Supported Exempt Accommodation
DualRecord is the first activity recording system built specifically for supported exempt accommodation providers — capturing both HB-eligible IHM costs and CSS threshold evidence in a single entry, eliminating the compliance gap that leaves providers exposed.
Built on the Turnbull framework. Aligned with DWP guidance paragraph 153. Ready for SHROA licensing.
Phase 1 now live. Accepting expressions of interest from providers.
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The Opportunity You Are Missing
Every activity you record for a supported tenant potentially does two things simultaneously. It may constitute an accommodation-related cost eligible for inclusion in your Housing Benefit eligible rent — that is IHM, and it is chargeable. It may also count toward the "more than minimal" CSS threshold that justifies your exempt accommodation status — that is CSS evidence, and it is not chargeable but it is essential.
The legal authority for this is clear. In Allerdale BC v JD [2019] UKUT 304, the Upper Tribunal confirmed that a single activity can satisfy both tests at the same time. A welfare check, an enhanced repair, a safeguarding intervention, tenancy sustainment work — these activities are simultaneously IHM-eligible costs and CSS-qualifying evidence.
But most providers record them once in a maintenance log and once in a support log, in separate systems that cannot speak to each other. When a challenge arrives — from an HB team, from a First-tier Tribunal, from a local authority questioning exempt status — they cannot produce coherent evidence for either test.
DualRecord captures both dimensions in one entry. The worker records what happened once. The system tags it against both legal tests automatically and builds a running evidence trail.
"A single activity can simultaneously constitute HB-eligible Intensive Housing Management and count toward the CSS threshold. Most providers are recording it twice and evidencing it never."
When an HB team challenges your eligible rent, you need to show that the costs you are claiming relate to intensive housing management — activities that go beyond ordinary housing management and arise from your tenants' vulnerabilities.
When a local authority challenges your exempt accommodation status, you need to show that you provide care, support, or supervision that is more than minimal — regular, structured, outcomes-focused, delivered one-to-one, evidenced by a contemporaneous record.
These are different legal tests. But they draw on the same underlying activity data. If your records were not designed to capture both, you will fail one or both challenges — even if you are actually providing excellent support.
Property-facing activities recorded by the property team. No vulnerability link, no real difference narrative, no CSS evidence value.
Support sessions recorded by the support team. No cost attribution, no Turnbull analysis, no IHM evidence value.
When the challenge arrives, the two data sets cannot be cross-referenced. The provider scrambles to retrospectively construct evidence that was never captured in the right form.
How DualRecord Works
The worker opens one form. They record what happened — the category, description, duration, and how the activity was delivered. One entry. No duplication.
Based on the activity category, DualRecord pre-populates the IHM eligibility status, the CSS-qualifying status, and the Turnbull framework points engaged. The worker confirms or adjusts. Three guided fields capture the vulnerability link, the beyond-ordinary justification, and the real difference narrative — the exact evidence needed for both legal tests.
Every activity adds to a running evidence trail. The tenant profile shows the CSS threshold indicator in real time. Compliance alerts flag gaps. The system prompts re-engagement attempts when tenants disengage. When a challenge arrives, the evidence is already there.
"The legal analysis is embedded in the system. Front-line workers do not need to understand the law — they record what happened, and DualRecord captures the evidence."
Key Features
Every activity is simultaneously assessed against the HB-eligible IHM framework and the CSS threshold test. Category defaults encode the legal analysis. Workers confirm or override.
Real-time dashboard showing each tenant's CSS-qualifying activity in the last 28 days — weekly average, one-to-one session count, and a status: Likely met, Borderline, or At risk. Based on DWP guidance paragraph 153.
The seven points from Chorley BC v IT [2009] UKUT 107 are embedded in every activity record. Each entry maps to the specific Turnbull points it engages, building an aggregate analysis across tenants and schemes.
Automated daily checks flag tenants with no CSS-qualifying activity in 14 or more days. Email nudges go to assigned workers with a direct link to record a re-engagement attempt.
Automated generation of CSS threshold packs, IHM claim packs, combined packs, and appeal packs as branded PDF and DOCX. Structured for HB submissions and First-tier Tribunal proceedings.
As the Supported Housing (Regulatory Oversight) Act 2023 licensing regime matures, evidence pack templates update centrally for all providers. The data model is designed for the incoming national standards.
Who It Is For
Built on the Case Law
DualRecord was built by a supported housing legal analyst with sector-defining expertise in exempt accommodation law. The activity category defaults, the Turnbull framework mappings, the Schedule 1(f) risk flags, and the CSS threshold logic are not generic compliance features — they are a direct operationalisation of the case law.
"DualRecord does not give legal advice. It gives you a legally-structured evidence trail built to withstand challenge."
Expression of Interest
Phase 1 is live with pilot providers. We are preparing to open DualRecord to a wider group of supported exempt accommodation providers. Register your interest below and we will contact you when places become available.
We have received your expression of interest and will be in touch when DualRecord opens to new providers. In the meantime, if you have questions, contact us at hello@dualrecord.co.uk.
About
DualRecord is a product of Leonard Payne Consulting. Leonard Payne is a supported housing legal analyst, consultant, and publisher specialising in supported exempt accommodation law, Housing Benefit Regulations, and the SHROA 2023 regulatory framework. He is the author of the sector's definitive legal handbook on exempt accommodation and the publisher of the Supported Housing Briefing.
DualRecord operationalises the legal analysis from his briefing note "Same Activity, Two Legal Tests" (March 2026), which established the dual-eligibility framework that the system is built on.
Contact: hello@dualrecord.co.uk