Government launches new vulnerability debt toolkit

This will be accessible to government departments and public bodies, enabling them to identify and assist individuals whose physical or mental health may affect them repaying money owed.

The aim of the toolkit is to provide government employees with training to handle disclosures of vulnerability, and a framework for gaining more information about an individual’s circumstances. It also provides a protocol for supporting people in potentially dangerous situations or with mental capacity limitations.

Commenting on the news, cabinet office minister Lord Agnew said: “This new guide will ensure an individual’s hardship and circumstances are factored into their cases by government bodies.

“At a time when the country continues on its path to build back better from the pandemic, it’s vitally important we don’t lose sight of the need to not leave anyone behind in the process.”

Charities Christians Against Poverty, the Money Advice Trust and StepChange Debt Charity, as well as ministerial and non-ministerial departments such as the Insolvency Service, Ministry for Justice, the Department of Health and Social Care and the Department for Work and Pensions have been involved in “shaping the toolkit”.

In order to handle disclosures of vulnerability, the toolkit has put forward the TEXAS protocol - something that is widely used by creditors across industries.

• T - Thank the customer.
• E - Explain how the information provided will be used.
• X - Obtain eXplicit consent.
• A - Ask the customer questions to get key information
• S - Signpost or refer to internal or external help.

In order to gain more information about a person’s circumstances, the toolkit proposes the use of the IDEA framework. This is deliberately designed to work across the whole range of vulnerabilities that a customer may present.

• I - Impact: Staff should ask those on the phone what the vulnerable situation stops the customer doing in terms of their financial situation.
• D - Duration: Staff should discuss how long the customer has been living with the reported vulnerability.
• E - Experiences: As some people may have more than one experience of their vulnerable situation, staff will need to take such fluctuating situations into account.
• A - Assistance - Staff should consider whether the customer has been able to get any care, help, support or treatment for their situation.

In addition to this, the debt management vulnerability toolkit has set up a separate protocol for handling disclosures from carers through the CARERS protocol.

• C - Check for authority: Make sure that the carer has the authority to act on the customer’s behalf.
• A - Avoid discussing any account details.
• R - Reassure the carer that their concerns can still be recorded as observations.
• E - Explain to the carer their observations will need to be shared with the customer.
• R - Record the carer’s observations.
• S - Summarise the next steps.

In order to help staff to support customers with mental capacity limitations, the toolkit puts forward the BRUCE protocol. It was first developed to help financial services staff to identify mental capacity limitations.

• B - Behaviour and talk: Staff should look for indicators of a limitation in the customer’s behaviour and speech.
• R - Remembering: is the customer experiencing problems with their memory?
• U - Understanding: Does the customer understand the information they are given by staff?
• C - Communicating: Can the customer communicate their thoughts, questions and ultimately a decision about what they want to do?
• E - Evaluating: Can the customer “weigh-up” the different options to open to them?

When using this protocol, staff should always presume customers have the mental capacity to make the decision in question and provide reasonable support to individuals to help them make their own decision and provide reasonable support to individuals. They should also always remember that the decision is always the customers, and avoid guessing what’s “wrong” with a customer.

To find the full details of the advice, click here.