{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

---

Managing Service User Finances Policy

1. Purpose

This policy sets out how {{org_field_name}} supports people who use the service to manage their money safely, lawfully, transparently and in a person-centred way. It applies where staff provide support with budgeting, shopping, bill payment, accessing cash, benefits-related tasks, safekeeping of small sums of money, or record-keeping in relation to money handled on a person’s behalf.

This policy is intended to support compliance with the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 including Regulation 11 (Need for consent), Regulation 12 (Safe care and treatment), Regulation 13 (Safeguarding service users from abuse and improper treatment), Regulation 17 (Good governance), Regulation 18 (Staffing), Regulation 19 (Fit and proper persons employed), the Care Act 2014, the Mental Capacity Act 2005, the Mental Capacity Act Code of Practice, data protection law, and other applicable financial safeguarding requirements.

The policy aims to:

• promote independence and maximise each person’s control over their own money wherever possible;
• ensure staff only provide the level of support that has been assessed, agreed, recorded and kept under review;
• protect people from financial abuse, coercion, theft, fraud, misappropriation and avoidable financial harm;
• ensure that staff do not exceed their role or act without lawful authority;
• require accurate, contemporaneous and auditable records for every transaction supported by the service;
• ensure concerns, discrepancies and incidents are escalated promptly through safeguarding, management and, where appropriate, external reporting routes; and
• support compliance with CQC fundamental standards through safe systems, staff competence, oversight and continuous quality monitoring.

2. Scope

This policy applies to all permanent, temporary, bank, agency, student and volunteer staff, and to managers who may in any way support a person with money or access to money.

It applies to all situations where the service:

• supports a person to understand, budget, save, shop or pay for goods or services;
• supports access to cash, bank accounts, benefit income or personal allowances;
• holds or stores small amounts of money or financial records on a temporary basis;
• keeps records of financial transactions carried out with or for the person; or
• liaises with attorneys, deputies, DWP appointees, local authorities, family members, advocates or other third parties about a person’s finances.

This policy does not permit staff to take control of a person’s finances outside an assessed, authorised and documented arrangement. Staff must not act as an attorney, deputy or appointee unless formally appointed and authorised to do so through the proper legal process and approved by the organisation.

3. Related Policies

• SL07 – Person-Centred Care Policy
• SL08 – Dignity and Respect Policy
• SL09 – Consent to Care Policy
• SL13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• SL34 – Confidentiality and Data Protection (GDPR) Policy
• SL39 – Mental Capacity and Deprivation of Liberty Safeguards Policy
• SL42 – Communication and Engagement with Service Users and Families Policy
• SL17 – Infection Prevention and Control Policy (where applicable to financial documents handling)

4. Principles

Promoting autonomy and independence
People should manage their own money wherever they are able to do so, with support adjusted to the minimum necessary level.

Presumption of capacity
Capacity must always be presumed unless there is a proper reason to assess it. A person must be given practicable support to make their own financial decisions before anyone concludes that they cannot do so.

Least restrictive practice
Any support provided must be the least restrictive option and must not remove control from the person unless this is lawful, necessary and properly documented.

Lawful authority and role clarity
Staff may support but must not assume legal control of finances unless there is clear legal authority and organisational approval. Support with money must never blur into unauthorised control.

Transparency and auditability
Every transaction supported by the service must be evidenced, traceable, signed or otherwise verified, and capable of being checked by management and, where appropriate, by the person or their representative.

Safeguarding and prevention of abuse
The service will take all reasonable steps to prevent financial abuse, coercion, theft, fraud, exploitation, undue influence and conflicts of interest.

Professional boundaries
Staff must not borrow from, lend to, gift money to, receive money from, use loyalty points belonging to, or benefit personally from the finances of people using the service.

Confidentiality and dignity
Financial information must be handled discreetly, securely and only shared on a need-to-know and lawful basis.

5. Financial Management Procedures

5.1 Assessing Capacity and Decision-Making

Capacity is decision-specific and time-specific. A person must not be treated as unable to make a financial decision merely because they make an unwise decision. Where there is reason to doubt a person’s ability to make a particular decision about money, the service must assess capacity in line with the Mental Capacity Act 2005 and the Mental Capacity Act Code of Practice.

Before concluding that a person lacks capacity, staff must take all practicable steps to support decision-making. This may include using accessible information, preferred communication methods, visual prompts, quieter settings, trusted supporters, interpreters, advocates, or allowing additional time.

Any assessment of capacity relating to finances must clearly record:

• the specific decision to be made;
• why there is doubt about capacity;
• what support was offered to enable decision-making;
• the outcome of the assessment;
• who completed the assessment and their role;
• who else was consulted; and
• the date for review where the situation may change.

Where a person is assessed as lacking capacity for a specific financial decision, any action taken must be in their best interests, be proportionate to the risk, and be the least restrictive option. Best-interests decisions must be properly recorded and, where appropriate, involve family, advocates, attorneys, deputies, appointees, commissioners and other relevant professionals.

Staff must not rely on a general statement that a person “lacks capacity with money”. Capacity must be considered in relation to the actual decision in question, such as managing a weekly budget, making a one-off purchase, understanding a tenancy charge, or consenting to support with shopping.

5.2 Legal Authority to Manage Finances

The service must clearly distinguish between:

• support given to a person who retains capacity;
• support given to a person who lacks capacity but where staff are only carrying out agreed practical tasks; and
• formal legal authority held by another person or body to manage finances.

Legal authority may include:

• a Property and Financial Affairs Lasting Power of Attorney;
• a Court of Protection deputyship for property and affairs;
• a DWP appointeeship for benefit matters only; or
• another lawful arrangement recognised by the relevant public authority.

Staff must verify and record the nature and extent of any third party’s authority before sharing financial information, accepting instructions, handing over money, or supporting financial decisions on that basis.

A DWP appointeeship relates to benefits and does not automatically give authority over all other financial matters. Staff must not assume that an appointee, family member or informal representative has authority beyond what is formally in place.

Copies or verified details of the relevant authority must be retained on the person’s file in accordance with confidentiality and data protection requirements.

5.3 Bank Accounts, Cards, PINs and Day-to-Day Money Handling

People should, wherever possible, hold and use their own bank accounts in their own name and be supported to manage these as independently as possible.

Staff must not:

• open, operate or control a bank account in a person’s name unless this forms part of a lawful, documented and authorised arrangement;
• use any organisational bank account to hold personal money belonging to a person using the service;
• use their own personal account, card, wallet or cash to hold or process money for a person using the service;
• keep a person’s bank card, cheque book, PIN, password or online banking credentials unless there is a clear risk assessment, written authorisation, documented rationale, and management oversight; or
• make withdrawals, transfers or purchases that are not evidenced, agreed and recorded.

Where staff support a person to access cash or make purchases, the level of support must be set out in the care and support documentation or risk assessment and must state:

• what support is required;
• when and why it is required;
• any limits on amounts;
• whether one or two staff are required;
• how the transaction will be evidenced; and
• what review arrangements apply.

Each supported transaction must be recorded contemporaneously and include the date, amount, purpose, running balance where applicable, name of the person, name and signature of staff involved, and the signature or confirmation of the person wherever possible.

5.4 Cash Handling, Storage and Reconciliation

The service should avoid holding cash for people unless there is a clear assessed need. Where cash is held temporarily, the arrangement must be risk assessed, authorised by the manager and clearly recorded.

Cash held on the premises must:

• be kept separately for each person;
• be stored securely;
• have a clearly recorded opening balance;
• be reconciled after every transaction; and
• be subject to regular and unannounced checks by management.

Receipts must be obtained for all purchases wherever reasonably possible. If a receipt is unavailable, the reason must be recorded, together with the item purchased, date, amount and staff involved.

Where change is returned after a purchase, this must be counted and recorded at the time of return.

Any discrepancy, missing money, unexplained balance difference, missing receipt, unusual withdrawal pattern or concern about staff practice must be treated as a potential safeguarding and governance issue and escalated immediately to the manager. The manager must decide whether safeguarding referral, disciplinary action, incident reporting, police involvement, commissioner notification or other action is required.

Financial reconciliation records must be reviewed at defined intervals by the manager and included in the provider’s wider audit system.

5.5 Budgeting, Bill Payments and Planned Expenditure

Staff should support people to understand income, essential expenditure, discretionary spending, savings goals and financial commitments in a way that matches their communication needs and level of understanding.

Any regular support with budgeting, tenancy-related payments, utility payments, shopping plans or savings must be recorded in the person’s support plan or finance support plan.

Where staff support a person to make payments, the record must show:

• what was paid;
• the amount;
• the date;
• the reason for the payment;
• how consent or best-interests authority was established; and
• what evidence was retained.

Online banking, banking apps, contactless payments or digital wallets must only be supported where risks have been assessed and controls are in place regarding access, confidentiality, fraud prevention, device security and record keeping.

Staff must not make financial decisions for a person merely for convenience. Where the person has capacity, the person remains the decision-maker.

5.6 Prevention, Recognition and Reporting of Financial Abuse

The service recognises financial abuse as a form of abuse and will act promptly on any concern, allegation, pattern or indicator suggesting theft, fraud, coercion, exploitation, misuse of benefits, misuse of cards or PINs, pressure to hand over money, misuse of online banking, inappropriate staff involvement in finances, or unexplained loss of money or possessions.

Indicators may include:

• missing cash, cards, valuables or receipts;
• unusual or unexplained withdrawals or transfers;
• sudden changes in spending pattern;
• unexplained debt, arrears or repeated lack of money for essentials;
• pressure from relatives, staff or others to give money or buy items;
• signatures, agreements or transactions the person does not understand; or
• reluctance, anxiety or distress when finances are discussed.

All staff must report concerns immediately in line with safeguarding procedures. Concerns must never be minimised because the amount involved appears small.

The manager or safeguarding lead must ensure that concerns are documented, immediate protective action is taken where required, and referrals are made to the local authority safeguarding team and any other relevant body without delay where thresholds are met.

Staff must not accept loans, cash gifts, substantial gifts, bequests, shopping benefits, reward points, or any personal financial advantage from people using the service or those close to them. Any low-value token of appreciation must be managed strictly in line with the organisation’s gifts and hospitality rules.

5.7 Benefits, Appointeeship and Third-Party Financial Roles

People must be supported to access the benefits, personal allowances and other financial entitlements to which they are entitled.

Staff may assist a person to understand correspondence, complete forms, attend appointments or gather evidence, but must not assume control of benefit income unless there is a lawful basis and organisational authorisation.

Where a DWP appointee is in place, the service must clearly record:

• who the appointee is;
• the scope of the appointee’s authority;
• how staff will liaise with the appointee;
• what financial information may be shared; and
• how the person’s day-to-day needs, dignity and preferences will be respected.

The service must not assume that a DWP appointee can make decisions beyond benefits administration. Where wider financial authority is needed, this must be considered through the appropriate legal route, such as deputyship or a valid LPA.

Any concerns about misuse of benefits or misuse of an appointeeship arrangement must be treated as a safeguarding concern and escalated immediately.

5.8 Governance, Audit and Management Oversight

The provider must maintain effective systems to assess, monitor and improve the safety, quality and integrity of all arrangements involving support with money.

This must include:

• routine reconciliation checks;
• scheduled monthly audits of financial records;
• unannounced spot checks;
• management review of discrepancies, incidents and safeguarding alerts;
• review of whether support levels remain appropriate and least restrictive;
• review of staff competence and compliance; and
• identification of patterns, themes and lessons learned across the service.

Audit findings must be recorded, actions allocated, timescales set and completion monitored.

Where audits identify repeated poor recording, missing receipts, unexplained variances, weak supervision or blurred staff boundaries, the provider must take prompt remedial action.

People using the service and, where appropriate, their lawful representatives must be able to see clear and understandable records relating to money handled with or for them, subject to confidentiality and lawful information-sharing rules.

5.9 Individual Finance Risk Assessment and Support Plan

Where a person needs any support with finances, the service must complete and maintain an individual finance risk assessment and, where appropriate, a finance support plan.

This must set out:

• what the person can do independently;
• what support is required and why;
• the person’s wishes, preferences and goals;
• any known risks of exploitation, self-neglect, scams, coercion or impulsive spending;
• who is authorised to support specific tasks;
• any limits, controls or escalation arrangements; and
• how often the arrangement will be reviewed.

The assessment must take account of capacity, communication needs, safeguarding history, digital banking risks, tenancy and benefit responsibilities, and the least restrictive approach.

5.10 Staff Conduct and Prohibited Practices

Staff must maintain strict professional boundaries when supporting people with finances.

The following are prohibited unless explicitly authorised by law, assessed, documented and approved through organisational procedures:

• borrowing or lending money;
• using a person’s money for shared household purchases without clear agreement and records;
• holding bank cards, PINs, passwords or devices informally;
• making online purchases through a staff member’s own account;
• combining funds belonging to different people;
• using personal loyalty cards, cashback schemes or discount accounts when shopping for a person if the benefit goes to the staff member;
• witnessing or influencing wills, gifts, transfers of money or major purchases where there is a conflict of interest;
• keeping blank signed withdrawal slips, cheques or forms; and
• delaying reporting of discrepancies or concerns.

Breach of this section may be treated as misconduct or gross misconduct and may also trigger safeguarding, referral to external agencies or criminal investigation.

6. Training and Competence

Staff who support people with finances must receive training and competence assessment appropriate to their role. This must include:

• safeguarding adults, including financial abuse;
• the Mental Capacity Act 2005 and best-interests decision-making;
• consent and supported decision-making;
• professional boundaries and conflicts of interest;
• fraud awareness and scam prevention;
• accurate financial record keeping and reconciliation;
• incident reporting and escalation;
• confidentiality and data protection in relation to financial information; and
• any local systems used for finance records or audits.

Managers must ensure staff are competent before they undertake unsupervised support with money. Refresher training and supervision must be provided at appropriate intervals and whenever audits, incidents or changes in law or guidance indicate a need.

7. Confidentiality, Information Sharing and Records Security

Financial records must be complete, accurate, legible, contemporaneous, stored securely and accessible only to authorised persons.

The service must handle financial information in accordance with data protection law, confidentiality requirements and the person’s rights.

Information about a person’s finances must only be shared:

• with the person;
• with someone who has lawful authority or a proper professional need to know;
• where this is necessary for care, safeguarding, benefit administration or legal compliance; or
• where disclosure is otherwise lawful and proportionate.

Copies of receipts, logs, reconciliations, best-interests records, appointeeship details, deputyship or LPA documents, and audit records must be retained in line with the organisation’s record-retention arrangements.

8. Review, Assurance and Version Control

This policy will be reviewed at least annually and sooner if there is:

• a change in legislation, regulation, statutory guidance or CQC guidance;
• a safeguarding incident, financial discrepancy or audit finding indicating that changes are needed;
• a change to the service model or the way financial support is provided; or
• learning from complaints, concerns, whistleblowing or investigations.

Reviews must consider whether the policy remains consistent with current CQC fundamental standards, current safeguarding duties and the Mental Capacity Act framework.

---

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.