Housing Assocations Guide Part 6 Appendix 3
Adaptations to Dwellings
(For Tenants with physical disabilities or sensory impairments)
Contents
1.01Application – this Appendix of the Guide covers the procedures and requirements for the approval and payment of Housing Association Grant (HAG) to Associations, undertaking ‘structural’ adaptations to make dwellings more suitable for tenants with physical disabilities or sensory impairments.
1.02Physical disabilities or sensory impairments – that have substantial and long term adverse effects on the person’s ability to carry out normal day to day living activities, can arise as a result of injury or from birth, but are more likely to be progressive and as a consequence of the person’s health or age. Once the need for a ‘structural’ adaptation arises, this can cause considerable hardship for the person with, for example, the person being unable to take a bath, or to use the toilet facility unaided. As a temporary measure, friends and family can help, but in some cases assistance has to be provided through Health Trusts or even respite care in Residential Homes or Hospitals. As the weekly or monthly cost of such care can easily exceed the cost of the adaptation this is also an important reason for reducing the implementation time for the ‘structural’ features to the minimum.
1.03‘Structural’ Adaptations - can apply to:
- Existing dwellings;
- Dwellings under construction; or
- New dwellings - including dwellings acquired as Existing Satisfactory Purchases (ESPs) and Off-the-Shelf purchases.
1.04Adaptations - can be for existing tenants or new tenants (including a person who normally resides in the household of the tenant, a licensee in shared housing, and for communal use by one or more tenants in a shared housing situation). Associations should attach a high priority to undertaking ‘structural’ adaptations to enable tenants with physical disabilities or sensory impairments to continue living safely and conveniently – and with independence, privacy and dignity - in their existing dwellings or to take up a new tenancy in a dwelling better suited for their particular needs. Adaptations are mainly to help tenants achieve the maximum level of their ability in all aspects of daily life, but can also include ‘structural’ facilities to help carers provide essential help and assistance to the tenant – e.g., larger shower to allow for assistance.
1.05Options - in the majority of cases, the tenant’s existing dwelling can be adapted for the tenant’s specific needs. However, in a number of cases, alternative housing options may need to be considered, and adaptations undertaken to make the dwelling suitable for the tenant’s particular needs. The provision of new and rehabilitated housing for rent by Associations is covered in Parts 1 to 4 of the Housing Association Guide.
1.06Grant Position - adaptations are eligible for 100% Grant from the NIHE (DPG) – this is to ensure that the normal rental income charged on the dwelling is not affected and remains at normal levels. Grant-aid from NIHE (DPG) to a Housing Association is subject to the conditions set out below.
2.00 Revised procedures for adaptations
2.01This Appendix - revised and replaced previous approval arrangements and requires an Association claiming Grant to:
- Identify the needs of the individual in association with the relevant Health Trust’s Occupational Therapist (OT), where estimated works costs are likely to exceed £1,000;
- To undertake an ‘Options Appraisal’ before proceeding where estimated works costs are likely to exceed £7,000; and
- To complete the work before applying for grant at practical completion stage.
[Notes: 1. As a general rule, the NIHE (DPG) will only accept, for grant purposes, Occupational Therapist (OT) assessments and recommendations. The only exception to this rule is where the OT delegates the assessment to a particular ‘specialist’ – e.g., a specialist Social Worker for the deaf.
2. Where the works cost of adaptations to any single dwelling is likely to exceed £20,000 the Association must inform the NIHE (DPG) of the situation as early as possible and also complete the Adaptations Checklist (Form AC1) for Schemes over £20,000 (see Annex E). This ensures NIHE (DPG) is provided with preliminary details before work starts to ensure that, in high-costing schemes, the Association is achieving best value for money. This will also ensure that Grant will be available when the Association makes an application for HAG in accordance with the new procedures.]
2.02Streamlined Procedures - these streamlined procedures have been in place for some time. Only schemes complying with the revised procedures should be submitted to the NIHE (DPG) for payment of Grant.
2.03 The Change in Procedures - which requires Associations to complete the work before applying for Grant was an extension of an existing facility that allowed work to be completed prior to project approval and Grant claim. The main purpose of the change was to allow Associations to respond more quickly to requests for adaptations and to reduce administrative requirements to the minimum. However, in all cases it is essential that ‘best value for money’ criteria and accountability are maintained and these will be achieved by:
- Adherence to the procedures by Associations;
- Certification by Associations; and
- Audit by the DSD.
3.00 Items eligible for grant
3.01Structural Items - as a general rule, Housing Association Grant (HAG) is restricted to items, which because they are fixed to or become a permanent part of the structure of a dwelling may be regarded as ‘structural.’ It should be noted that the ‘structure’ of a dwelling also includes the incurtilage part of the dwelling such as gardens, private open spaces, any designated car-parking area, car-port or existing garage associated with the dwelling. Examples of ‘structural’ features are listed at Annex A.
4.00 Items ineligible for grant
4.01Non-structural’ - items such as portable aids and equipment are considered to be the responsibility of Health Trusts and are not eligible for funding from the NIHE (DPG). Examples of ‘non-structural’ items are listed at Annex B. Also ineligible, are costs normally associated with Acquisition & Works or Works Only schemes, and Major Repairs, Miscellaneous Works, and Maintenance items, or items which were required to be provided by the various design standards applicable at the time the dwelling was build. An example would be ramped or level access to a wheelchair bungalow.
5.00 Housing Association Grant (HAG)
5.01Works (adaptations) to dwellings - are eligible for Housing Association Grant (HAG) if they:
- Are necessary to make the dwelling more suitable for an existing or new tenant - including a person who normally resides in the household of the tenant, a licensee in shared housing, and for communal use by one or more tenants in a shared housing situation - with physical disabilities and/or sensory impairments;
- If they are by definition ‘structural’; and
- If they comply with the requirements for funding.
Necessary works costs – including the ‘net’ works cost, any VAT applicable to the works cost and the on-cost applicable to the scheme - will be eligible for 100% HAG funding from the NIHE (DPG).
5.02Value Added Tax (VAT) - in undertaking adaptations for an individual tenant with physical disabilities, the supply of some goods and services may be zero-rated for VAT purposes – see Annex E. Grant-aid from NIHE (DPG) is only available on standard-rated VAT, where such VAT applies.
[Note: Reduced rate VAT is available for certain energy saving items e.g. electronic timers and thermostats for central heating units. Please see HMRC VAT Notice 708/6 (August 2006) for further details, also refer to HMRC VAT Notice 701/7 Part 6: VAT relief for disabled people, & HMRC VAT Notice 708/5: Registered Social Landlords.]
5.03On-Costs - a fixed on-cost of 14% applies to any eligible works and to any standard-rated VAT applicable to the eligible works costs.
[Note: An optional supplementary on-cost of +2% can be applied where the Association has a suitable ‘priced schedule’ contract in place for undertaking the adaptation works; or an optional supplementary on-cost of +4% can be applied where extensive alterations and extensions are necessary to the dwelling, to warrant the Association taking out a suitable form of Building Warranty or Defects Liability Insurance on the works (see Appendix: 2 to Part 4).]
5.04Tranche Payments - valid applications for Housing Association Grant (HAG) for adaptations will normally be paid in one Tranche after practical completion stage.
6.00 Action by the Association
6.01Policy Statement - Associations should formally adopt a policy statement, which sets out the organisation’s approach to the provision of adaptations to its housing stock, and the priority that should be attached to undertaking this type of work. In order to expedite adaptations, the Association should appoint a member of staff to oversee all adaptations and act as a ‘contact point’ for queries and progress. The appointment of consultants, contractual arrangements and the Association’s formal approval of schemes should be streamlined where possible, and performance/time targets established for the various processes.
6.02Need for Adaptations - the need for adaptations may be initially identified to the Association in a number of ways, including the tenant, a tenant’s relative or representative, a member of the Association’s staff, or through Health and Social Services sources. The Association needs to have suitable internal systems in place to record and action requests for adaptations and should identify the ‘structural’ features required by the tenant. In cases where:
a.The ‘structural’ features required are relatively minor – i.e., where the estimated works costs are unlikely to exceed £1,000 – the Association may proceed without obtaining specialist advice from an Occupational Therapist, provided the features are necessary and relevant for the tenant’s needs. Examples of minor ‘structural’ features are listed at Annex C.
b.The ‘structural’ features required are more complex – i.e., where the estimated works costs are likely to exceed £1,000 –the Association must obtain specialist advice from the Occupational Therapist attached to the relevant Health Trust (or from a particular ‘specialist’ delegated by the OT – e.g., a Social Worker for the sensory impaired). The Association should request a suitable letter or report from the Occupational Therapist listing the ‘structural’ features required for the specific needs of the tenant.
6.03Associations should note - that HAG can only be claimed on the net cost of achieving the ‘structural’ features identified as necessary for the tenant. As an example, in dwellings under construction any estimated savings due to omissions must be deducted from the adaptations works costs (In simple terms, the net cost is the additional cost that the adaptation incurs over and above the norm).
6.04Liaison with the Occupational Therapist (OT) - the DSD considers that good liaison between the Association and the OT is essential to discuss the tenant’s specific requirements and any problems/ alternatives should be resolved quickly to enable the adaptation works to be carried out within a reasonable time-span. As well as identifying the tenant’s immediate needs, anticipated future needs must also be considered - this is to ensure the adaptations proposed will suffice for a suitable period of time and meet ‘best value’ objectives. In cases, where the existing dwelling cannot readily be modified to meet the needs of an existing tenant, other housing solutions may need to be considered. Although an OT has a great deal of experience in assessing the needs of disabled people, it is not reasonable to expect them to understand the construction implications of their recommendations (this particularly refers to major adaptation work). It is therefore important that any OT recommendation is considered by a staff member of the Association who understands the construction implications/ practicality etc. Alternatively recommendations can be referred to a Consultant if there are any construction issues. It is DSD’s view that Associations should not implement OT recommendations without first examining them, and engaging with the OT to resolve any construction issues that arise. Where estimated works costs are likely to exceed £7,000 for a particular dwelling, the Association should undertake an ‘Option Appraisal’ before the decision to proceed is taken – see Annex D.
6.05Standards to be achieved – whilst generally the OT will be able to advise Associations on the required ‘structural’ features, the specification and associated space requirements etc., this may not be the case when the requirements are more complex and/or technical. Advice on designing for the disabled is contained in Part 3 of the Guide, Design Requirements. In the case of ‘structural’ adaptations costing under £1,000 – where no OT advice is necessary – there are various information sources available to Associations, including: The Disabled Living Foundation (www.dlf.org.uk ). General advice on adaptations can be found in a Good Practice Guide “Wheelchair Housing Design Guide”, by S. Thorpe.
6.06Once the necessary ‘structural’ features have been identified – which the Association considers to be practical and can be achieved at reasonable cost – the Association should arrange for the works to be undertaken without undue delay. Guidance on Procurement Requirements for adaptations is contained in Annex E.
[Note: The Association should consider the extent of the adaptation requirements identified in the OT report (where applicable), and develop a specification / schedule of works / drawings (if required) incorporating all the associated works, to allow for the supply of competitive quotations. Similarly, the Association should ensure that the tenant is kept informed of the proposed work programme & liaised with to agree suitable dates / times for Contractor or Supplier access.]
6.07Adaptations to Lifetime Homes – Associations should take care when implementing adaptations to dwellings with Lifetime Homes status. It is important to ensure that the Lifetime Homes status of the dwelling is not compromised. The requirements of this standard are explained in detail in Appendix: 1 to Part 3 of the Guide. In summary, the standard is designed to ensure that the home is flexible, adaptable and accessible throughout a person’s lifetime. Compromising this standard e.g. by replacing a bath with a shower adaptation would mean that the adaptation would be unlikely to receive grant funding. Furthermore, NIHE (DPG) could ultimately recoup the enhanced grant which was paid in respect of the provision of the dwelling.
It is recognised however that in certain exceptional circumstances, following liaison between the Association and the OT, a satisfactory alternative may not be available. In such cases the Association should write to NIHE (DPG), providing a copy of the OT report and full details of the proposed adaptation. Work should only be carried out with the prior written consent of NIHE (DPG).
6.08Decanting – in certain cases e.g. major adaptations such as extensions, it might be considered necessary for the tenant to be decanted for the duration of the work. Decisions regarding possible decanting should be made by the Association following liaison with the contractor, tenant, OT and other relevant health professionals, where appropriate.
[Note: Grant funding is not available from NIHE (DPG) for additional costs as a result of decanting].
6.09Quarterly Return – on a quarterly basis NIHE (DPG) will contact Associations for details of all adaptations planned or that have been carried out but not yet claimed. It is imperative that this return is completed accurately and promptly. Failure to advise NIHE (DPG) of unclaimed adaptations may result in insufficient funds being available to meet a subsequent claim. Associations are asked to ensure that adaptation claims are submitted promptly having regard to the guidance set out in Para 6.12.
6.10At Practical Completion Stage - the Association should determine the final cost of each adaptation scheme, and submit a Grant application to the NIHE(DPG) on Form AW 1 – see Annex F to this Part of the Guide. This Form is signed by a Member or Officer of the Association, acting with the delegated authority of the Management Committee. The Association will submit the following documents:
- Form AW1, for one or more completed adaptation schemes;
- Receipted invoice(s), clearly identifying works costs applicable to each dwelling (or equivalent documentation – e.g., certificate of practical completion and Consultant’s breakdown of works costs applicable to each dwelling);
- Copy of the Occupational Therapist’s report, where relevant.
6.11Certification by the Association - the requirements, on which the Association will certify compliance with this Appendix of the Guide, is included on Form AW1, Certifications (see Annex F).
6.12Grant Claim – Associations should either forward claim for grant in batches of 10 adaptations or within 12-months of practical completion of the works, whichever is earlier.
7.00 Action by the Northern Ireland Housing Executive (DPG)
7.01On receipt of a valid application for Grant – the NIHE (DPG) will check that the submission is complete and that the Form has been signed by an authorised signatory. It will then check briefly that the works are eligible for grant in accordance with the criteria laid down in this Appendix of the Guide. If satisfied the NIHE (DPG) will issue approval on Form AW 2 – see Annex G - and advance the amount of Grant due to the Association’s bank account.
7.02Advice on how to proceed – if an Association is unsure of the procedures with a difficult or exceptional case, the Association should contact the NIHE (DPG) for advice.
8.01Regulation and Inspection – as part of this process the DSD will check the validity and accuracy of the Certifications given by the Association as part of the procedures for Grant. The main purpose will be to verify that all the DSD’s requirements and conditions have been met, and that the Association has properly exercised its responsibilities set out in the relevant Appendix of the Guide. This does not reduce the responsibility of the Association to ensure that the costs of any claim for Grant are appropriate and have been properly incurred.
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