What the law says
Housing Benefit (Persons who have attained the qualifying age for state pension credit) Regulations 2006 (SI 2006/214), reg 27:
- (1) For a claimant who has, or whose partner has, "an award of state pension credit comprising only the savings credit", the authority uses the Secretary of State's calculation or estimate of income and capital made for that award.
- (4) The authority "shall modify the amount of the net income provided by the Secretary of State only in so far as necessary to take into account— (a) the amount of the savings credit payable; ..." plus childcare charges, certain higher disregards and other listed items.
So a savings-credit-only claimant's HB income includes the Savings Credit itself.
What the model does
housing_benefit_applicable_income (policyengine_uk/variables/gov/dwp/housing_benefit/applicable_income/housing_benefit_applicable_income.py) sums earnings, other income and a list of benefits (child_benefit, income_support, jsa_income, esa_income, carers_allowance, carer_support_payment, esa_contrib, jsa_contrib, state_pension, maternity_allowance, SSP, SMP, SSMG). It does not include pension_credit and has no savings-credit-only route, so a pension-age HB claimant's income leaves out the Savings Credit that reg 27(4)(a) adds.
Council Tax Reduction already does this: council_tax_reduction_applicable_income has a savings-credit-only branch (in_receipt_of_savings_credit_only) that adds pension_credit_income and pension_credit (England SI 2012/2885 Sch 1 para 14).
Fix
Mirror the CTR branch in housing_benefit_applicable_income for pension-age claimants with a savings-credit-only award, citing SI 2006/214 reg 27, with YAML cases for a savings-credit-only couple and a Guarantee Credit couple (passported, unaffected), and a real Enhanced FRS impact run.
Found in the independent review of #1938 (its YAML expectations for two pension-age cases include the model's current HB income rules, so they omit the Savings Credit).
What the law says
Housing Benefit (Persons who have attained the qualifying age for state pension credit) Regulations 2006 (SI 2006/214), reg 27:
So a savings-credit-only claimant's HB income includes the Savings Credit itself.
What the model does
housing_benefit_applicable_income(policyengine_uk/variables/gov/dwp/housing_benefit/applicable_income/housing_benefit_applicable_income.py) sums earnings, other income and a list of benefits (child_benefit,income_support,jsa_income,esa_income,carers_allowance,carer_support_payment,esa_contrib,jsa_contrib,state_pension,maternity_allowance, SSP, SMP, SSMG). It does not includepension_creditand has no savings-credit-only route, so a pension-age HB claimant's income leaves out the Savings Credit that reg 27(4)(a) adds.Council Tax Reduction already does this:
council_tax_reduction_applicable_incomehas a savings-credit-only branch (in_receipt_of_savings_credit_only) that addspension_credit_incomeandpension_credit(England SI 2012/2885 Sch 1 para 14).Fix
Mirror the CTR branch in
housing_benefit_applicable_incomefor pension-age claimants with a savings-credit-only award, citing SI 2006/214 reg 27, with YAML cases for a savings-credit-only couple and a Guarantee Credit couple (passported, unaffected), and a real Enhanced FRS impact run.Found in the independent review of #1938 (its YAML expectations for two pension-age cases include the model's current HB income rules, so they omit the Savings Credit).