Direct Payments and Risk: What Commissioners Expect Providers to Know

Direct Payments and Risk: What Commissioners Expect Providers to Know


Why Risk Awareness is Essential for Providers

Direct Payments offer people more choice and control over their care, but for providers, they bring heightened risks. These risks include safeguarding vulnerabilities, financial management concerns, and blurred lines of accountability between the person, the local authority, and the care organisation.

Commissioners increasingly expect providers to understand these risks and demonstrate robust governance when bidding for contracts or working under Direct Payment arrangements.


Key Risks Providers Should Recognise

  • Safeguarding: Direct Payment arrangements can reduce oversight, increasing safeguarding risks if not properly managed.
  • Financial Mismanagement: Providers may be exposed to late payments, misuse of funds by recipients, or lack of clarity over invoicing responsibilities.
  • Accountability: Confusion over who is responsible for what can leave providers vulnerable to disputes or non-compliance claims.

What Commissioners Expect to See

In tenders and provider assessments, commissioners will typically look for evidence that you:

  • Understand the specific risks linked to Direct Payments.
  • Have governance in place to manage these risks effectively.
  • Can safeguard individuals while respecting choice and control.
  • Have clear terms for payment and accountability with individuals and commissioners.

Your ability to evidence this through robust policies, risk assessments, and staff training will strengthen both your reputation and your success in tendering.


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Updated for Procurement Act 2023 β€’ CQC-aligned β€’ BASE-aligned (where relevant)


Written by Impact Guru, editorial oversight by Mike Harrison, Founder of Impact Guru Ltd β€” bringing extensive experience in health and social care tenders, commissioning and strategy.

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