse and neglect, including financial and material abuse.
Mental Capacity Act 2005 and Code of Practice – governing decision-making for people who may lack capacity, including financial decisions, best-interests decision-making and use of deputies or attorneys.
Financial Services Act 2012 – ensuring compliance with financial regulations where relevant.
Fraud Act 2006 – defining fraud offences and supporting prevention and detection of financial mismanagement and abuse.
UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018 – ensuring the lawful, fair and transparent processing of personal and financial information.
CQC Regulation 13: Safeguarding service users from abuse and improper treatment – including the explicit protection of people from financial abuse through theft, misuse or misappropriation of money or property belonging to a service user.
Local Safeguarding Adults Board procedures for reporting and responding to financial abuse or concerns about a person’s finances.

4. Roles and Responsibilities in Financial Management

Registered Manager:
- Oversees financial transactions involving service users.
- Ensures all staff follow financial procedures and safeguarding guidelines.
- Reviews and investigates any concerns of financial mismanagement.
Care Workers:
- Provide support with handling day-to-day financial tasks, such as shopping.
- Maintain accurate and transparent records of all transactions.
- Report any suspicions of financial abuse or irregularities immediately.
Service Users and Representatives:
- Where possible, service users retain control of their own finances.
- Families, Power of Attorney holders, or advocates may manage finances where authorised.

5. Consent, Capacity, and Decision-Making Authority

Before providing financial assistance, staff must obtain explicit consent from the service user.
Where a service user lacks capacity to manage their finances:
- A Mental Capacity Act assessment is conducted to determine decision-making ability.
- Decisions are made in the best interests of the service user, involving their legal representatives.
- Where necessary, a Deputy (appointed by the Court of Protection) or Power of Attorney takes financial responsibility.

All assessments of capacity in relation to financial decisions must follow the five statutory principles of the Mental Capacity Act 2005 and be decision-specific and time-specific. Staff must take all practicable steps to support the person to make their own decisions before concluding that they lack capacity. Where a person is assessed as lacking capacity for a particular financial decision, a recorded best-interests decision must be made, involving the person (as far as possible), their family, attorney or deputy, and other relevant professionals. Decisions must be the least restrictive of the person’s rights and freedoms.

6. Handling of Service User Finances

All financial transactions involving service users must be:

Transparent and accountable – Every transaction must be recorded contemporaneously in the individual’s financial record (paper or electronic) and be supported by an original receipt or other documentary evidence.
Limited to necessary expenses – Staff should only handle money for agreed, care-related purposes (for example, shopping, paying small bills, topping up utilities). Staff must not handle large sums of cash or manage savings or investments unless there is a formal, documented arrangement in place (e.g. appointee, deputy or attorney) and this has been risk-assessed and authorised by the Registered Manager.
Kept strictly separate from staff finances – Under no circumstances may staff mix their own money and a service user’s money, or store a service user’s funds in personal bank accounts or wallets.
Authorised and documented – Any purchase made on behalf of a service user must be agreed in advance with the service user (where they have capacity) or with their attorney/deputy/representative, and clearly documented in the care plan and financial records.
Checked and reconciled – Cash balances must be counted and reconciled regularly (and at least weekly where staff handle money) by two staff wherever practicable, with both signing the record. Any discrepancy must be reported immediately to the Registered Manager and investigated.
Carried out safely – Use of cash must be minimised. Where cards are used, staff should not know or record a service user’s PIN unless this has been formally risk-assessed, agreed in writing with the person (where they have capacity) or their legal representative, and clear controls are in place (for example, staff signing to confirm use and amount).
Supported by clear care plans – Each service user receiving financial support must have a care plan and risk assessment that set out what support is required, who is authorised to provide it, and any safeguards in place.
Open to review by the service user and/or their representative – Service users, their attorneys/deputies or representatives must be able to see and check their financial records on request.

Staff must never borrow money from, lend money to, or enter into personal financial arrangements (such as buying or selling goods, informal loans or running errands on credit) with service users or their families. Any request for this kind of arrangement must be politely declined and reported to the Registered Manager as a potential safeguarding risk.

7. Prevention of Financial Abuse

To protect service users from financial exploitation, {{org_field_name}}:

Provides mandatory safeguarding training on financial abuse for all staff.
Implements strict protocols on handling money, bank cards, and valuables.
Conducts random audits and spot checks on financial records.
Encourages service users to involve family members in financial decisions.
Implements whistleblowing procedures to report any concerns of financial misconduct.

Signs of Financial Abuse:

Sudden unexplained withdrawals or purchases.
Missing money, valuables, or documents.
A service user appearing anxious about money or pressured into transactions.
Unauthorised changes to financial records or Power of Attorney.

Any actual or suspected financial abuse is treated as a safeguarding concern in line with the Care Act 2014. This includes theft, fraud, misuse or misappropriation of money or property, being put under pressure in relation to money or property, and any unexplained or suspicious financial activity. Staff must report concerns immediately to the Registered Manager or on-call manager, who will take prompt action in line with local Safeguarding Adults Board procedures and, where appropriate, notify the local authority, CQC and any other relevant agencies.

8. Record-Keeping and Audit Processes

To maintain accountability and transparency, {{org_field_name}} requires:

Receipts and transaction logs for all financial transactions.
A designated financial record book for each service user requiring financial support.
Quarterly financial audits conducted by management to identify discrepancies.
Incident reporting procedures for any financial concerns or irregularities.

These arrangements form part of {{org_field_name}}’s wider governance system and support compliance with Regulation 17 (Good governance). Financial records must be retained, stored securely and disposed of in line with {{org_field_name}}’s data protection and record retention policies, the UK GDPR and the Data Protection Act 2018.

9. Staff Training and Compliance

All staff must:

Undergo mandatory financial safeguarding training.
Understand their legal responsibilities when assisting service users with finances.
Follow strict documentation and reporting procedures.
Report any suspicions of financial abuse immediately to the Registered Manager.

Training will be refreshed at appropriate intervals and will be aligned with current CQC guidance on safeguarding (including financial abuse) and, where applicable, national training standards on learning disability and autism.

10. Monitoring and Continuous Improvement

To ensure continued compliance and best practice:

This policy is reviewed annually or sooner if required.
Findings from financial audits and incident reports inform improvements.
Feedback from service users, families, and staff helps shape better financial support systems.
Any legal or regulatory updates are integrated into staff training and procedures.

11. Gifts, Gratuities, Loans and Bequests

Staff must maintain clear professional boundaries and must not seek or accept money, gifts, loans, tips or other financial benefits from service users or their families, except for small tokens (for example, low-value seasonal gifts) in line with {{org_field_name}}’s Gifts and Hospitality Policy.
Staff must not borrow money from, lend money to, or act as guarantor for any service user or their representative.
Staff must not influence, or appear to influence, any service user in relation to wills, property, inheritance, or other significant financial decisions and must not accept any role as executor or beneficiary of a service user’s will without prior written approval from the Registered Manager and, where appropriate, legal advice.
Any attempt by a service user or family member to make a staff member a significant beneficiary of a will, or to give a high-value gift or loan, must be reported to the Registered Manager and recorded as a potential safeguarding concern.

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.

DC41-Managing Service User Finances Policy