Key elements of service delivery

This chapter lists the key elements of social services support for families and adults with care and support needs who have no recourse to public funds. Local authorities should understand and regularly review how they deliver each of these elements and consider how their organisational structure facilitates that delivery.

2.1 Oversight

Strategic, operational, and financial oversight is crucial to ensuring that services remain at a high, consistent standard and align with organisational priorities.

2.1.1 Organisational oversight

The provision of accommodation and financial support to people with no recourse to public funds can be an exemplar of how local authorities can support residents in need. Therefore, it is important that the delivery of this social care support is considered at a strategic level across the whole local authority.

The responsibility for service monitoring and improvement amongst senior managers and directors should be clearly designated. It should be clear who is responsible for approving policies and agreements with key partners, aligning those policies with organisational priorities, and who is accountable for ensuring that policies are followed.

Managers can encourage strong engagement from senior management and politicians by following the councils existing processes for scrutiny and decision-making, for example when:

Making information available on services for residents with no recourse to public funds on the council website
Providing service updates and briefings at management meetings and for the benefit of elected officials
Aligning to wider priorities, such as ending homelessness, violence against women and girls, and supporting migrants and refugees
Agreeing important service changes according to their impact on residents, such as reviewing subsistence rates, and completing Equality Impact Assessments
Making the business case for change and investment to improve services and save money in the long-term

Asking directors and council leaders for direction is an effective way of sharing the decision-making responsibility and facilitating challenge. They can also help to build relationships with external organisations such as other councils and health providers, facilitate internal relationships, upskill other council teams, and advocate for investment in services.

2.1.2 Caseload oversight

Proper managerial oversight of service delivery should ensure needs assessments are undertaken correctly and that accommodation, subsistence, and other support is provided consistently and in line with best practice. Methods can include:

Using reports from NRPF Connect to allow managers to see council wide summaries of support provision, monitor caseloads and forecast financial spend
Service-wide case panels, in which all cases are presented to senior managers, often held monthly or quarterly
Designating a lead worker for overseeing cases where families or adults with no recourse to public funds are receiving accommodation or financial support.
Writing and implementing clear, transparent policies for supporting people with no recourse to public funds, such as a subsistence policy or referral pathway guide
Agreeing procedures for assessment and review processes, particularly when responsibilities are shared across service areas
Providing opportunities for supported households to feed back to managers and inform discussions around service improvement

In authorities with no dedicated NRPF workers, monitoring service standards is especially advisable for those elements of support that social workers do not usually provide, such as providing accommodation and subsistence. Equally, authorities with dedicated NRPF services that sit outside of social care must ensure that families or adults with no recourse to public funds continue to receive necessary social work interventions and relevant support from social workers.

2.1.3 Financial oversight and planning

In March 2024, the average annual cost per household to social services providing accommodation and financial support to families and adults with care and support needs was £21.7k and £24.5k respectively, on average those households had been supported for over 1.5 and 2.5 years.

Managers and senior managers responsible for financial oversight and planning must seek to mitigate the risks associated with the delivery of high-cost social care responses through budget setting, budget monitoring, and identifying investment in services which can reduce overall cost. The council should be aware of grant money received for refugees and asylum seekers and consider when services, such as legal services, can be commissioned to include people with no recourse to public funds supported by children’s or adult’s social care and alleviate pressures on service delivery.

Financial oversight can be facilitated by caseworkers recording expected expenditure for each of their cases on NRPF Connect, the summation of which can be viewed by managers. This expectation can then be cross referenced with transaction reports to ensure accurate forecasting of spend and investigation of significant discrepancies. A local authority may decide to establish a centralised budget for accommodation and subsistence provision if this helps to collate spend from across different teams and evidence spend.

A strong understanding of expenditure in terms of numbers of supported households accompanied by insight into caseload trends (such as reasons for support, duration of support, or reasons for leaving support) can help build a plan for cost-control and cost reduction. A local authority may identify opportunities to invest in improving services and controlling expenditure, such as taking a proactive approach to resolving cases or investing in staff training, with financial information informing decision making. For more information about resolving cases, see section 2.8.

2.2 Training and supervision

Overseeing, maintaining and improving staff skills and knowledge, both amongst those delivering care and the wider local authority, is essential to providing services which comply with statutory legislation and maximise the care available to residents in need.

2.2.1 Social workers and caseworkers

Councils should have a clear plan for upskilling and supervising staff who are undertaking needs assessments or meeting the needs of people with no recourse to public funds to ensure that the welfare of children and adults with care needs are suitably met. Because of the complexities that can be faced when working with people affected by immigration exclusions and common misunderstanding about entitlements and support options, a service-wide plan could include:

Regular clinical supervision of responsible social workers, with supervisors sufficiently trained to provide critical oversight to support NRPF casework
Regular supervision of non-social workers involved in delivery of care and support, including oversight of overall social care considerations
Reflective practice sessions, in which workers can discuss cases and best practice amongst peers
Individual multi-disciplinary team meetings, including all those involved in a person’s care
Ensuring staff know how to access the NRPF Network online resources and email enquiry service
Attendance at regional NRPF Network meetings to share practice, challenges, and updates
Periodic NRPF training regarding assessments, service delivery, statutory duties, and using NRPF Connect
Engagement in the existing council training offer such as safeguarding, conflict resolution, suicide prevention etc. as well as wider skills-based training

2.2.2 Council-wide awareness and understanding

Councils will need to consider how to create a mainstream, council-wide awareness of the impacts of the NRPF condition on residents and how to serve people who are at risk of homelessness or have insufficient income to meet their basic living needs. Senior managers and the relevant leads should have a plan for upskilling all relevant staff across the council, such as non-specialist social workers, early help, education, housing or front door teams. That plan could include:

Knowledge sharing opportunities such as lunch-and-learns, pop-up information stalls, workshops, or events. Often, highly knowledgeable council staff, such as dedicated NRPF workers, will be able to deliver basic training or facilitate knowledge sharing
A council-wide training strategy on removing barriers to accessing services, including making best use of interpreting services or working towards a supportive environment where people at risk of violence or exploitation feel confident to approach
A communications plan, to tie-together good news stories for the council, and to see how service improvements or developments can be best brought to the attention of staff
Training specialist workers in different teams on rights and entitlements for people affected by the NRPF condition, referral pathways into social care, and the use of NRPF Connect to monitor caseloads and obtain information from the Home Office

Councils should also consider the training needs of homelessness and benefits teams, and how those more in-depth training needs can be aligned with training for social workers.

A council wide awareness of the impact of the NRPF condition will help preventative action to be taken. For example, by frontline staff feeling more confident in referring to immigration advisers or signposting people to other support services in the local area.

2.3 Referral routes

Councils will need to ensure that families and adults with care and support needs who are experiencing destitution or at risk of destitution are identified as early as possible and referred for statutory assessment when appropriate. Early identification of need can allow councils to provide preventative assistance, potentially reducing the need for statutory interventions, and give social workers sufficient time to complete assessments and arrange emergency support when required.

Managers should identify the internal and external points at which need may present and ensure that referral routes for social care assessments are defined. Written procedures or processes will help set service expectations and define role responsibilities between teams. Outlining key evidence or information that people may need to provide, including about their financial circumstances or support history, may help to make the assessment process more efficient. Referral routes are strengthened by regular review and the opportunity for referrers, assessors, and staff delivering support to easily communicate and feedback on the referral process.

Referrers may include:

Central council contact centres
Reception centre staff at council buildings or hubs
Online referrals via the council website
Social services front door staff, such as those based in a Multi-Agency Safeguarding Hub or Access Centre
Housing and homelessness services, including rough sleeper teams
Other parts of children’s services e.g. education and early help

People experiencing or at risk of destitution will often approach voluntary and community sector (VCS) organisations; strong relationships with those organisations, including knowledge sharing and regular communication is vital to the early identification of need in the community. Clear and transparent online information is also an important element of successful referral pathways.

In addition to a general referral route, which will typically come via a social services referral, some councils have developed specific referral routes for certain NHS partners or VCS organisations. Providing referral routes which allow trained staff, such as certain workers in a council’s general reception centre or call centre, to directly engage any dedicated NRPF social workers or caseworkers can reduce referral times and operational overheads.

2.4 Assessment of need

Assessing need under social care legislation is one of the foremost functions of an NRPF service. Assessors must ensure that statutory duties are correctly implemented so that homelessness and destitution is alleviated for children and adults with care and support needs who cannot rely on mainstream benefits and that the service can evidence why support must be provided when immigration-based restrictions to social services support apply. Needs assessments must be undertaken in line with the relevant legislation and statutory guidance. For more information on how to assess need under social care legislation, please see section 4.2 of the Adults Practice Guidance and chapter 6 of the Families Practice Guidance.

When a parent or adult has no lawful status in the UK, a human rights assessment will be required in addition to a needs assessment. This requires assessors to consider the family or adult’s ability to return to their country of origin. Individuals will need to be assisted to access immigration advice and the local authority will need to liaise with the Home Office about outstanding immigration claims over NRPF Connect. Councils will need to be clear on who has responsibility for undertaking and overseeing human rights assessments and consider the training needs of the assessing practitioners who carry them out. For more information please see section 3.4 of the Adults Practice Guidance and section 4.3 of the Families Practice Guidance.

All needs assessments must be compliant with the relevant statutory guidance and the lead practitioner for an assessment must hold appropriate social work skills and expertise. For more information about how to identify a lead practitioner, see section 6.1.1 of the Adults Practice Guidance and section 4.2.2 of the Adults Practice Guidance.

2.5 Provision of accommodation and subsistence

When social care duties are engaged, families and adults with care and support needs with no recourse to public funds can be provided with accommodation and financial support when they are homeless, at risk of homelessness, or have insufficient income to meet their basic needs. The provision of non-specialist housing and regular subsistence payments does not typically feature in other areas of social work practice, but a plan must be in place to deliver this important function when meeting needs of people affected by the NRPF condition.

2.5.1 Provision of accommodation

Appropriate accommodation is vitally important when meeting need and is the most expensive part of relieving destitution amongst supported households with no recourse to public funds, accounting for 78% of the cost of supporting families and 86% of the cost of supporting adults with care and support needs in 2023-24 .

Services will need to be able to secure accommodation to meet varying needs on an emergency basis and for a long duration, considering that families and adults with care and support needs in 2023/24 had been accommodated for an average of 1.5 and 2.5 years respectively. Housing requirements can include emergency accommodation, long term accommodation for individuals and families, and specialist accommodation such as refuges, supported accommodation and residential care.

Strategies for sourcing accommodation vary widely between local authorities. Councils have reported successes with the following strategies:

Collaborating with housing departments/district housing authorities to leverage existing housing expertise to help procure affordable private rented sector accommodation that meets housing standard
Building direct relationships with public and private housing providers.
Purchasing HMOs or single units to use as emergency accommodation.
Paying or topping up rent on someone’s private tenancy if they can no longer pay it themselves
Providing council owned or housing association housing on a non-secure tenancy to families supported when social care duties are engaged

For more information on the types of accommodation that can be provided, see section 5.2 of the Adults Practice Guidance and chapter 7 of the Families Practice Guidance.

Invariably, councils report significant benefits where a good working relationship can be established between social workers or caseworkers and housing departments or district councils. Otherwise, housing knowledge must be acquired by caseworkers, social workers, or dedicated NRPF teams, sometimes by employing a specialist NRPF housing officer. Whatever the adopted approach, councils must consider how housing can be found which is value for money, ensures the safety and well-being of occupants and avoids high-cost nightly rates which can be incurred when commissioning emergency accommodation on a short-term basis.

2.5.2 Subsistence

Deciding the level of subsistence (financial support) that an adult or family receive should be carefully and individually considered as part of a child in need (CIN) plan or care plan. Those decisions must be taken by officers with a full understanding of the individual’s needs and comply with any relevant case law. Councils will need to establish and regularly review a subsistence policy such that it aligns with their statutory duties, case law, and values.

Councils should also consider how to effectively deliver subsistence payments. The majority of councils find that the significant administrative workload associated with processing subsistence payments can be more efficiently handled by designated administrative staff, either employed as part of a dedicated NPRF team or as part of a wider administrative team.

For more information on delivering subsistence support, including setting a subsistence policy and administering subsistence payments please see section 5.3 of the Adults Practice Guidance and chapter 8 of the Families Practice Guidance.

2.6 Provision of social care beyond destitution relief

Social care providers must meet the needs of supported families and adults with care and support needs with no recourse to public funds in line with legislation and best practice.

When a family with no recourse to public funds has been assessed to only require accommodation and subsistence support, social workers must ensure that the assessment is regularly reviewed, arising additional needs are not missed, and the family receive support consistent with any other child in need case.

Where most families will be supported under a child in need plan, councils must be cognisant of the challenges presented by safeguarding cases, where a family may be supported by a child protection team. The family must still be provided with consistent, appropriate support for immigration related issues. Continuity of support can be particularly challenging when a family are transferred between child in need and child protection teams, especially in services with dedicated NRPF social workers who only deal with child in need cases.

Adults with care and support needs with no recourse to public funds will often be known to specialist social work teams, such as those related to mental health or certain disabilities. It must always be clear who is responsible for reviewing need and for providing accommodation, subsistence, and immigration related support.

When non-social work caseworkers carry out functions that are specific to delivering support to households with no recourse to public funds, such as liaising with the Home Office about immigration claims and sourcing temporary accommodation, it remains important for adult and children social care teams to fulfil their responsibility to review the care being provided. Regular case reviews will ensure that the financial support being delivered remains consistent with the overriding objective of promoting the well-being of adults with care and support needs or supporting the welfare and development of children.

2.7 Discretionary support and edge of care

When adults with no recourse to public funds are homeless or destitute but do not meet social care eligibility criteria, the local authority will need to identify alternative support options for the individual. Groups that can be supported by social care on a discretionary basis could include pregnant women and people with vulnerabilities relating to domestic abuse, modern slavery or trafficking, age, or a medical condition.

In England and Wales, when an adult is assessed as not having eligible care and support needs the local authority must consider whether discretionary powers to meet non-eligible care and support needs under section 19(1) of the Care Act or section 36 of the Social Services and Well-being (Wales) Act are engaged. For more guidance about when a discretionary power may be engaged to provide support, please see section 4.4 of the Adults Practice Guidance.

Directors and senior managers should consider how the provision of discretionary support to vulnerable groups can align with the housing authority’s homelessness strategy. Council wide initiatives to support vulnerable people who are subject to immigration related restrictions often require complex planning and cooperation which can be led by specialist workers or refugee and migrant services. Councils could consider specific ‘NRPF roles’ in departments where need is most common, such as a specialist NRPF rough sleeper outreach worker or a member of a VAWG team with responsibility for clients with no recourse to public funds. For more information about specialist roles, see chapter 7.

In addition, councils should build strong signposting and referral routes with other council teams and voluntary organisations such that they can effectively signpost people not eligible for social care support but who, nevertheless, require financial and housing advice.

For more guidance on early intervention for families please see section 4.1 of the Families Practice Guidance.

For adults who are assessed as not having care and support needs and whose only needs are related to a lack of accommodation or other financial support, please refer to chapter 12 of the Adults Practice Guidance, which describes the other powers and duties that may be considered in England.

2.8 Pathways off support

Promoting independence and reducing the need for statutory accommodation and subsistence support is a fundamental part of care provision for people with no recourse to public funds and managers must ensure that the right organisational relationships are in place to help supported households resolve their immigration issues and gain access to mainstream benefits and other sources of income.

On average, the cost to social services of providing accommodation and subsistence to an adult or family with no recourse to public funds was £471 and £417 per week respectively . As discussed in section 2.1 of this guidance, local authorities must seek to understand their caseloads and identify the support required to find long-term solutions to destitution. Councils must then then build partnerships and invest in services to be able to offer support in complex areas, reduce time on support, and remain in control of their finances.

2.8.1 Immigration advice

Councils will need to assist people with no recourse to public funds who are at risk of destitution to access immigration advice as early as possible i.e. when they first access local authority services or when a needs assessment is being completed. Good quality immigration advice can:

Promote the welfare of adults and children by enabling them and their families to make informed decisions about their future
Prevent someone from falling into destitution if there is an immediate solution available to them that is in their best interests, such as applying to the Home Office for a change of conditions whereby the NRPF condition is removed, or upgrading from pre-settled to settled status under the EU Settlement Scheme
Assist people to find a long-term route out of destitution and into mainstream support where an application for leave to remain with recourse to public funds can be made to the Home Office

Gaining access to benefits via a grant of leave to remain is the most common way that adults and families with no recourse to public funds leave social services support . Reducing the amount of time that a household is supported with accommodation and subsistence will both promote the welfare of supported children and adults with care needs and reduce the social services spend for the local authority.

Sourcing immigration advice

It is well known that immigration advice has become increasingly oversubscribed in the UK, as evidenced in a report commissioned by Refugee Action. Legal aid for immigration and asylum claims is only available in Scotland and Northern Ireland, and some areas of the UK have significantly less immigration advice provision than others. Councils should assess the availability of immigration advice in their area and build signposting routes to ensure that residents are able to access the right advice. Where the capacity to provide that advice does not exist councils should consider how they might be able to procure advice themselves.

Councils invariably report that the cost of providing immigration advice is outweighed by savings found through reducing the amount of time spent paying for accommodation and subsistence.

How a council chooses to source immigration advice, and whether they decide to procure it themselves, will depend on regional availability, existing relationships, and the size of their caseload. Councils should ensure that advice is provided by reputable, regulated advisors and consider:

Availability and capacity of local legal charities and law centres for referrals
Predictability of their caseload, whether a core need for legal advice is likely to remain and can be commissioned in the long term
Need for initial immigration advice at short notice
Need for lower-level OISC regulated advice, such as assistance with making certain applications
Need for longer term representation
Cost of different types of immigration advice
Whether the cost can be spread across services, such as resettlement pathways by procuring legal services together.

Ways to commission immigration advice

The most popular ways to provide legal advice are as follows, many local authorities will choose a mixture:

Procuring legal services from local legal providers or VCS organisations specifically for supported households with no recourse to public funds
Procuring legal services from local legal providers or VCS organisations for general use by migrant services or wider council teams
Referrals to local legal charities and organisations providing pro bono advice
Case-by-case funding

For more information on providing legal support please see section 9.2 of the Families Practice Guidance and section 13.1 of the Adults Practice Guidance. A detailed analysis of different funding methods is set out in the Justice Together report, ‘It’s a No-brainer’: Local Authority Funding for Immigration Legal Advice in the UK.

Providing in-house legal advice

A small number of councils have found reported successes in obtaining OISC registration and training internal staff to provide immigration advice to OISC level 1 or 2. Internal staff may be able to provide immigration advice more quickly, even at the initial point of contact, and OISC qualified caseworkers and social workers can provide more holistic advice to the people they support. Qualified staff will also be able to assist people in making certain immigration applications, avoiding the delays and inconsistency associated with finding external support.

Councils will have to consider the code of standards that OISC regulated organisations must abide by concerning case management, record keeping and client care. They should also consider the independence of their advice and where conflicts of interest may arise, such as where faster immigration outcomes may save money for the council but not align with the best interests of the client.

Managers who are considering introducing in-house immigration advice should speak to their local authority’s legal team to understand the risks associated with such provision. More information about OISC registration is available on gov.uk.

2.8.2 NRPF Connect

NRPF Connect is a national database and case management tool managed by the NRPF Network, used by 89 councils across the UK. It allows councils to record details of support provided to households with no recourse to public funds and quickly view a person’s digital immigration status to find out whether a person can access benefits and homelessness assistance, or whether the provision of social care support must be considered.
NRPF Connect users also have the dedicated support of the NRPF Team in the Home Office and the NRPF Network to overcome complex casework issues and expedite decision-making. Given the undertaking of the Home Office to fulfil this work for local government, it is highly advisable for councils to keep information up to date to facilitate this expedited decision-making.

NRPF Connect will:

Reduce the amount of time spent on statutory support as complex immigration cases are prioritised
Aid with assessments as a person’s access to public funds can be quickly identified
Allow councils to easily view the support they are providing to households with no recourse to public funds across adults and children’s social care
Contribute to the regional and national understanding of the prevalence of accommodation and subsistence support provided by adults and children’s social care to households with no recourse to public funds
Inform policy recommendations made to central government by the NRPF Network and other organisations

To see if your council has subscribed to NRPF Connect or for more information on how to access NRPF Connect and maximise its use please see please visit the NRPF Connect section of the NRPF Network website.

2.8.3 Supporting people to access employment

Some adults and parents will have the right to work, such as those with leave to remain with NRPF or pre-settled status. When they are in a position to be able to work, helping them to find employment can create an income stream which promotes independence, reduces reliance on subsistence payments, and in the case of those with pre-settled status, can enable access to certain benefits. As well as direct employment support, practitioners should consider assisting people to gain wider skills to assist with employment by providing access to training or ESOL teaching.

Services supporting people with no recourse to public funds should forge relationships with council employment teams, local DWP Jobcentre Pluses, and employment related VCS organisations. They may also consider the cost benefits of providing grants to people who incur certain costs in trying to find work.

2.8.4 Accessing benefits advice

Whilst those who are subject to the NRPF condition will not be able to access most benefits, some who are in work will be able to access contribution-based benefits and those with pre-settled status can access benefits if they are exercising a qualifying right to reside. For more information about entitlements to benefits please see the NRPF Network website.

Fostering a good relationship with council benefits teams, Citizens Advice services or Jobcentre Plus colleagues is important so that advice can be sought quickly.

In addition, expert benefits advice can ensure that supported households make the right benefits claims and gain access to their full entitlement of mainstream benefits as soon as they are eligible, and so no longer require accommodation and subsistence support. This is crucial to lowering costs for a local authority.

2.9 Hospital discharge

In some authorities, particularly those which contain a large number of hospitals, a significant number of adults with care and support needs are likely to become known to a local authority at the point of discharge, if not before.

Managers should consider their relationship with local NHS providers such that patients can access appropriate advice, referrals are streamlined, social care assessments are completed in a timely manner, and post-discharge support can be planned. Early identification of potential need will help reduce pressures by enabling councils to complete assessments, identify immigration issues, and source suitable housing and care provision early on.

In England and Wales, local authorities will have to work with Integrated Care Boards (ICBs) and NHS mental health trusts to agree on responsibilities for providing accommodation and subsistence when a person is being discharged from detention and qualifies for aftercare under s117 Mental Health Act 1985. Local authorities adopt varying approaches to managing s117 aftercare responsibility. Most commonly, councils will organise housing and subsistence payments, and in some cases reclaim costs from the ICB. In some instances those roles are reversed, and in others, either one of councils or ICBs can manage the entire process and pay for the costs. The decision of how to handle this process should be made by agreement, in advance.

NHS providers will have discharge coordinators and some will have specific staff responsible for liaising with local authorities regarding patients who are homeless or who have no recourse to public funds. Councils should build relationships with hospital discharge coordinators, identify their point of contact in the local authority, and consider including them in training or knowledge sharing.

More guidance is available in the Adults Practice Guidance at chapter 9 (hospital discharge) and chapter 10 (mental health aftercare).

2.10 Transition to mainstream support

A local authority’s duty to provide accommodation and financial support will end when a supported household gains access to benefits and homelessness assistance. Following a grant of leave to remain, which is the most common pathway off support for supported households , gaining access to mainstream benefits and housing can take several weeks to achieve. As such, a clear and efficient process by which supported households can transition into mainstream support can reduce costs for local authorities and improve outcomes for supported people.

The process will require social services to build strong relationships with:

Homelessness services, either in the council, the relevant district councils, or other councils where a family or adult is placed out of area
Benefits advisers, either in council teams, Jobcentre Plus or elsewhere
Employment advisers

Councils have reported that providing housing for people with no recourse to public funds in partnership with council housing departments or district councils can save time and money if the accommodation provider is prepared to allow universal credit claimants to enter into a tenancy agreement. In such scenarios, the person may be able to remain in the same accommodation when the right to access universal credit is enabled. Where people awarded recourse to public funds cannot stay in the accommodation sourced under social care legislation, a presentation to homelessness services will be required for alternative housing options to be found.

Senior managers should consider the overall savings to the council, associated with reduced accommodation and subsistence costs, when a person who has been granted access to public funds is prioritised by mainstream housing services and benefits, and seek cross-department agreements accordingly. A target period to achieve transfer from full-cost social care accommodation and subsistence to mainstream benefits and housing may be applied, but social care financial support must continue until such time suitable alternative accommodation is found.

For more information how transfers to alternative accommodation should be handled when support is withdrawn, please see chapter 6 of the Adults Practice Guidance and chapter 10 of the Families Practice Guidance.