Supervision in exempt accommodation

If a relevant landlord provides ‘care, support or supervision’ then the dwelling should be treated as exempt accommodation and qualify for enhanced housing benefit.  Charges for nursing/personal care and general counselling/support are ineligible for housing benefit, but there doesn’t appear to be a specific reference to supervision.

I am trying to work out the logic for a category of ‘supervised exempt accommodation’.  In contrast to ‘supported exempt accommodation’ where alternative funding is needed for the support service, it seems that ‘supervised exempt accommodation’ would be fully eligible for housing benefit.  The presence of supervision would satisfy the criteria for exempt accommodation, but is not ineligible for housing benefit under schedule 1.

In a way this could be similar to IHM models of exempt accommodation.  IHM can meet the threshold for ‘support’ if more than minimal, whilst at the same time being eligible for housing benefit.

There is obviously a piece of work to be done on what ‘supervision’ would look like in exempt accommodation and how this differs from ‘care’ or ‘support’.  If a distinction can be made it may provide an alternative model for clients with lower needs (care = acute, support = complex, supervision = low). 

I’m only thinking about this due to the continuously difficult financial climate.  Local authorities may welcome a model that is fully funded by housing benefit, especially if the landlord is a housing association.

All thoughts welcome.