THE CARE ACT 2014 THE DUTY TO ASSESS NEED duty specified in section 1(1). This requires a local...

Doughty Street Chambers 54 Doughty Street, London, WC1N 2LS

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W www.doughtystreet.co.uk

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THE CARE ACT 2014

THE DUTY TO ASSESS NEED

1. This paper considers the duties to undertake assessments of care needs in the Care

Act 2014 ("the Act"), including the primary duty under section 9, the duty to assess

carers under section 10; the transition assessment duties and the out of area

transfer duties under sections 58 and 37 respectively.

The section 9 duty to assess needs

2. Sections 9 to 11 of the Act are concerned with the assessment of needs for care and

support. They are augmented by:

a. The Care and Support (Assessment) Regulations 2014 (“the Assessment

Regulations”);

b. The Care and Support Statutory Guidance of October 2014 (“the Guidance”),

Chapter 6, Assessment and eligibility.

3. Section 9(1) provides: “Where it appears to a local authority that an adult may have

needs for care and support, the authority must assess: (a) whether the adult does

have needs for care and support, and, (b) if the adult does, what those needs are.

4. This duty to assess (defined as a "needs assessment" by section 9(2) of the Act)

replaces the existing duty under section 47 of the NHS and Community Care Act

1990 (“the section 47 duty”). The assessment of an individuals needs for support

still comes before the decision as to whether they are eligible for support or care.


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Threshold for assessment

5. The existing low level of ‘knowledge of possible needs’ is retained. This is made

explicit in section 9(3) which provides:

(3) the duty to carry out a needs assessment applies regardless of the authorities’

view of:

(a) the level of the adult's needs for care and support, or

(b) the level of the adult’s financial resources.

6. Despite slight differences in wording the trigger for assessment is very similar to the

section 47 duty. Thus, as was previously the case, there is no need for anyone to

have requested the assessment.

Content of the Assessment

7. The Act is highly prescriptive as to the content of assessments. Whereas previously

there was minimal input from primary legislation as to content, now section 9 (4)

provides that a needs assessment must include an assessment of “(a) the impact of

the adults’ needs for care and support on the matters specified in section 1(2); (b)

the outcomes that the adult wishes to achieve in day to day life, and (c) whether,

and if so to what extent, the provision of care and support could contribute to the

achievement of those outcomes”.

8. Section 1(2) of the Act defines the scope of ‘well-being’ for the purposes of the

general duty specified in section 1(1). This requires a local authority, when

exercising its functions under the Act in relation to an individual, to promote that


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individual's well-being. Section 1 (2) requires that the well-being must relate to one

of the following areas:

(a) personal dignity (including treatment of the individual with

respect);

(b) physical and mental health and emotional well-being;

(c) protection from abuse and neglect;

(d) control by the individual over day-to-day life (including over care

and support, or support, provided to the individual and the way in

which it is provided);

(e) participation in work, education, training or recreation;

(f) social and economic well-being;

(g) domestic, family and personal relationships;

(h) suitability of living accommodation;

(i) the individual's contribution to society”.

9. The Guidance requires that assessments be ‘person-centred, involving the individual

and any carer that the adult has, or any other person they might want involved‘ (at

paragraph 6.9) and that they must ‘establish the total extent of needs’ (at

paragraph 6.10). The purpose of the assessment is to “identify the person’s needs

and how these impact on their wellbeing, and the outcomes that the person wishes

to achieve in their day-to-day life” (the Guidance at paragraph 6.9).

Process of assessment

10. The Act is also more prescriptive than the previous requirements regarding the

assessment process. As to who can undertake an assessment, the Guidance requires

assessors to be ‘appropriately trained’, but also states that registered ‘social

workers and occupational therapists can provide important support and may be

involved in complex assessments which indicate a wide range of needs, risks and


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strengths that may require a coordinated response from a variety of statutory and

community services’ (at paragraph 6.7).

11. This implies that for non-complex cases social workers may not be necessary.

Although, paragraph 6.88 of the Guidance qualifies this by adding, if an ‘assessor

does not have the knowledge of a particular condition or circumstance, they must

consult someone who has relevant expertise’ and paragraph 6.86 requires that:

“assessors undergo regular, up-to-date training on an ongoing basis. The training

must be appropriate to the assessment, both the format of assessment and the

condition(s) and circumstances of the person being assessed. They must also have

the skills and knowledge to carry out an assessment of needs that relate to a

specific condition or circumstances requiring expert insight, for example when

assessing an individual who has autism, learning disabilities, mental health needs or

dementia”.

Proportionate and appropriate

12. Proportionality and appropriateness are the guiding principles that should inform all

assessments. Regulation 3(1) requires that a local authority carry out an assessment

in a manner which (a) is appropriate and proportionate to the needs and

circumstances of the individual to whom it relates; and (b) ensures that the

individual is able to participate in the process as effectively as possible.

13. In seeking to ensure that an assessment is carried out in an appropriate and

proportionate manner, a local authority must have regard to: (a) the wishes and

preferences of the individual to whom it relates; (b) the outcome the individual

seeks from the assessment; and (c) the severity and overall extent of the individual's

needs (Reg. 3(2)). Further guidance on ensuring that an assessment is appropriate


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and proportionate is set out in the Guidance at 6.35 to 6.43.

14. The new approach is said to be focused on outcomes. This means that processes of

assessment must be “flexible and can be adapted to best fit with the person’s needs,

wishes and goals” (the Guidance at paragraph 6.4).

15. The Guidance at 6.3 states that an assessment may come in different formats and

can be carried out in various ways, including but not limited to:

A face-to-face assessment between the person and an assessor, whose professional

role and qualifications may vary depending on the circumstances, but who must

always be appropriately trained and have the right skills and knowledge.

A supported self-assessment, which should use the same assessment materials as a

face to face assessment, but where the person completes the assessment

themselves and the local authority assures itself that it is an accurate reflection of

the person’s needs (for example, by consulting with other relevant professionals and

people who know the person with their consent).

An online or phone assessment, which can be a proportionate way of carrying out

assessments (for example where the person’s needs are less complex or where the

person is already known to the local authority and it is carrying out an assessment

following a change in their needs or circumstances).

A joint assessment, where relevant agencies work together to avoid the person

undergoing multiple assessments (including assessments in a prison, where local

authorities may need to put particular emphasis on cross-agency cooperation and

sharing of expertise).


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A combined assessment, where an adult’s assessment is combined with a carer’s

assessment and/or an assessment relating to a child so that interrelated needs are

properly captured and the process is as efficient as possible.

16. However, the format of assessment must match the severity and complexity of the

situation and the severity and overall extent of the person’s needs. The Guidance

requires that an individual with more complex needs will require a more detailed

assessment, potentially involving a number of professionals (Guidance, paragraph

6.42).

17. Following section 9 (5), in carrying out a needs assessment the local authority must

involve the adult who is being assessed, any carer, and “any person who the adult

asks the authority to involve or where the adult lacks capacity to ask the authority to

do that, any person who appears to the authority to be interested in the adult's

welfare”.

18. Section 12 of the Act requires the provision of a written record of the needs

assessment to the individual concerned, their carer/s and to anyone else the adult

wishes to be provided with a copy (section 12(3)).

19. Sections 12 (5) and 12 (6) provide for combined assessments where a section 10 and

a section 9 assessment can be undertaken at the same time (see the Guidance at

paragraphs 6.3, 6.74 and 15.14). And following the Guidance, local authorities are

also required to ‘provide in advance, and in accessible format, the list of questions

to be covered in the assessment’ (Guidance, paragraph 6.38).

20. In assessing needs the local authority must disregard any support being provided by


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a carer (Guidance, paragraph 6.15). The ‘eligibility criteria’ regulations1 make

explicit that the decision about whether an adult has eligible needs, is made on the

basis that it does not take into account any support that is being provided by third

parties (i.e. carers): ‘instead, where a person receives support from a carer, this will

be taken into account during the development of the care and support plan.’

21. This approach is again stated at paragraph 10.26 of the Guidance which requires

that authorities ‘must identify, during the assessment process, those needs which

are being met by a carer at that time, and determine whether those needs would be

eligible’.

Strength-based approaches?

22. A local authority must consider whether matters other than the provision of care

and support might contribute to the achievement of the outcomes that the adult

wishes to achieve, and whether the adult may benefit from the provision of

“anything which might be available in the community” or of anything available

under section 2 (measures which have been provided or arranged with a view to

preventing, delaying, or reducing needs for care and support) or section 4 (the

provision of information and advice) (Section 9(6)).

23. The Guidance encourages a strengths-based approach “In considering what else

might help, authorities should consider the person’s own strengths and capabilities,

and what support might be available from their wider support network or within the

community to help” and goes on to give the example that “Strengths-based

approaches might include co-production of services with people who are receiving

care and support to foster mutual support networks.”

1 See the Care and Support (eligibility Criteria) Regulations 2014, regulation 2(3), which states “an adult is to be

regarded as being unable to achieve an outcome if the adult is unable to achieve it without assistance”.


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24. However, the Guidance does provide the caveat that “any suggestion that support

could be available from family and friends should be considered in light of their

appropriateness, willingness and ability to provide any additional support and the

impact on them of doing so. It must also be based on the agreement of the adult or

carer in question” (Guidance, paragraph 6.6.4, emphasis added).

25. Further guidance on the strengths-based approach was published last week by the

Social Care Institute for Excellence2. This was published as part of the work the

Institute is undertaking as part of a government funded program of work to assist in

the implementation of the Act. This guide defines a strengths-based approach as

one that takes into account how the person’s capabilities, knowledge, social

network and community resources can help them meet their care and support

needs and desired outcomes. It goes on to state that “In order to achieve the

benefits of the strengths-based approach, a full picture of the person’s current and

past situation will need to be built up. This will focus both on the problems the

person is experiencing (a deficit-based approach) and on their history (e.g. their

likes and dislikes, hobbies, occupation, social network etc.) to get a picture of their

skills and abilities (a strengths-based approach). In the subsequent discussion it is

possible that the assessor and the person may together identify potential sources of

support not previously considered.”3

Fluctuating needs

26. Regulation 3(3) makes provision for when the adult’s needs fluctuate. This requires

the local authority to consider the individual’s circumstances over such a period as it

2

http://www.scie.org.uk/care-act-2014/assessment-and-eligibility/process-map/ and http://www.scie.org.uk/care-act-2014/assessment-and-eligibility/strengths-based-approach/ 3 http://www.scie.org.uk/care-act-2014/assessment-and-eligibility/process-map/

http://www.scie.org.uk/care-act-2014/assessment-and-eligibility/strengths-based-approach/

http://www.scie.org.uk/care-act-2014/assessment-and-eligibility/process-map/

http://www.scie.org.uk/care-act-2014/assessment-and-eligibility/strengths-based-approach/

http://www.scie.org.uk/care-act-2014/assessment-and-eligibility/process-map/


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considers necessary to accurately establish the individual level of need. The

Guidance also addresses this at paragraphs 6.58 and 6.59.

Supported self assessment

27. The Assessment Regulations make provision at Regulation 2 for “Supported self-

assessment”. A local authority proposing to conduct an assessment must ascertain

whether the person to whom it relates wishes it to be a supported self-assessment

(Reg 2(2)), and if so, the assessment must take that form, so long as the person to

whom it relates has capacity to engage (Reg 2(3)). Supported self-assessments are

addressed in the Guidance at paragraphs 6.44 to 6.53. Notably, paragraphs 6.46 and

6.47 state that once the person has completed the assessment, “the local authority

must ensure that it is an accurate and complete reflection of the person’s needs,

outcomes, and the impact of needs on their wellbeing. The process of a supported

self-assessment begins with first contact and is only complete when this assurance

has been secured” (Guidance, paragraph 6.46). And “In assuring self-assessments

local authorities may consider it useful to seek the views of those who are in regular

contact with the person self-assessing, such as their carer(s) or other appropriate

people from their support network, and any professional involved in providing care

such as a housing support officer, a GP, a treating clinician, a district nurse, a

rehabilitation officer or relevant prison staff”.

Refusal of assessment

28. Under section 11, a local authority may not carry out an assessment where the

person concerned refuses (section 11(1)). However under section 11 (2), this does

not apply, if (a) the person concerned lacks capacity and the authority is satisfied

that carrying out the assessment is in the best interests of the individual or (b) the

person is experiencing or at risk of neglect or abuse.


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29. However, where an assessment is refused, but then requested again at a later date,

the obligations under sections 9 (1) and 10 (1) arise again. This is made clear by

sections 11 (3) and sections 11 (5).

30. This clarifies an area that has caused uncertainty in the past. There are a number of

cases stating that local authorities should not necessarily take a person’s refusal to

be involved in the assessment process as the final word on the matter, and that

authorities need to be persistent to ensure that vulnerable people are not unwisely

leaving themselves at risk: eg R v Kensington & Chelsea RLBC, ex p Kutjim, R (J) v

Caerphilly CBC and R (M) v Hammersmith & Fulham LBC.

31. The duty to assess also arises again, if circumstances change (see section 11 (4) and

section 11 (7)).

Section 10 Carer’s assessment

32. Section 10 provides a detailed framework for carer’s assessments, which brings

them much closer to assessments for people who are themselves in need of care

and support. The new duty arises were it appears that a carer may need support

“currently or in the future”.

33. This expands the scope of the duty: it is no longer necessary that carers already

provide or intend to provide a substantial amount of care on a regular basis.

“Where it appears to a local authority that a carer may have needs for support

(whether currently or in the future), the authority must assess—

(a) whether the carer does have needs for support (or is likely to do so in the

future), and (b) if the carer does, what those needs are (or are likely to be in the


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future)” (section 10(1)).

34. A carer is defined in section 10(3) read with section 10(9) as an “adult who provides

or intends to provide care for another adult”, unless the care is provided under or by

virtue of a contract or as voluntary work. However Section 10(1) provides that

where the care is provided on a contractual basis “the local authority considers that

the relationship between the adult needing care and the adult providing or intending

to provide care is such that it would be appropriate for the latter to be regarded as a

carer, that adult is to be regarded as such.” This is also set out in the Guidance at

paragraph 6.16-6.17 “The local authority has the power to carry out an assessment

in such cases, if it judges that there is reason to do so”.

35. “Care” is to be read for the purposes of section 10 as including “practical or

emotional support” (section 10 (11) and paragraph 61.8 of the Guidance).

36. As with a needs assessment, the duty to carry out a carer's assessment applies

regardless of the authority's view of the level of the carer's needs for support, or the

level of the carer's financial resources or of those of the adult needing care (section

10(4)).

37. A carer’s assessment “must seek to establish not only the carer’s needs for support,

but also the sustainability of the caring role itself, which includes both the practical

and emotional support the carer provides to the adult” (see Guidance paragraph

6.18). This means that the assessment must include a consideration of “potential

future needs”.

38. A local authority, in carrying out a carer's assessment, must have regard to whether

the carer works or wishes to do so, and whether the carer is participating in or

wishes to participate in education, training or recreation (section 10(6)). The


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authority must involve the carer and “any person whom the carer asks the authority

to involve” (section 10(7)).

39. As with a needs assessment, the authority must consider whether matters other

than the provision of support could contribute to the achievement of the outcomes

that the carer wishes to achieve in day-to-day life, and whether the carer would

benefit from the provision of anything under section 2 or 4 of the Act or of anything

which might be available in the community (section 10(8)).

Power to delegate assessments

40. Section 79 (1) of the Act provides that a local authority “may authorise a person to

exercise on its behalf a function” including, inter alia, assessments under sections 9

and 10; this is also referred to in the Guidance at paragraph 6.99 and Chapter 18.

Section 67; independent advocacy

41. Section 67 of the Act contains significant provision for independent advocacy during

the assessment process. The authority must, if the condition in subsection (4) is

met, “arrange for a person who is independent of the authority (an “independent

advocate”) to be available to represent and support the individual for the purpose

of facilitating the individual’s involvement”.

42. The condition in subsection 4 is that the local authority considers that, were an

independent advocate not to be available, the individual would experience

substantial difficulty in doing one or more of the following:

understanding relevant information;

retaining that information;


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using or weighing that information as part of the process of being involved;

communicating the individual’s views, wishes or feelings (whether by talking, using

sign language or any other means).

43. However, there is an exemption on this duty provided by subsection 5, which

excludes the applicability of the duty if the local authority is satisfied that there is a

person;

(a) who would be an appropriate person to represent and support the

individual for the purpose of facilitating the individual’s involvement, and

(b) who is not engaged in providing care or treatment for the individual in a

professional capacity or for remuneration.

44. The Guidance deals with this further at paragraphs 6.23 and 6.33-6.34 and in

chapter 7.

Timescales

45. The Guidance states at paragraph 6.29 that "the assessment should be carried out

over an appropriate and reasonable time scale taking into account the urgency of

the needs and a consideration of any fluctuation in those needs. Local authorities

should inform the individuals of an indicative timetable over which their assessment

will be conducted and keep the person informed throughout the assessment

process."

46. However, there is a seemingly significant caveat to this. It is worth repeating the

Guidance on this point at length, at paragraph 6.61 it requires local authorities to

consider the “benefits of approaches which delay or prevent the development of

needs in individuals. This applies to both people with current needs that may be

reduced or met through available universal services in the community, and those


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without needs who may otherwise require care and support in the future. This could

include directing people to services such as community support groups which ensure

that people feel supported, including an ability to participate in their local

community. It may also include helping the person to access services which the local

authority provides universally, such as preventative services”.

47. It then goes on to state at paragraph 6.62 that “Where the local authority judges

that the person may benefit from such types of support, it should take steps to

support the person to access those services” and if this is the case “The local

authority may ‘pause’ the assessment process to allow time for the benefits of such

activities to be realised, so that the final assessment of need (and determination of

eligibility) is based on the remaining needs which have not been met through such

interventions”.

Assessing children's needs and ensuring continuity

48. Sections 58 and 59 of the Act supplement the leaving care duties currently found in

Part III of the Children Act 1989. They make provision for the assessment and

meeting of the needs of children as they make the transition between child and

adult services at the age of 18.

49. Section 58 of the Act requires a local authority “(1) Where it appears to a local

authority that a child is likely to have needs for care and support after becoming 18,

the authority must, if it is satisfied that it would be of significant benefit to the child

to do so and if the consent condition is met, assess (a) whether the child has needs

for care and support and, if so, what those needs are, and (b) whether the child is

likely to have needs for care and support after becoming 18 and, if so, what those

needs are likely to be” (emphasis added).


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50. “Likely to have needs” is not defined by the Act, however the Guidance at

paragraph 16.9 advises that a young person is ‘likely to have needs’ if they have ‘any

likely appearance of any need for care and support as an adult” and “not just those

needs that will be deemed eligible under the adult statute”. It is likely that young

people who are in receipt of children’s services would be ‘likely to have needs’ in

this context, and local authorities should therefore carry out a transition assessment

for those who are receiving children’s services as they approach adulthood, so that

they have information about what to expect when they become an adult.

51. ‘Significant benefit’ is also left undefined by the Act. The Guidance at paragraph

16.6 advises that it will be of significant benefit to assess “at the point when their

needs for care and support as an adult can be predicted relatively confidently”. In

relation to young people with special educational needs who have an Education,

Health and Care Plan the Guidance states very clearly that the transition assessment

process should begin from year 9 (see paragraph 16.11).

52. Paragraph 16.7 gives further guidance as to the point at which the young persons’

needs for care and support (as an adult) can be predicted reasonably confidently,

stating: “Transition assessments should take place at the right time for the young

person or carer and at a point when the local authority can be reasonably confident

about what the young person’s or carer’s needs for care or support will look like

after the young person in question turns 18. There is no set age when young people

reach this point; every young person and their family are different, and as such,

transition assessments should take place when it is most appropriate for them.”

53. Paragraph 16.10 states that the consideration of ‘significant benefit’ is ‘not related

to the level of a young person or carer’s needs, but rather to the timing of the

transition assessment’. It then provides a helpful list of factors that should be

considered when trying to establish the right time to assess:


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The stage they have reached at school and any upcoming exams;

Whether the young person or carer wishes to enter further/higher education or

training;

Whether the young person or carer wishes to get a job when they become a young

adult;

Whether the young person is planning to move out of their parental home into their

own accommodation;

Whether the young person will have care leaver status when they become 18;

Whether the carer of a young person wishes to remain in or return to employment

when the young person leaves full time education;

The time it may take to carry out an assessment;

The time it may take to plan and put in place the adult care and support;

Any relevant family circumstances;

Any planned medical treatment.

54. Notably, under section 58 (4) where a child refuses a child’s needs assessment and

the consent condition is accordingly not met, the local authority must nonetheless

carry out the assessment if the child is experiencing, or is at risk of, abuse or

neglect.

55. Under section 59 a child’s needs assessment/transition assessment must include an

assessment of (a) the impact on the matters specified in section 1(2) of what the

child’s needs for care and support are likely to be after the child becomes 18, (b) the

outcomes that the child wishes to achieve in day-to-day life, and (c) whether, and if

so to what extent, the provision of care and support could contribute to the

achievement of those outcomes.


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56. Section 66 of the Act provides for ‘continuity of service’ provided under ‘other

legislation’. It amends the Children Act 1989 and the Chronically Sick and Disabled

Persons Act 1970, the effect of which is that assessments of disabled children take

place before the young people become 18, will either continue to apply when they

become 18 until reviewed or if the local authority do not treat the assessments as a

continuing obligation, then they must reassess.

Duty to assess an individual moving into an area

57. If an adult’s needs are being met by an authority (the ‘first authority’) and the adult

notifies a ‘second’ authority that he/she is moving into its area, then under section

37 of the Act the second authority must (a) assess whether the adult has needs for

care and support and, if the adult does, what those needs are, and (b) where the

adult has or is proposing to have a carer and it is appropriate to do so, assess

whether the carer has or is likely to have needs for support and, if the carer does or

is likely to, what those needs are or are likely to be (section 37(6)).

58. When undertaking this assessment, the second authority must have regard to any

care or care plan provided by the first authority. This applies to both needs

assessment and carers assessments (section 37(8)). The first authority must also

keep the adult and carer informed of its contact with the second authority (section

37 (10)). If the second authority’s identification of needs under the assessment

differs from the first authority’s then they must provide a written explanation of the

difference (section 37(11)).

59. Section 38 provides for the circumstance where the second authority’s assessment

is not complete on the day of the move. If, on the day of the intended move, the

second authority has yet to carry out the assessment or assessments under section

37(6), or has done so but has yet to take the other steps required under this Part in


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the adult's case, it must (a) meet the adult's needs for care and support, and the

needs for support of any carer, which the first authority has been meeting, and (b)

where the first authority has been keeping a care account in the adult's case, itself

keep that account on the same basis.

Impact of changes on volume of assessments

60. The impact of the changes made under the Act is likely to include a significant

increase in the volume of assessments local authorities will be required to carry out

in 2015-16 and 2016-17.

61. Local authorities will have to review their processes for assessing the needs of

carers, and will now need to carry out far more assessments than they currently do,

in particular assessments of carers who may have support needs in the future. The

Government’s own analysis estimates that there will be up to 250,000 extra carers

assessments each year (i.e. above the current 400,000 a year). In addition, more

self-funders will seek assessments because of the new funding cap, which means

that even self-funders will need to be assessed and tracked annually. The

Government predicts this will result in up to 230,000 additional assessments when

the cap comes into force in 2016-17.

Louise Price

Doughty Street Chambers

9 March 2015

THE CARE ACT 2014 THE DUTY TO ASSESS NEED duty specified in section 1(1). This requires a local...

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