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Model the Pension Credit severe disability exemptions for joint occupiers, commercial lodgers and separate accommodation (SPC Sch I para 2(5)-(7), para 3) #2074
#1951 applies the Pension Credit severe disability addition's residence condition (SPC Regs 2002 Sch I para 1(1)(a)(ii), (b)(ii), (c)(iii)). Of the people whose presence is ignored, it models only those in para 2(2)(a), (b) and (f). Each exemption it leaves out can only withhold the addition, never grant it. This issue records those exemptions, how the FRS could identify each one, and how much each matters on the Enhanced FRS.
A person who is not a close relative and who (a) is liable to pay the claimant or partner on a commercial basis to occupy the dwelling (a boarder or lodger), or (b) is someone the claimant or partner is liable to pay on a commercial basis to occupy that person's dwelling (their landlord); and (c) any member of either person's household
Candidates only. CVPAY (rent paid as a boarder or lodger, net of benefits) identifies a payer on the payer's adult record, not the payee or the commercial liability. The relationship grid (R01-R14) gives "close relative" (reg 1(2): parent, parent-in-law, son, son-in-law, daughter, daughter-in-law, step-parent, step-son, step-daughter, brother, sister, or the other member of a couple that includes any of them). The partner limb needs a two-step hop through the resident's partner, for example an adult child's cohabitee. The payer side already has inputs from #2002/#2006 (rent_paid_as_boarder, rent_paid_as_lodger, pays_rent_to_householder).
Sch I para 2(6)-(7) with para 3(3)
A person who jointly occupies the dwelling and co-owns it with the claimant or partner, or is jointly liable with them to the landlord; and that person's partner. For a close relative this applies only if the claimant's or partner's co-ownership or joint liability arose before 11 April 1988, or by the date the claimant or partner first occupied the dwelling.
Candidates: HHOLDER ("whether householder") set for both the resident and the claimant or partner. The para 3(3) date is not in the FRS. A recent move-in by the resident (CHANGE) does not settle it either way.
Sch I para 3(1)-(2)
A person who shares only a bathroom, a lavatory or a communal area, or where each person is separately liable to the landlord, does not reside with the claimant
Candidates only: household HHSTAT=2 (shared household arrangements), plus policyengine-uk-data#512's liable_for_share_of_household_rent
Sch I para 2(2)(a), Scottish benefits
A resident on pension age disability payment, the care component of Scottish adult DLA at the middle or highest rate, or the daily living component of ADP
The list in relevant_benefits lacks these, and FRS ADP codes are unmapped (policyengine-uk-data#500). 130 FRS ADP daily-living recipients have no qualifying benefit, and 127 of them count as residents.
Sch I para 2(2)(c)
A resident whose certification as blind or severely sight impaired ended no more than 28 weeks earlier
Not in the FRS
Sch I para 2(2)(d)-(e)
A person who lives with the claimant to care for the claimant or partner and is engaged by a charitable or voluntary organisation that charges the claimant or partner for the service; and that person's partner
Not in the FRS
Sch I para 2(3)-(4)
A person who joins the household for the first time to care for the claimant or partner, where the claimant or partner was treated as severely disabled immediately before; first 12 weeks only
Not in the FRS
The pension-age Housing Benefit severe disability premium (HB(SPC) Regs 2006 Sch 3 para 6) has a non-dependant test with the same structure. HB defines who is not a non-dependant in reg 3, so any inputs added here should be shared with HB.
Size on the Enhanced FRS (policyengine-uk-data#510 build D, FY2025-26, GB, survey weights)
These are GB benefit units entitled to Pension Credit on main (3525263) whose addition #1951 (5008b53) removes. Weighted aggregates and record counts only.
Joint-occupier candidates (resident and claimant or partner both householders), records
3
7
of which close relatives (the para 3(3) date decides)
2
6
A counted resident pays boarder/lodger rent
0
0
The claimant or partner pays boarder/lodger rent and a non-close relative is householder, records
1
1
Shared household arrangements
0
0
A counted resident on ADP daily living
0
0
Across GB, 26 units fail the residence test only because of an ADP recipient, and none of those losing the addition is entitled on main.
So these exemptions reach only a few survey records. They still matter for household calculations, where a user may co-own with an adult child from the start. Today there is no way to express that.
Proposed change
Add person inputs that state facts, defaulting to "not applicable" so microsimulation output does not change until data sets them:
whether the person co-owns the dwelling or is liable to the landlord for it (a householder);
whether the person is a close relative (reg 1(2)) of the claimant or partner in their household's Pension Credit unit;
Extend is_counted_resident_for_severe_disability_addition with para 2(5)-(7), including the household members under 2(5)(c) and the partners under 2(7). Extend meets_severe_disability_addition_residence_condition with para 3(1). Add YAML cases for each provision, including the close-relative date test, plus Hypothesis properties: adding an exemption never lowers the addition, and a household with no exemption inputs is unchanged.
Data (policyengine-uk-data): set the householder and close-relative inputs from HHOLDER and the relationship grid. The relationship-grid reader already exists on branch frs-non-dependant-residence for Count a non-dependant shared by joint tenants in each tenant's Housing Benefit size criteria #2035. Leave the para 3(3) date input unset, which means not ignored: the FRS cannot establish it.
Design question: Pension Credit's "close relative" is a relation between two people, but PolicyEngine variables are per person. Defining it against the claimant or partner of the unit whose addition is being tested works for the usual household of one pension-age unit. Households with two pension-age units need a rule.
Evidence
Real runs; scripts and outputs are local (FRS-derived), with aggregates in the #1951 comment: #1951 (comment)
DWP's guidance confirms these conditions (DMG Chapter 78, read in full):
78078. It restates paras 2(3)-(7) and 3(3), including the household members under 2(5)(c) and the partners under 2(7). Note 2: for the close-relative date test, the claimant's "first occupation" means the date they had the right to occupy, even if they moved in later.
78079. "Commercial basis" needs a legal liability and payments broadly in line with what a lodger would pay for similar accommodation (R(IS) 11/98).
78080. Registered Shared Lives carers are ignored, because the claimant pays them on a commercial basis. An input for "liable to pay this person on a commercial basis" should cover this case.
78068-78069 and 78074. These cover separate accommodation. A kitchen counts as shared if the person's items are stored or meals prepared there, and separate liability must be to the same landlord. The Katja example has a self-contained granny flat sharing only the hall, so she does not reside with her daughter.
78077. It lists ADP daily living among the ignored residents, which supports adding the Scottish benefits row here.
Summary
#1951 applies the Pension Credit severe disability addition's residence condition (SPC Regs 2002 Sch I para 1(1)(a)(ii), (b)(ii), (c)(iii)). Of the people whose presence is ignored, it models only those in para 2(2)(a), (b) and (f). Each exemption it leaves out can only withhold the addition, never grant it. This issue records those exemptions, how the FRS could identify each one, and how much each matters on the Enhanced FRS.
Unmodelled exemptions (SPC Regs 2002, legislation.gov.uk text)
CVPAY(rent paid as a boarder or lodger, net of benefits) identifies a payer on the payer's adult record, not the payee or the commercial liability. The relationship grid (R01-R14) gives "close relative" (reg 1(2): parent, parent-in-law, son, son-in-law, daughter, daughter-in-law, step-parent, step-son, step-daughter, brother, sister, or the other member of a couple that includes any of them). The partner limb needs a two-step hop through the resident's partner, for example an adult child's cohabitee. The payer side already has inputs from #2002/#2006 (rent_paid_as_boarder,rent_paid_as_lodger,pays_rent_to_householder).HHOLDER("whether householder") set for both the resident and the claimant or partner. The para 3(3) date is not in the FRS. A recent move-in by the resident (CHANGE) does not settle it either way.HHSTAT=2 (shared household arrangements), plus policyengine-uk-data#512'sliable_for_share_of_household_rentrelevant_benefitslacks these, and FRS ADP codes are unmapped (policyengine-uk-data#500). 130 FRS ADP daily-living recipients have no qualifying benefit, and 127 of them count as residents.The pension-age Housing Benefit severe disability premium (HB(SPC) Regs 2006 Sch 3 para 6) has a non-dependant test with the same structure. HB defines who is not a non-dependant in reg 3, so any inputs added here should be shared with HB.
Size on the Enhanced FRS (policyengine-uk-data#510 build D, FY2025-26, GB, survey weights)
These are GB benefit units entitled to Pension Credit on main (3525263) whose addition #1951 (5008b53) removes. Weighted aggregates and record counts only.
Across GB, 26 units fail the residence test only because of an ADP recipient, and none of those losing the addition is entitled on main.
So these exemptions reach only a few survey records. They still matter for household calculations, where a user may co-own with an adult child from the start. Today there is no way to express that.
Proposed change
The commercial boarder/lodger and landlord facts can reuse Model rent from boarders, lodgers and sub-tenants for the householder #2002/Give sharers, boarders and lodgers their own rent, tenure and LHA category #2006's inputs.
is_counted_resident_for_severe_disability_additionwith para 2(5)-(7), including the household members under 2(5)(c) and the partners under 2(7). Extendmeets_severe_disability_addition_residence_conditionwith para 3(1). Add YAML cases for each provision, including the close-relative date test, plus Hypothesis properties: adding an exemption never lowers the addition, and a household with no exemption inputs is unchanged.HHOLDERand the relationship grid. The relationship-grid reader already exists on branchfrs-non-dependant-residencefor Count a non-dependant shared by joint tenants in each tenant's Housing Benefit size criteria #2035. Leave the para 3(3) date input unset, which means not ignored: the FRS cannot establish it.Design question: Pension Credit's "close relative" is a relation between two people, but PolicyEngine variables are per person. Defining it against the claimant or partner of the unit whose addition is being tested works for the usual household of one pension-age unit. Households with two pension-age units need a rule.
Evidence
Real runs; scripts and outputs are local (FRS-derived), with aggregates in the #1951 comment: #1951 (comment)