CAMPAIGN FOR AUTHORITES TO STOP USING NAFAO GUIDLINES

Campaign to stop local authorities using NAFAO guidelines when calculating disability related expenditure (DRE) in relation to household fuel allowance

The National Association of Financial Assessment Officers (NAFAO) is an unelected and unaccountable body. See https://www.nafao.org.uk/

NAFAO supply the guide used by local authority financial assessment officers when assessing DRE (Disability related expenditure). I am particularly concerned about the table used by local authorities – see below – in relation to DRE for household fuel allowance. The figures are not independently verified.

Figures for 2022/2023 Standard N East / E Midlands N West / W Midlands

Single person - Flat/Terrace £1,438.41 £1,559.22 £1,741.69

Couple – Flat/Terrace £1,897.75 £2,055.05 £2,295.42

Single person – Semi Detached £1,527.77 £1,656.11 £1,849.93

Couples – Semi Detached £2,016.90 £2,180.90 £2,436.37

Single – Detached £1,858.73 £2,013.54 £2,252.63

Couples – Detached £2,450.21 £2,654.08 £2,966.18

This table is wrong in a number of ways and I believe that the inaccuracy of the table costs service users assessed using this table about £1,000 a year.

Example Calculation

Service user household fuel bill is £1764.03 per year used in the calculation below.

£1764.03 MINUS £1527.77 DRE allowance 2022 semi-detached house = £236.26 per year.

Divide by 52. The DRE allowance for fuel is £4.55 per week.

Costs of Disability is expenditure that is incurred by a recipient of social care services that would not be incurred by someone who does not require social care services. It is essentially a cost related to someone’s disability that would not be incurred by a ‘standard’ or ‘average’ person that does not have a disability and the related impacts.

Some of the problems with the table are:

1. The standard figures in the table for a region are for all households and the service user is part of all households. When comparing the service user’s bill against a standard, a number is used that includes the service user’s higher than standard bill. This inflates what the figure for a standard bill should be.

2. The standard figures in the table for a region are for all households and this includes households of other social service users who would generally have higher than standard fuel bills. This inflates what the figure for a standard bill should be.

3. If figures for standard household bills are to be used as a comparison, they should be based on household bills of non-social services users only. This would be fairer and more accurate estimate of what a standard bill is.

4. In the table, the description of ‘semi-detached’ for a house is vague. A semi-detached house could be anything from 1 bedroom to 5 bedrooms or more, and could have a basement room or an attic room and a number of other rooms, e.g. study, separate dining and living rooms. To compare a 2 bedroom house to a vague ‘semi-detached’ house is unreasonable when the number of bedrooms and other rooms is not known.

5. According to the National Audit Office’s table 41 - which is what these figures are based upon – in footnote 5, it states

a. ‘The Retail Prices Index and its derivatives do not meet the required standards for designation as National Statistics. A full report can be found at: http://www.statisticsauthority.gov.uk/’

This means the figures are clearly not reliable or accurate enough to be used as a data standard. Also, when I asked the National Audit Office how NAFAO can construct this table from National Audit Office data, they said they did not know.

The trouble with trying to calculate DRE household fuel using the figures in this table, is that it is an estimate based on an estimate based on over inflated averages that include social services users’ household fuel bills, whereas it should only be based on household fuel bills of people who do not require social care services.

A more accurate, fair and reasonable way to calculate DRE household fuel figures is to start with the social services user’s household fuel bill and discuss with the service user an estimate how much of that is an extra costs due to disability and the related impacts. This is what I think local authorities should be doing.

When you start with the actual bill, you start with a figure that is actually known and relates to that specific social service user directly and the actual accommodation that they are living in, rather than on figures based on vague ‘semi-detached’ houses of indeterminate size with unknown number of occupants and unknown number of bedrooms. This is the way my DRE household fuel was calculated before.

I contacted Cascaidr https://www.cascaidr.org.uk/ about how best to challenge the use of these figures. They suggested the below.

It would be better to raise awareness of what's wrong with the table at a national level, so that NAFAO comes under pressure from councils who will be embarrassed by logical mistakes and lean on NAFAO.

Local authorities’ reliance on these figures is what matters. The table provides some standard or average figures that local authorities use as a starting point in calculations, but they do have to consider every case individually. They have to have a reasonable rationale for relying on a table from an outside body, and if you marshal your arguments about the irrationality of the figures for the purpose for which they're being used, they have to give you reasons for continuing to rely on them.

I am looking for people who are interested in a campaign to stop this table in the NAFAO guide being used by local authorities when calculating DRE for household fuel allowance.

Don O’Neal

donboy667@yahoo.co.uk

twitter - @ONealDonaldM