TL;DR (for busy SEA leaders)
- IHM (Intensive Housing Management) is HB-eligible when it’s a landlord-side housing management function that is necessary for occupation and material to tenancy sustainment—distinct from care/support (which is not HB-eligible) and from core landlord costs (repairs, arrears chasing, general overhead).
- Auditors and councils look for three proofs: (1) necessity (“why is this needed for these tenants in this scheme?”), (2) delivery by/for the landlord (not a support provider unless contracted “by or on behalf of” the landlord), and (3) auditable evidence (task logs tied to individuals/units, frequency, time, role).
- Charges fail when there’s double-counting with support contracts, generic overheads, vague task descriptions, or no time attribution.
- Win audits by using a bottom-up costing, tight task taxonomy, rota + log evidence, and clean separation between IHM vs support vs ineligible landlord functions.
1) IHM in Plain English (what it is—and isn’t)
Think of IHM as enhanced housing management you only need because of the higher risks/needs in supported or specialist schemes: intensified tenancy sustainment, safeguarding-adjacent vigilance (but not care), environmental management that prevents nuisance/ASB, and resident coaching on housing use (not therapy or personal outcomes).
Is IHM (usually eligible):
- Pre-tenancy readiness checks focused on housing (explaining licence conditions, community rules, safety briefings).
- Enhanced move-in/set-up for complex residents (key-safe, safe-use orientation, utilities set-up where failure risks tenancy).
- Sustained tenancy work: compliance with house rules, guest policy enforcement, noise/ASB mediation, safeguarding alerts (hand-off to support), structured reminders for rent/HB evidence, escorted property access where needed.
- Hygiene & safety inspections beyond normal periodic checks (e.g., daily communal standards checks where risk profile warrants it), sharps sweeps in schemes with known risks.
- Coordinating multi-agency housing actions (police/ASB teams/landlord panels) to protect occupation and quiet enjoyment.
- Out-of-hours housing response/concierge for building and tenancy safety (not clinical observation).
Is not IHM (usually ineligible):
- Care/support tasks: keywork sessions on mental health, benefits maximisation, therapy, life-skills beyond housing use, case management, personal outcomes planning.
- Repairs & maintenance; capital improvements; cyclical compliance (gas/elec testing); these are landlord core costs.
- Arrears enforcement/credit control as a standalone “IHM” line.
- General overheads (HQ admin, finance team, directors) rebadged as “intensive management.”
- Security guards/NVC that primarily serve non-housing outcomes (unless clearly preventing tenancy loss/unsafe occupation and evidenced as such).
2) The Audit Lens: What Investigators Actually Check
Auditors don’t start from ideology—they start from files. Expect them to ask:
- Task taxonomy – A written schedule listing IHM tasks with: description, why necessary, frequency, role who delivers, and how logged.
- Bottom-up costing – Rate cards per role (salary + on-costs), productivity factor, % time to project/scheme, and the per-unit/week allocation method.
- Evidence chain – Real logs: daily/weekly entries naming who/where/what/why/how long; rotas that match logs; supervision/QA notes; incident reports that show housing actions (not support plans).
- Separation – A clean line between IHM and support (different budget lines, job descriptions, and logs). If support funding exists, auditors look for no double funding.
3) Task Table: Survives vs Fails (with why)
| Task pattern | Likely outcome | Why |
|---|---|---|
| Tenancy sustainment visits with house-rules coaching, logged per resident (10–20 mins, weekly/fortnightly) | ✅ Survives | Housing-specific, necessary for occupation, evidenced with time and outcome |
| Communal standards inspections (daily sweep in high-risk schemes) with action notes | ✅ Survives | Prevents tenancy/environmental risk; frequency tied to risk profile |
| ASB early-intervention letters/door-knocks, multi-agency liaison to protect quiet enjoyment | ✅ Survives | Core housing function directly preventing tenancy loss |
| Night concierge with incident log focused on building safety/tenancy risks | ✅/⚠️ Depends on logs | Survives if logs show housing risk management; fails if “present but nothing recorded” |
| General “support sessions”, keywork towards personal goals | ❌ Fails | That’s support/care, not housing management |
| Repairs coordination, void turnaround, cyclical compliance | ❌ Fails | Core landlord functions, not additional IHM |
| “Management overhead” without role/time breakdown | ❌ Fails | Unattributed overhead ≠ eligible IHM |
| Security contractor with no tenancy-linked incident narrative | ❌ Fails | Looks like generic guarding, not housing management |
4) Bottom-Up Costing That Auditors Trust
Step 1: Roles & rates. For each IHM-delivering role, calculate an hourly loaded rate: salary + NI + pension + holiday + supervision + training + payroll overheads → divide by productive hours (not contractual hours).
Step 2: Time attribution. Use rotas + timesheets + logs to show hours per week per scheme.
Step 3: Allocation. Scheme IHM total £/week ÷ occupied units → £ per unit per week.
Step 4: Cross-checks.
- Does rota × weeks ≈ logs total time?
- Do supervision notes reference the IHM task list?
- Is there no overlap with a support contract (funding stream, outcomes, logs)?
Sanity test: If you removed IHM tomorrow, what tenancy/occupation failures would appear within 30 days? Your narrative should make that obvious.
5) Evidence Pack (build this before anyone asks)
- IHM Schedule (2 pages): task taxonomy, frequency, risk rationale per task.
- Role briefs: job descriptions highlighting housing management duties; a one-pager mapping duties → IHM tasks.
- Rota set + sample logs (last 8–12 weeks): date/time, unit/resident initials, action, duration, outcome.
- Costing workbook: rate build-ups, attribution, allocation, and version control.
- Separation memo: one page that draws the boundary between IHM and support in your service model.
- Trigger library: examples of tenancy-linked incidents (noise, guests, fire safety breaches) and the IHM response taken.
6) Common Failure Modes (and the quick fixes)
- Vague language (“resident support provided”): Fix: rewrite logs to housing verbs—“enforced guest policy,” “noise warning issued,” “bin contamination corrected; resident briefed.”
- No time data: Fix: add start/finish or duration minutes to every log entry; round to 5-minute blocks.
- Double-counting with support: Fix: single source of truth—if it’s in a support file, don’t bill as IHM unless the housing action is distinct and logged in IHM.
- Generic concierge: Fix: nightly checklist tied to tenancy risks (fire exits clear, guest control, noise patrol), with exception logging.
- One giant “management” line: Fix: split by role, show rate × hours × units; narrative per role.
7) Mini Templates You Can Paste Into Your Pack
A) IHM Task Definition (use as a master row format)
- Task: Guest policy enforcement (door knocks + written notices)
- Why necessary: Prevents unauthorised occupancy and ASB jeopardising other residents’ quiet enjoyment and tenancy security
- Frequency: As required; typical 1–3 times/week per scheme
- Delivered by: Housing Officer / Concierge (landlord)
- How evidenced: Log entry per intervention (resident/flat, time, action, outcome), copy of notice where issued
B) Log Entry (example – 2 lines)
- 10:25–10:40 2B – Noise complaint from 1A; spoke with tenant; issued Stage 1 warning; agreed quiet hours; follow-up booked Fri.
- 22:10–22:20 Front entrance – Challenged unauthorised guest; refused entry per house rules; resident briefed; incident note filed.
C) Separation Statement (drop into your policy)
“IHM in this scheme consists solely of landlord-side housing management tasks required to enable safe occupation and tenancy sustainment. It excludes personal support or care. Where a task could appear in both spheres, it is logged once as housing management only if its primary purpose is tenancy sustainment or estate safety.”
8) Council Challenge Patterns → Your Rebuttals
“This looks like support.”
Rebuttal: “This task enforces licence conditions and protects quiet enjoyment (see logs and letters). No case notes, therapy or outcomes planning are involved. It’s performed by housing staff and evidenced as a tenancy intervention.”
“Provide all staff HR/DBS files.”
Rebuttal: “Reg 86 requires evidence reasonably needed to determine entitlement. We’ve provided role briefs and logs demonstrating landlord delivery. Bulk HR files are not relevant to the entitlement decision; we can confirm roles/clearances where proportionate.”
“Security is not eligible.”
Rebuttal: “Generic guarding is not; however, our concierge function undertakes specific housing risk controls (guest policy, noise, safety checks) documented in housing logs. See incident-outcome trail attached.”
“Overhead can’t be IHM.”
Rebuttal: “Agreed—hence our bottom-up costing excludes HQ overheads and attributes only productive housing time by role, evidenced by rotas and logs.”
9) Pricing & Reasonableness (how to keep it defensible)
- Anchor your figure in time and risk. Higher-risk schemes justify higher frequency and out-of-hours cover; show that logic.
- Keep productivity honest (e.g., 70–80% for field roles). Don’t forget supervision—but keep it lean and linked to IHM quality assurance.
- Review quarterly: if logs show consistently less activity than budgeted, re-set the allocation and credit back—auditors love that discipline.
10) One-Page Reference (pin this)
IHM = landlord-side, tenancy-sustainment management that is necessary for occupation.
To pass audit, every £ must answer: What tenancy risk did we prevent? Who delivered it (landlord)? Where is it logged and timed?
Hard NOs: support/care, repairs/voids, arrears chasing as “IHM,” rebadged HQ overheads.
Your pack: IHM schedule ▸ role briefs ▸ rota + logs ▸ bottom-up costing ▸ separation memo ▸ trigger library.
Language in logs: housing verbs (enforce, warn, inspect, mediate, secure, brief), not support verbs (coach, counsel, plan, keywork).