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Introduction
1. The Community Care (Direct Payments) Act 1996 ("the Act") gives local authorities the power for the first time to make cash payments for community care direct to individuals. Direct payments are a major step forward for community care, and present an opportunity to bring about improvements in the quality of life of people who would like to manage their own care. It is inevitable that local authorities' control over this money is less direct than where they provide or purchase services directly, and there are risks involved. On the other hand, day-to-day control of the money and care package is passing to the person who has the strongest incentive to ensure that it is spent properly on the necessary services, and who is well placed to judge how best to match the available resources to needs - the user himself or herself. Users have consistently asked for greater influence over the way in which services are provided and, in particular, younger disabled people have expressed the desire to receive direct payments so they can manage their own care.
2. This practice guidance should be read together with the accompanying policy guidance.
3. This practice guidance draws on the experience of several of the schemes which some local authorities have been operating in recent years to support independent living. It aims to give advice to enable local authorities to make the most of this new power to make direct payments whilst minimising the risks involved. Operating direct payments effectively can involve handling some complex issues, and it is worth taking time to think through all the areas covered in this guidance and the accompanying policy guidance before beginning to take the first steps towards making payments locally. The aim should be to set up simple but effective systems, which contain safeguards but are not unnecessarily bureaucratic or time-consuming. Local authorities may find it helpful to designate a contact point within the authority with responsibility for answering queries and for identifying and addressing any problems which arise.
4. The purpose of direct payments is to put more control in the hands of people who need community care services. That is a process which needs to start right at the beginning. It is important that local people should be consulted fully as local arrangements for making direct payments are set up. Local authorities will wish to take care to avoid focusing on one group of potential users to the exclusion of other groups and should not make the assumption that organised groups necessarily represent all users or carers in the locality. In particular, care should be taken to include people with different kinds of impairment, people from different ethnic backgrounds and people of different ages. The views of informal carers and of potential providers will also be important. Whatever form consultation takes, it is important that people who have been consulted receive feedback about what has happened, and how their views were taken into account. It is also important that the lines of communication remain open, so that the local authority remains responsive to users' views over time.
Scope of the Act
5. The Act enables local authorities to make direct payments to people so that they can purchase some or all of the community care services which the authority has assessed them as needing. Local authorities can make direct payments for any community care service, except permanent residential care. Local authorities have the discretion to decide for which services they wish to offer direct payments. Existing independent living initiatives have enabled disabled people to secure assistance with personal and domestic tasks inside and outside the home, such as getting in and out of bed, dressing, having a bath, preparing a meal, doing housework and laundry, going shopping etc. Other examples have included assistance to enable an informal carer to take a break and enabling a deafblind person to secure the services of a guide-communicator.
6. The Act also allows local authorities to make direct payments to enable people to purchase for themselves aids and adaptations which come within the legal definition of community care services and so would otherwise be provided by the social work department.
Direct payments cannot be used to purchase services or equipment that would otherwise be arranged by other authorities (e.g. the NHS or housing departments - direct payments are not a substitute for Improvement Grants for adaptations for disabled people). It is up to the local authority to decide whether to make direct payments to allow people to purchase equipment. If they do so, they will need to bear in mind the specialist expertise that may be needed to ensure that equipment purchased is safe and appropriate, and the question of whether making a direct payment is a cost-effective way of purchasing such equipment. Authorities would also need to clarify, with the user, the ownership of any equipment, and where responsibility lies for' its ongoing care and maintenance. For these reasons the Department considers that direct payments are unlikely to be appropriate for purchasing complex and expensive pieces of equipment, although they may well make sense for smaller, less specialised items.
7. The restriction in regulations on the length of time for which people may use direct payments to pay for residential accommodation is intended to prevent direct payments being used to pay for permanent residential accommodation. Within the limit set by the regulations, some one might use their direct payments to secure, for example, one week in six, or periodic weekends, in residential accommodation. This does not affect the local authority's power to arrange residential accommodation itself on behalf of people who are receiving direct payments for the rest of their care package (and there is no restriction on the length of time for which the local authority may arrange residential accommodation for each person).
Who is eligible for direct payments
8. Direct payments may only be offered to people who are eligible to receive community care services. Local authorities will also need to bear in mind the limits on eligibility for direct payments set by the regulations. Within these limits, it is up to each local authority to decide to whom to offer direct payments.
Information about direct payments
9. Making information about direct payments readily available might include, where appropriate, providing information in formats which are accessible to people with different forms of disability and to people whose first language is not English. In cases where there is a strong possibility that direct payments may be offered, it may also be helpful to put people in touch with a support group or local centre for independent living, or people who already manage direct payments, before their needs are assessed. The Government would expect to see information about direct payments in local authority community care plans.
Assessment for direct payments
10. The accompanying policy guidance identifies a number of key points which are essential to a successful assessment for direct payments: involving the user in the assessment; enabling the user to think through whether or not he or she would like to receive direct payments; and assessing the user's ability to manage direct payments.
11. If someone whom the local authority is considering offering direct payments is also seeking funding from the Independent Living Fund (ILF), or is already receiving ILF money, the local authority will need to keep in touch with the ILF (just as they would do if arranging services for that person).
(a) Involving the user
12. Direct payments involve the user taking over the day-to-day control of his or her care package. The greater ownership the user has of the process by which his or her needs are assessed, and by which the decision is reached on the areas for which a direct payment will be made, the more likely it is that direct payments will be a success. Taking time to discuss with the user what assistance he or she needs and for what a direct payment is to be provided can avoid problems with direct payments at later stages.
13. Some users may already have clear views about the activities with which they need assistance. Others may need help and encouragement to play a more active part in the process. This may mean practical assistance, such as providing interpreters for those who are unable or find it difficult to communicate in spoken English, more intensive advocacy support to help people to think through and ask for what they need, or simply allowing them more time. In some areas, self-assessment forms designed by user groups, have been used to prompt users to think through the tasks with which they need assistance before their needs are assessed by the local authority.
(b) Helping the user decide
14. In order to make an informed decision, people will need to understand what is involved in managing direct payments. The Department is producing a guide to managing direct payments. It may be helpful to give people a copy of this guide, or of locally-produced information, at this stage. If someone is not sure whether he or she would be able to manage direct payments, or what would be involved, it may also be helpful for the local authority to put him or her in touch with a local support group or centre for independent living, which may be able to advise on ways in which potential problems may be overcome, or to give the user an opportunity to meet people who already manage their own care. Some users may also want time after the assessment to think about the local authority's offer of direct payments before making a decision.
(c) Assessing the user's ability to manage
15. The judgement as to whether someone is able to manage direct payments, and how much help is appropriate, can sometimes be difficult and will need to be made on an individual basis. The local authority may find it helpful to ask the following questions. It should be emphasised that these questions are intended as an aid to, not a replacement for, the authority's judgement and decision in each individual case.
16. If the answer to either of the first two questions is "No", then that person is unlikely to be able to manage direct payments. Negative answers to the remaining questions may raise doubts, but local authorities should consider what assistance would enable the person to manage that aspect, rather than taking it as an automatic indication that the person is unable to manage. For example, the Government envisages that people might receive assistance with keeping records, management of day-to-day relationships with staff or operation of PAYE. - If someone needs help to manage but does not have access to the help he or she needs on an ongoing basis, the local authority may wish to consider facilitating the provision of that assistance. It may also wish to consider offering training to assist direct payments recipients to manage.
17. If the necessary assistance is available, the local authority will need to consider whether the person concerned would be in control of the money. Local authorities should take care to avoid the danger that control may pass to the third party, either with or without the consent of the user. This may need delicate negotiation, particularly where the third party is a close relative or friend who may be making sacrifices in order to provide assistance, or who might have their own interest in the way direct payments are used. It is a key principle of direct payments that it is the user who controls the money. Allowing more time for the assessment process may help the authority to ascertain whether it is really the user's own choice to receive direct payments, and whether they would really be in control. Ensuring that the authority talks to the user on their own, or if an interpreter is needed that he or she is not the person who would be helping to manage the direct payment, is also likely to aid this decision.
18. Local authorities will need to consider how to treat someone with a fluctuating condition which affects his or her ability to manage direct payments. In many cases, people with such conditions may nevertheless be able to cope with direct payments if a friend, relative or some other third party is willing to provide greater assistance when their condition worsens. If the person's condition is likely to deteriorate to the point where he or she is unable to manage even with assistance, the local authority might consider ways of enabling him or her to receive direct payments while he or she is able to manage, with a back-up system controlled by the local authority to be triggered during periods when he or she loses that capacity. In the absence of such arrangements, it is unlikely to be appropriate to offer direct payments to people who are only able to manage periodically. Equally, local authorities might decide to .offer direct payments to people whose condition means that they are likely, at some point in the future, to lose the ability to manage permanently, but they will still need to satisfy themselves that safeguards are in place to ensure that direct payments do not continue when such people are no longer able to manage. People whose condition is likely to fluctuate or deteriorate permanently should be given an opportunity to explore any worries they may have about their ongoing ability to manage direct payments, and care should be taken to avoid their feeling under pressure to accept direct payments.
19. There may be cases where the local authority has doubts about a person's ongoing ability to manage although he or she appears to understand clearly what is involved and be willing to take it on. It is the local authority's decision whether to offer a direct payment in such cases. It may be appropriate to set up a formal trial period to give people the opportunity to demonstrate their ability to manage. However, the fact that the person cannot count on receiving the payments beyond the trial period may make it more difficult for them to manage. For example, he or she may have difficulty recruiting staff for a short period.
20. Refusing direct payments to someone who cannot take on the responsibility for managing the money may lead to disappointment for some, but the responsibility for the way in which direct payments are spent should not be underestimated. There is nothing to be gained and much to be lost, not least for the person concerned, from passing this responsibility to people who are not able to cope with it. It may be helpful to discuss with users and carers general criteria by which the local authority might assess someone's ability to manage, although it still remains the local authority's judgement and decision in each individual case.
21. If the local authority concludes that someone would not be able to manage direct payments, it is good practice to discuss with him or her the reasons for the decision, particularly if he or she disagrees. Although the person may continue to be unhappy with the decision, the offer of an explanation is an important indication that the matter has been considered seriously. The authority should also make the individual aware that they can use the complaints procedure to challenge the local authority's decision not to offer direct payments.
Deciding how direct payments are to be used
22. Local authorities will need to consider carefully how much flexibility to allow each individual over how to spend direct payments and what conditions to attach to ensure that the arrangements direct payments recipients make are satisfactory. Authorities may wish to seek legal advice in deciding on appropriate conditions. They will need to bear in mind the regulations which prevent people from using direct payments to secure services from their spouse, partner or a close relative living in the same household and the further restrictions contained in paragraph 36 of the accompanying policy guidance.
23. Some people may already have ideas about how they would use direct payments, and may have discussed these with the care manager at the assessment stage. Other people may need advice or advocacy to help them think through the alternatives. The local authority could help people to obtain accurate information about local services which they might purchase. If it has not already done so, it might also consider at this stage whether there is a local support group with which it could put the person in touch. If there is a local register of approved providers, and those providers are willing for their details to be passed on, the authority should bring the register to the attention of the individual, but it would not be appropriate to require the individual only to contract with providers from the register.
24. In considering whether people's proposed arrangements will be adequate, local authorities should not be constrained by existing patterns of service provision. By exploring innovative and creative options, it may be possible to identify alternatives which both cost less and meet the user's needs more effectively. Where the user's needs fluctuate over time, it will be important to discuss in advance how the direct payments will be used to secure a package of assistance which varies according to need. Local authorities may also wish to consider offering someone a combination of direct payments and services, whether for an initial trial period or on a longer term basis.
25. Many people will prefer to use direct payments to take on their own personal assistants as direct employees. This option gives them the most direct control over the assistance they receive, but it also carries the most responsibility (for example, to pay tax, national insurance contributions and statutory sick and maternity pay), so it will not be everyone's choice. Others may choose to contract with self-employed individuals or with independent agencies. People will not be able to use direct payments to purchase local authority services, as local authorities are not permitted to sell community care services in this way, but they may continue to receive those services direct from the local authority.
26. It may be difficult to make direct payments for the community care element of an integrated service, for example the support element of supported housing, or the care element of integrated education packages. However, it may be possible for bodies other than the social work department to provide their services separately, allowing the individual to receive a direct payment to secure the community care element for himself or herself.
27. Care plans in relation to direct payments will need to cover all the areas discussed between the authority and the user and set out clearly what has been decided. The care plan should make clear to the user what the money may or may not be spent on, how much flexibility he or she has in the way in which the money is spent, the type of variations to the care package which the local authority would expect to be asked to approve in advance, the information the user will be expected to provide for audit purposes and any other conditions which the local authority has set. The Annex to this guidancecontains a checklist of points which should be sorted out before direct payments start and which should be covered in the care plan.
Calculating the amount of a direct payment
28. It is up to the local authority to decide on the amount of a direct payment but it must be enough, taking into account any contribution which the individual is expected to make to the cost of his or her care package, to enable the recipient legally to secure the relevant service to a standard which the local authority considers is acceptable (see paragraph 41 of the policy guidance). In deciding on the level of a direct payment, local authorities will need to discuss with the user the arrangements that he or she is planning to make and the costs that may be associated with this (eg National Insurance, sick pay, maternity pay, employers' liability insurance, public liability insurance, VAT). However, the particular costs involved will depend on the way in which the user secures the service, and the local authority is not obliged to fund the particular costs associated with the user's preferred method of securing the service if the service can in fact be secured more cheaply (but still to a quality which the authority considers is acceptable) in another way. Nor is the local authority obliged to fund particular costs which are incurred by the user on a discretionary basis, which are not therefore essential in order to secure the service. Local authorities have discretion to decide whether to include an amount in the direct payment to cover costs which they are not obliged to cover.
"Charging" for direct payments
29. In seeking to apply their charging policies fairly and equivalently to people who receive services and people who receive direct payments, local authorities may find it helpful to refer to the Department's Circular No: SWSGl/97: Charging for Adult Non-residential Sector Care.
Consent
30. People may need some time to consider the implications of taking on direct payments and the responsibilities involved. Local authorities may therefore want to give people the opportunity to reconsider a decision not to accept direct payments or to stop receiving direct payments, particularly if they change their minds as a result of a change in their circumstances. If someone who had initially expressed an interest in receiving direct payments decides not to accept them, the local authority may wish to discuss with him or her the reasons for that decision. Any such discussion should be handled sensitively.
Making payments
31. It is up to local authorities to decide how frequently payments should be made and whether in advance or arrears. Local authorities will need to set up mechanisms which enable them to monitor payments which are made and which minimise the risk of money being misspent. In considering what procedures to put in place, local authorities should bear in mind the likely effect of different alternatives on the circumstances of people who are likely to receive direct payments. Making payments in advance will ensure that people are in a position to pay for services as they are received. On the other hand, requiring the production of invoices before payments are made in arrears may help reduce the risk of money being misspent. In, either case the arrangements for payment will need to be reliable, as late or incorrect payments may put at risk users' ability to secure the services they need. The local authority may also need to set up procedures for making additional payments in emergencies, for example if needs change or regular payments go astray. Local authorities should tell users, before direct payments begin, how and when the payments will be made.
Support services
32. Experience with independent living projects suggests that direct payments will work best where people who receive the payments have access to support as they manage the money, particularly in the early stages. The Government encourages local authorities to arrange for people to whom they make direct payments to have access to such support. This might be by providing a service directly, in partnership with a local voluntary organisation, or by some other means.
33. One of the most valuable resources a support service can offer is to provide someone to act as a single point of contact who is able to help users with any problems which arise. The experience of users on existing independent living schemes is that they find it easier to seek advice from someone who is independent of the local authority. Authorities will need to consider carefully how to ensure that all people receiving direct payments feel comfortable with any support service being offered and are able to access its services. This may mean contracting-in the services of people with particular skills, eg language skills, to provide assistance to clients with particular needs. People who have experience of managing direct payments themselves are well placed to advise and help others as they begin to receive direct payments. In many areas, people who are managing their own care meet regularly to support one another and to discuss any difficulties which have arisen. This can be an effective way of sharing experience.
34. Users may also find it helpful to refer to written materials. The Government is producing a national guide for people who receive direct payments. Local authorities may find it helpful to supplement this with local information.
35. People who receive direct payments may need particular support when they first take on responsibility for managing their own care. People who are becoming employers for the first time may benefit from having access to someone with expertise in employment issues, or to a payroll service which will assist them with tax, national insurance or other matters. A support service may also be able to provide practical assistance, for example by holding a list of local agencies, helping people to draft advertisements, job descriptions and contracts, providing rooms for interviews and assistance with interviewing, or by acting as an address for responses to advertisements. A support service might also arrange training, for example in budgeting or assertiveness skills.
36. People who receive direct payments may also find it helpful to have access to advocacy support. A support service may be well placed also to act as an advocate for local users as a group when the local authority is considering changes to the scheme, but it may well be preferable to separate any support role from an advocacy role on behalf of individuals, to avoid any conflict of interest.
37. Local authorities should also consider whether it would be helpful for other people to have access to any support service. For example, informal carers of people who are receiving direct payments may need advice about how direct payments work, particularly if they are assisting their friend or relative with managing the payments. It may also be helpful for employees of people receiving direct payments to have access to training or support.
Monitoring and reviews
38. Monitoring arrangements should be consistent both with the requirement of the local authority to be satisfied that the person's needs are being met and with the aim of the policy to increase user choice and independence. Local authorities should seek to focus on whether the person's needs are being met, rather than on the service being delivered in a certain way. The authority should discuss with users what steps it intends to take to fulfil its responsibilities in this area, and may also wish to discuss how it might support them in securing adequate quality care. It should be prepared to consider variations to what it proposes. Some independent living schemes have found spot checks helpful for .this purpose and as a means of guarding against fraud (by the user, their employees, or any person providing assistance to the user to manage the direct payment). However, local authorities which are thinking of using spot checks will need to consider this very carefully and to bear in mind the need to respect the privacy of people who receive direct payments.
39. Each authority will need to ask itself how it would know if someone was experiencing difficulty with managing their direct payments. It may be appropriate to rely on someone who has been managing their own care for' some time to ask for extra help if he or she needs it, but authorities should not assume this will be an adequate safeguard, particularly when someone begins to receive direct payments for the first time. Where an authority wishes to ask the user whether he or' she is satisfied with the services he or she is securing, it should ensure that it communicates directly with the user wherever possible. In particular, it may need to use a different interpreter if the user may wish to comment on the services of his or her usual interpreter. Local authorities should not make assumptions that someone who is not receiving services to their satisfaction cannot manage direct payments. Authorites should seek to ensure that users do not feel inhibited from expressing reservations about the services they are purchasing, or about any other problems they are having in managing their direct payments, by a concern that their direct payments will be stopped automatically or arbitrarily.
40. Local authorities should follow existing guidance on carrying out reviews. It may be helpful to consider first whether the person's needs have changed, before moving on to review how he or she is managing direct payments and how well direct payments are working. Following the review, the amount of direct payments may need to be increased or reduced.
41. In order to audit direct payments, it is important to be able to identify the direct payments money separately from any other money used for similar purposes. For example, people may use their direct payments to employ a personal assistant, and then pay the assistant to work additional hours from their own resources or using funding from the Independent Living Funds. Local authorities will wish to bear in mind this possibility when discussing audit arrangements with people to whom they offer direct payments.
42. Local authorities should aim to keep audit arrangements as simple and easy to understand as possible. It is worth taking time to discuss with users what is required so as to avoid being needlessly intrusive.
When difficulties arise
43. Difficulties can be minimised by good assessments, clarity (eg about what the money can be used for), monitoring, effective support arrangements (where these are necessary) and by discussing potential areas of difficulty, and how they will be handled, with the user before direct payments begin.
44. Examples of contingency plans which people who receive direct payments might make include making arrangements with independent agencies for emergency cover, or recruiting personal assistants who are prepared to work additional shifts at short notice when necessary. However, it remains possible that difficulties will arise which have not been anticipated and which cannot be covered by the arrangements the individual has made. In these circumstances, it will be helpful if the direct payment recipient knows they can contact a named individual in the local authority or support service whom they can ask for help.
45. If the authority's monitoring or review process reveals that the person's needs are not being met, or if the person contacts the authority to seek emergency assistance, the authority will need to consider what action it should take. Good communication between the different parts of the authority involved will be very important at this stage. This may mean helping people to make other arrangements, or it may mean arranging services directly until they are able to make their own arrangements once more.
46. When difficulties arise, the authority will wish to ask itself the following questions:
Have the person's needs changed? If so, the person's needs should be reassessed and the level of direct payment should be reviewed.
Is the amount of money sufficient to enable the person to secure the relevant services? It may be that experience shows that there are other costs which were not taken into account when the cost was calculated initially, or that anticipated costs have not, in fact, arisen. It may be necessary to review the level of direct payment.
Is the person still able (0 manage direct payments? Local authorities need to continue to be satisfied that people can manage direct payments. However, difficulties will not necessarily mean the person cannot manage. There is inevitably a learning process when people begin to receive direct payments and people may make mistakes, but still be capable of managing direct payments in the longer term. Even experienced direct payments recipients may have problems at times but, with some support, be capable of overcoming them.
Does the person wish to continue receiving direct payments? As long as the authority considers direct payments are appropriate, it should attempt to enable people to overcome difficulties and prevent them becoming discouraged when they experience difficulties, but if someone has decided that he or she no longer wishes to receive direct payments, then the authority should enable him or her to switch to services.
Has all the money been spent on the services for which it was intended? If the money has been diverted to other purposes there may be a case for considering seeking repayment. There may be a case for requiring repayment of some of the money even where the person has secured services to meet his or her needs, for example if he or she has secured the service for less than the expected cost and so there is a surplus (although the authority should bear in mind that there may be a good reason for a direct payment recipient to build up a surplus, eg to pay his or her employee's quarterly PAYE). The local authority should explain before someone begins to receive direct payments the circumstances in which it would seek repayment.
Have services for which the user has paid been received? If not, then it is the responsibility of the user to seek a refund from the service provider. If the local authority has made further provision for services to meet the same needs or if the services were not received because they were no longer required, then it may wish to consider requiring repayment of the direct payment from the user.
Has the money been spent wisely? If not, the person may need more support to enable him or her to manage, or the authority may decide that he or she is not capable of continuing to manage direct payments and should receive services instead.
47. During the consultation on this guidance, some local authorities expressed concern that they might be perceived as being liable for the actions of the user (eg the way in which the user treats their employees). Local authorities which are concerned about this issue should discuss it, and how it might be handled, with users and carers as part of their overall planning, monitoring and reviewing of the way in which they operate direct payments. Authorities which are concerned about legal liability should also discuss this with their legal advisers.
Discontinuing direct payments
48. Either the authority or the individual may decide at any time that they no longer wish to continue with direct payments. For example, the authority may decide this because it is not satisfied that the person's needs are, in fact, being met, because the person is no longer able to manage direct payments, because the authority has had cause to seek repayment of funds and has reason to fear that further payments may be misspent, or because direct payments are no longer the most cost-effective option. Clearly, wherever possible, the decision to discontinue should follow discussion with the user and any carer, and the authority should, in any case, keep the individual informed throughout the process. The authority may also need to keep in touch with the Independent Living Funds (ILFs) and share information where appropriate in cases where the individual is also receiving ILF funding.
49. There may be circumstances in which the local authority wishes to discontinue direct payments temporarily. Examples might be when a user does not require assistance for a short period (because he or she is in hospital, or because his or her condition improves), or when a user is temporarily unable to manage direct payments (perhaps again due to fluctuation in his or her condition or the support available). In these cases, the authority will need to discuss with the user how best to manage. The aim should be to enable the user to ,resume responsibility for his or her own care after the interruption, if that remains his or her wish. The authority, might decide to take over the management of the user's arrangements in the interim. In considering whether it is practical, desirable and cost-effective to maintain the user's arrangements, the authority should bear in mind any contracts into which the user has entered. How this situation is handled is an issue which the authority should discuss with the user before starting to make direct payments.
50. Where direct payments are discontinued, some people may find themselves with ongoing contractual responsibilities or having to terminate contracts for services (including possibly making employees redundant). The local authority will wish to discuss this with people before they begin to receive direct payments and agree how this would be handled. Authorities should also consider how to recover unspent direct payments if the recipient dies, eg if someone wishes to pay an agency in advance for its services, the local authority should bear in mind that it may be difficult to recover money paid for services which were not in fact delivered. Authorities should also consider, if the direct payment recipient does leave unspent funds to be recovered, that before his or her death, the direct payment recipient may have incurred liabilities which should legitimately be paid for using the direct payment (eg he or she received services for which payment had not been made at the time of death).
Monitoring direct payments as a whole
51. As well as monitoring how well direct payments are meeting the needs of individuals, local authorities will wish to monitor how direct payments are working overall. In doing so, authorities should actively seek the comments and suggestions of people who receive direct payments or who have considered receiving them.
PRACTICE GUIDANCE
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CHECKLIST FOR CARE PLAN FOR DIRECT PAYMENTS |
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