Supported Exempt Accommodation — England and Wales
DualRecord is the only activity recording system built specifically for supported exempt accommodation providers — capturing HB-eligible IHM costs and CSS threshold evidence in a single entry, eliminating the compliance gap that leaves providers exposed at tribunal.
Built on the Turnbull framework. Aligned with DWP guidance paragraph 153. Ready for SHROA licensing.
Now accepting applications from supported exempt accommodation providers.
Subscriptions are by application. 28-day free trial on Professional tier.
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.
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, a local authority questioning exempt status, or a First-tier Tribunal — they cannot produce coherent evidence for either test. DualRecord captures both dimensions in one entry, every time.
“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. Useful for repairs schedules. Useless at tribunal.
Support sessions recorded by the support team. No cost attribution, no Turnbull analysis, no IHM evidence value. They show something happened. They cannot show what legal test it satisfies.
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. Retrospective reconstruction is one of the weakest positions you can be in at a First-tier Tribunal.
How DualRecord Works
The worker opens one form. They record what happened — the category, description, duration, and how the activity was delivered. One entry. The system does the rest.
Based on the activity category, DualRecord pre-populates the IHM eligibility status, the CSS-qualifying status, and the Turnbull framework points engaged. Three guided fields capture the vulnerability link, the beyond-ordinary justification, and the real difference narrative — the exact evidence needed for both legal tests simultaneously.
Every activity adds to a running evidence trail. The tenant profile shows the CSS threshold indicator in real time. Compliance alerts flag gaps before they become problems. 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 per-tenant dashboard showing 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. In active development — released to all eligible subscribers automatically on launch.
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.
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.”
Pricing
All plans include a 28-day free trial on the Professional tier. Annual billing available on all tiers: pay for 10 months, get 12.
£990 / year
Up to 25 bed spaces
£1,990 / year
Up to 100 bed spaces
£3,490 / year
100+ bed spaces or multi-scheme
All plans include unlimited users and provider-branded evidence packs. Evidence pack generation (marked Phase 2) is in active development and will be released automatically to all eligible subscribers on launch. Subscriptions are by application — we review each application to ensure DualRecord is the right fit for your organisation.
Apply for Access
Complete the form below. We review every application personally and will be in touch within two working days. If DualRecord is the right fit, we will set up your account with a 28-day free trial on the Professional tier.
Thank you. We have received your application and will be in touch within two working days. In the meantime, if you have any questions email 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 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