Item 8 Charging Policy for Non Residential Care Services 2025_26

West Dunbartonshire Council · 5 March 2025
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Health and Social Care Partnership (HSCP)
Council: 5 March 2025
Subject: Charging Policy for Non-Residential Care Services 2025/2026
1. Purpose
1.1 To present an overview of the proposed changes to West Dunbartonshire Council’s
Charging Policy for Non-Residential Care Services 2025/26 for consideration and
approval.
2. Recommendations
2.1 It is recommended that Council:
Approves the following amendments to the 2025/26 Charging Policy for Non-
Residential Care Services after consideration of the consultation outputs and
current guidance:
i. Strengthening of current policy wording around the inclusion of partners
earnings when undertaking a Financial Assessment, to remove current
ambiguity;
ii. Set Minimum Income Thresholds for a single person or couple based on
being either under state pension qualifying age or over pension
qualifying age;
iii. Agree that people who are in receipt of Independent Living Fund (ILF)
will be subject to a Financial Assessment and may be required to make
a contribution to their care package;
iv. Increase the current percentage taper on disposable income, in excess
of the Minimum Income Threshold from 50% to 75%; and
v. Retain the maximum weekly charge for services which will increase by
5% to £90.50 in 2025/26.
3. Background
3.1 Levying charges for some non-residential social care services is common practice
across Councils and forms part of the delegated budget to the Health and Social
Care Partnership (HSCP) Board. While the income derived from charging forms part
of the delegated net budget, the legal authority to levy and set charges remains with
the local authority.
3.2 Since the introduction of the Community Care & Health (Scotland) Act 2002, the
Convention of Scottish Local Authorities (COSLA) has produced annual guidance
which defines a set of principles to underpin the development of local charging
policies for social care support for people at home.
3.3 The levying of non-residential charges was addressed within “The Independent
Review of Adult Social Care” report published in February 2021. In March 2021,
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the Scottish Government and COSLA published a Joint Statement of Intent on
how they would work together to deliver on the Review’s recommendations.
This included agreement on: “an end to charging for non-residential services as
soon as possible”. 
3.4 The current Charging Policy was approved by Council on the 9th March 2022. 
At this time the Council agreed to remove thresholds of income based on age
and to remove charging for Independent Living Fund service users. This
approval was on the understanding, that charging for social care support was to
be abolished by the Scottish Government and Council funding increase to cover
the ability to raise income from charging.
3.5 While the abolition of charges remains a joint intent, there is no clear timeline for
this, especially in light of national budgetary pressures.  Locally, the changes
made in 2022 have been revisited via consultation undertaken in October 2024
and the revised policy changes recommended for approval in section 2.1 above,
reflect the consultation output as well as remaining consistent with COSLA
guidance. 
3.6 The proposed changes to the Charging Policy should also aid in reducing the
current under-recovery of income from non-residential charges forecasted in
2024/25 as circa £0.465m (flat-rate charges for day centre places and community
alarms are £0.408m under-recovered and means-tested support charges are
£0.057m under-recovered) against a budget of £1.405m (flat-rate charges budget is
£1.003m and means-tested support budget is £0.402m).  However it should be
noted that £0.286m of the current projection relates to reduction in income from
community alarms after a significant data cleanse and providing only personal care
services for those eligible for care at home support.
3.7 Each year income thresholds are increased in line with the Department of Work and
Pensions (DWP) rates and actual charges levied are updated to in line with Council
decisions on the annual percentage uplift to sales, fees and charges.  In 2023, a 4%
uplift was agreed by Council on the 15 March 2023.  In 2024, a 10% uplift was
agreed by Council on the 28 March 2024.
3.8 On the 18 December 2024, the Council agreed a 5 % uplift on charges across the
Local Authority.  The 2025/26 Charging Policy (attached at Appendix 2) schedule of
rates has been updated to reflect this uplift.
3.9 The 2025/26 revised Charging Policy continues to comply with COSLA’s latest
guidance.  West Dunbartonshire Council’s Charging Policy’s main aims are to:
a) Provide a consistent, fair and transparent framework for charging;
b) Recover appropriate costs of service provision;
c) Maintain essential services; and
d) Maximise the income of service users and their carers.

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4. Main Issues
4.1 As stated above, the Council has the legal power to set and levy charges. Therefore
any material changes made to the Charging Policy must be considered and
approved by Council and are summarised in the recommendations at section 2.1
above.
4.2 Further details on the proposed changes are provided in the sections below. 
With the exception of the “inclusion of partners earnings”, the other proposals, if
accepted would align to the current guidance and improve the robustness of the
financial assessment process by reflecting the impact age related benefits have
on a service users ability to contribute to an element of the cost of their care.
4.3 The application of the Minimum Income Threshold and the change to the taper
from 50% to 75% will increase the level of income being collected from charges
by circa £0.300m and help to reduce the current shortfall as set out in section
3.6 above.
4.4 The 2022 revision to the current charging policy removed people in receipt of
Independent Living Fund from any non-residential charges for HSCP services,
in recognition that they may make a contribution to their ILF package.  However,
as stated in section 3.4 above, the 2022 recommendations were approved
against the expectation that social care charges would soon be abolished.  The
maximum service user contribution to their ILF package has remained frozen
since 2021 at £43 per week but all social care charges for HSCP delivered
services has increased annually.  The current weekly maximum charge is
£86.20, rising by 5% to £90.50.  This is a significant difference and the proposal
below seeks to address this.
Inclusion of partner earnings
4.5 In September 2023, it was identified that there was an error in the formatting of the
Charging Policy 2023/24. This led to ambiguity and an inconsistency regarding the
inclusion of a partner’s earnings when undertaking a Financial Assessment.  The
2024/25 policy was corrected, however the change requires to be ratified by
Council.
4.6 COSLA guidance states “Where one member of a couple is in receipt of social care
support at home, most Scottish Local Authorities take account of the joint income
and capital in the financial assessment”.
4.7 The 2022/23 Charging Policy, section 14.1 stated “where a service user or their
partner is in receipt of earned income, only net earnings are considered, and a
minimum earnings disregard of £20 is applied. For example if someone earns £100
after tax then the council would take £80 into consideration when undertaking a
Financial Assessment”. 
4.8 This sentence is consistent with COSLA guidance that a partner’s income should be
considered as part of the supported person’s overall Financial Assessment.

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4.9 However, the inconsistency arises in section 14.2 “Income which will be
disregarded” that lists “partner’s earnings” are to be disregarded.  This formatting
error was contradictory to the intention set out at section 14.1 above and led to
confusion when undertaking a Financial Assessment.
4.10 Subject to Council approval, the 2025/26 Charging Policy has been updated to
remove “partner’s earnings” from the “disregarded list” as set out in
Recommendation 2.1 (i) above.
Minimum Income Thresholds, Independent Living Fund, Tapers and
Maximum Charge
4.11 In late October 2024, a range of stakeholders including; members of the public,
service users, their carers, partner organisation’s and HSCP operational services
were engaged in three separate face to face consultation events held in Clydebank
and Dumbarton, to review, comment and challenge four significant proposed
changes to the current charging policy.
4.12 These changes and their impacts are summarised in Table 1 below and approvals to
implement them are set out in Recommendation 2.1 (ii) to (v) above.
Table 1: Summary of Proposed Changes Consulted On
Proposed change Current procedure Impact
Add in upper limits
based on age for
Minimum Income
Thresholds.
If a service user income is
below £273 per week and
they are single, and are any
age, then there is no
requirement to pay. If a
service user lives as a
couple and is any age, and
their income is less than
£417 per week, then there is
no requirement to pay.
If the service user was
of pension age and
single, the threshold of
income the service user
would need to reach
before they would pay a
charge would be £273
per week, for a couple it
would be £471.
If the service user is
between 18 year old to
pension age and single
the limit would be £167
and for a couple it would
be £254.
This means the younger
you are the less income
needs to be brought into
the household before
the service user would
pay a charge.

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Re-instate Financial
Assessments for ILF
service users, to assess
if they could contribute
towards chargeable
services to equate their
maximum charge to that
as non-ILF service
users?
A service user who is in
receipt of Independent
Living Fund (ILF) and makes
a weekly contribution (which
is set at a maximum of
£43/week, unchanged since
2021) directly to ILF
Scotland is exempt from
further charges under the
Council’s Charging Policy.
After financial
assessment a service
user in receipt of ILF
may be charged up to a
maximum of £47.50.
I.e. the difference
between the Council’s
Charging Policy
maximum charge of
£90.50 - £43.00.
Decrease discount from
50% to 25%.  Also
referred to as increasing
the Taper from 50% to
75%
A discount or taper of 50%
is applied after deducting
housing costs, income and
weekly living costs.
Decrease the discount
from 50% to 25%
meaning the individual
would receive 25%
discount.
Removal of a maximum
charge for means tested
services.
The maximum charge is
£86.20 for means tested
services for 2024/2025. 
This will rise to £90.50 in
2025/26.
The individual would
pay the full cost of the
service.
4.13 At the consultation sessions, attendees were presented with the proposed changes to
the Charging Policy and the implications for the supported person, their partner where
relevant, carers as well as the future of social care services in a challenging public
sector financial landscape.  These were considered in officer facilitated roundtable
discussions who provided additional detail to stakeholders where required.  Appendix
1 details the extensive feedback from these three public sessions.
4.14 In summary Table 2 below details the general consensus on the proposed changes.
Table 2: Summary of feedback at public consultations
4.15 A survey was created to capture the views of those who could not attend the face
to face public consultation events.  The survey was sent out via the Council’s
Facebook page, HSCP Twitter page, partner organisations and HSCP operational
managers.
4.16 Table 3 below summaries the feedback from the survey of which 43 responses
Proposed change Feedback
Add Minimum Income Thresholds
based on age
General agreement in implementing this
proposed change.
Increase taper General agreement in implementing this
proposed change.
Charge ILF service users General agreement in implementing this
proposed change.
Removal of a maximum charge. 
This would mean that those who are
able to pay would pay full cost
recovery of the services they
receive.
There was a consensus across all three
sessions that this proposed change
should not be implemented.

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were received. Detailed feedback from the survey can be found in Appendix 1.
Table 3: Summary of feedback from online consultation
Proposed change Feedback
Add Minimum Income Thresholds
based on age
34 responses from the survey stated they
disagreed with implementing this change.
8 agreed to the change.
Increase taper 31 responses from the survey stated they
disagreed with implementing this change.
11 agreed to the change.
Charge ILF service users 9 responses from the survey stated they
disagreed with implementing this change.
33 agreed to the change.
Removal of a maximum charge. 
This would mean that those who
are able to pay would pay full cost
recovery of the services they
receive.
28 responses from the survey stated they
disagreed with implementing this change.
15 agreed to the change.
4.17 The online survey results differed from the overall general consensus of support
gathered at the face to face sessions.  One of the main reasons for this is likely to
be that the face to face sessions included detailed presentations from officers on
the policy landscape of charging, the principles of the COSLA guidance, how this is
reflected in neighbouring local authorities non-residential charging policies, self-
directed support legislation and working through detailed examples of how the
changes would impact on supported people across age ranges and differing
financial circumstances.
4.18 The feedback within the online survey was mainly negative towards the proposed
changes. However, based on the comments provided by the public, it could be
concluded that the responses provided revealed a general disagreement with
principles charging at all for social care services.  This is not unreasonable given
the raised expectations given by the joint intent statement by COSLA and the
Scottish Government to remove social care charging.  However, this must be
balanced against the challenging financial landscape for both the Council and the
HSCP.  The proposed changes to the 2025/26 policy do not contradict current
COSLA guidance and are broadly reflective of neighbouring local authority’s non-
residential policies which strive to be fair and consistent across all those eligible of
social care services.
4.19 Allowing for the added benefits of the three face to face consultation events and
compliance with COSLA guidance, the Council is asked to consider the following
recommendations detailed in Table 4 below and set out in section 2.1 above:
Table 4: Summary of Recommended Changes
Proposed change Recommendation
Add Minimum Income Thresholds
based on age
Approve
Increase taper Approve
Charge ILF service users Approve

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Removal of a maximum charge. 
This would mean that those who
are able to pay would pay full cost
recovery of the services they
receive.
Reject
4.20 Dependent on the outcome of the Council meeting on the 5 March 2025, the
revised draft Charging Policy 2025/26, contained within Appendix 2 may
require to be updated to reflect any material changes agreed.
5. Options Appraisal
5.1 Options on how the proposed changes could impact on supported people,
dependent on individual circumstances were provided at the consultation sessions.
6. People Implications
6.1 Any known people implications are covered throughout this report.
7. Financial and Procurement Implications
7.1 The income received from levying charges forms part of the net funding
contribution made by West Dunbartonshire Council to the HSCP Board for
services delegated, as set-out in section 3.6 above.  The HSCP finance team
have been working through a range of scenarios based on the proposed
changes.  Excluding those in receipt of ILF, which is shown below, it is projected
that the changes to calculation thresholds and tapers for means-tested charges,
coupled with the 5% increase in the maximum charge could increase income
collected by approximately £0.300m, subject to new financial assessments and
maximisation of income calculations being undertaken in 2025/26.
7.2 There are currently 71 service users in receipt of ILF funding. Of this total, 60 of
those service users currently pay ILF Scotland a charge towards their care
package, up to a maximum of £43/week. Given the HSCP does not current
financial assessment information for those ILF service users, it is not possible to
accurately predict how much additional income may be raised.  It would be
dependent on other services provided e.g. flat-rate charges for day care places
or means-tested social support.  If after applying the Minimum Income Threshold
and the 75% taper, if a person in receipt of ILF had the financial means, the
maximum additional charge that could be levied under the proposed 2025/26
Charging Policy would be £47.50/week or £2,470 per annum.
8. Risk Analysis
8.1 Failure to implement a revised Charging Policy, reflective of current guidance,
could leave the Council and HSCP exposed to reputational risk.
8.2 There is a risk that if agreement is reached to abolish non-residential charges, any
replacement funding from the Scottish Government could fall short of the loss of
income from charges levied.  This would have a detrimental impact on the HSCP’s
delegated net budget and could require the Council to increase their contribution.

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9. Equalities Impact Assessment (EIA)
9.1 An Equalities Impact Assessment (EIA – 1210) has been undertaken and is
provided within Appendix 3.
10. Consultation
10.1 Three public consultations took place held on the 21, 29 and 30 October 2024
across Clydebank and Dumbarton.  The session held on the 21 October was open
to partner organisations and HSCP operational services only and the sessions on
the 29 and 30 October were open to members of the public, partner organisations
and HSCP operational services.
10.2 The two public consultations were promoted via Twitter and Facebook, and partner
organisations and operational managers within HSCP were asked to share with
their service users.
10.3 The partner organisations and HSCP operational services invited to the three
sessions were;
 Carers of West Dunbartonshire;
 Improving Lives;
 Shop Mobility;
 Glasgow Disability Alliance;
 HSCP Adult Day services
 Mental Health Network Greater Glasgow and Clyde;
 Golden Hands of Friendship;
 Kinship Carers;
 HSCP Learning Disability service;
 Adult Social Work team;
 HSCP Self-Directed Support Team;
 HSCP Mental Health services; and
 HSCP Addiction services.
10.4 On the 21 October, ten service users and/or carers attended with representatives
from Carers of West Dunbartonshire.  HSCP staff facilitated this session.
10.5 On the 29 October, six members of the public attended, with members from
Improving Lives, Mental Health network and elected members attended.  HSCP
staff facilitated this session.
10.6 On the 30 October, seven members of the public attended, with members from
Kinship Carers, Shop Mobility and Glasgow Disability Alliance.  HSCP staff
facilitated this session.
10.7 An online survey was created to capture the views of those who could not attend
the face to face public consultation.  The survey was sent out via West
Dunbartonshire Council Facebook page, HSCP Twitter page, partner organisations
and HSCP operational managers.  This survey closed on Monday 6 January 2025.

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11. Strategic Assessment
11.1 The Council’s Long Term Financial Plan contains projections on income raised
from Sales, Fees and Charges that will increase based on annual uprating to
account for inflationary pressures.
11.2 The Charging Policy will provide a consistent, fair and transparent framework for
charging and does not inhibit any of the key strategic priorities of the Council.
Name: Beth Culshaw
Designation: Chief Officer, West Dunbartonshire HSCP
Date: 5th March 2025
Person to Contact: Julie Slavin
Chief Financial Officer
West Dunbartonshire HSCP
Email: Julie.Slavin@ggc.scot.nhs.uk
Appendices: Appendix 1: Detailed feedback from public engagement
Appendix 2: Draft Charging Policy 2025/2026
Appendix 3: Equalities Impact Assessment
Background Papers: COSLA-Social-Care-Charging-Guidance-2025-26-2.pdf
Wards Affected: All Council Wards