Policy for payments arising from the involvement of the public in the work of the HRA

If you would like this policy in an alternative format, please get in touch with the public involvement team at public.involvement@hra.nhs.uk

1.Background

2.Purpose

3.Scope

4.Limitations

5.Covering your expenses

• 5.1 Travel
• 5.2 Rail travel
• 5.3 International and air travel
• 5.4 Taxi travel
• 5.5.Car and bicycle travel
• 5.6 Accommodation
• 5.7 Subsistence (meals / refreshments)
• 5.8 Carer’s allowance
• 5.9 Carer’s costs
• 5.10 Personal assistants and support workers

6.Payment fees for involvement

7.Tax and national insurance

8.Advice for people receiving welfare benefits

9.Processing claims

• 9.1 How will fees and expenses be paid?
• 9.2 Changing your bank or address
• 9.3 Payments to an organisation

10.Exceptional circumstances

11.Enquiries

12.Review

• 12.1 Screening Questions - HRA Equality Analysis and Data Protection Impact Assessment
• 12.2 Initial Equality Impact Assessment

The Health Research Authority (HRA) is committed to involving patients, service users, carers and other members of the public in its work. When we do, this work is undertaken with and by those people working as advisers with our staff. In recognition of this we offer to pay people a fee for their involvement. We also cover people’s expenses. We refer to the people we involve in our work as ‘public contributors’.

This policy covers how we will pay fees and expenses to the people we involve in our work. It is based on guidance from the Department of Health and Social Care, a review of good practice amongst other national research organisations and the HRA’s previous policy.

It is for use by HRA staff who involve the public in their work and the people we involve. In this paper, ‘we’ means the HRA or HRA staff and ‘you’ means a public contributor involved in our work. HRA staff managing or administering payments to public contributors should refer to Procedure for payments arising from public involvement v1.1 08.04.19.

If you receive welfare benefits of any kind, please read section 8 of this policy before accepting any opportunity to get involved in the work of the HRA.

This policy concerns the payment of agreed fees and expenses for patients and the public who we involve in our work (public contributors).

This policy does not cover the valuable work that is carried out by volunteers who sit on HRA committees including Research Ethics Committees and the Confidentiality Advisory Group. However, there may be instances when we involve a public contributor who may sit on a HRA committee. On occasions such as this, the public contributor will not be contributing to our work in their capacity as a HRA committee member; they will be offering their perspective as a patient or member of the public.

It is important that this distinction is made clear to the public contributor and clarified when payment of fees and expenses are made in accordance with this policy and accompanying procedure for staff. Additionally, this policy also does not cover the recruitment, employment or contracting with any other individuals or with user-led and patient organisations or on behalf of HRA. These are addressed in HRA member, procurement, and Human Resources policies.

Section 242 of the Consolidated NHS Act 2006 (Section 11) obliges NHS organisations, including the HRA, to involve patients and those close to them in the planning of the provision of services; the development and consideration of proposals for changes in the way services are provided; and decisions to be made affecting the operation of services. The NHS constitution principle 4 also promotes NHS organisations to actively encourage feedback from the public, patients, and staff, welcome it and use it to improve its services.

We use the term public involvement as a short-hand term. By public we mean patients, service users, survivors, carers and family members.

Whilst all of us are actual, former, or indeed potential users of health and social care services, there is an important distinction to be made between the perspectives of the public and the perspectives of people who have a professional role in health and social care services or research.

The HRA will not pay fees or expenses to people we involve for time already contracted or paid by another organisation, e.g. a university or NHS organisation.

This section provides detailed guidance on the range of reasonable and necessary expenses that the HRA may cover arising from your involvement in our work;

• Travel (including rail, international and air, taxi, car and bike)
• Accommodation
• Subsistence (Meals / refreshments)
• Carer’s allowance
• Carer’s costs
• Personal assistants and support workers

If you have a question about your expenses, please talk to your HRA contact beforehand. The HRA has the right to refuse to reimburse any unreasonable expense claims.

This policy uses the term ‘covering your expenses’ to describe three ways in which HRA may pay expenses.

The first is that we offer a standard £5 per day expenses to contribute to the cost of attending online meetings. Evidence of spend such as receipts do not need to be provided to receive this.

The second is that, where possible and appropriate, we will pay directly for the costs ourselves, for example, by purchasing travel tickets or travel cards ahead of your journey, by booking and paying for hotel accommodation in advance, or by paying an alternative carer or personal assistant directly. You are strongly encouraged to book travel and accommodation through a HRA contact, in order to obtain the best possible prices.

The third is by you claiming back money that you have paid out as a result of your involvement in our work, which we refer to as ‘reimbursement.’ If you wish to have your expenses reimbursed, you should ensure that you are aware of the costs we cover beforehand and you will need to provide receipts for everything that you have paid for. You must discuss and approve these in advance with your HRA contact.

If you receive state benefits of any kind please read section 8 of this policy before accepting any opportunity to get involved in our work and incurring any expenses.

5.1 Travel

The HRA encourages the use of travel by the most cost-effective and sustainable method of transport where possible, recognising that some travel choices need to be guided by accessibility rather than sustainability. We encourage the use of public transport and electric cars on the basis of our commitment to Greening Government Commitments.

5.2 Rail travel

You are strongly encouraged to book rail tickets in advance through your HRA contact wherever possible, in order to obtain the best possible prices. Please advise your HRA contact of any current railcards you have when you request a travel booking or if you have any accessibility requirements.

We only reimburse at standard class travel rates unless there are cheaper ‘deals’ available for particular journeys or as a reasonable adjustment due to a disability, which should be discussed and approved in advance with your HRA contact. You should keep costs to a minimum by purchasing the cheapest standard train ticket available, making use of advance ticket purchase discounts wherever possible.

If you have a railcard that provides a discount on rail or bus fares then this can be used for fares booked for you by HRA staff and can also be used where you purchase tickets yourself.

5.3 International and air travel

Our aim at the HRA is to minimise all short-distance flights given their impact on the environment. No domestic flights should be booked unless to Ireland. If exceptionally a flight is required, this must be discussed and approved in advance with your HRA contact, who will need to gain approval from the HRA’s Director of Finance. Tickets for travel by air or international rail should be purchased for you by a HRA member of staff, unless an alternative arrangement has been agreed as part of that approval process.

If a flight is required, economy class travel or its equivalent class should be booked, unless there are cheaper ‘deals’ for particular journeys. If you have accessibility requirements such as priority boarding or airport assistance, please tell your HRA contact before travel is booked. Any non-standard travel must be discussed and approved in advance with your HRA contact. Journeys should also be booked sufficiently in advance to obtain the best possible prices.

5.4 Taxi travel

Travel by taxi should not occur routinely, unless agreed with your HRA contact as a reasonable adjustment, as more other sustainable methods of transport that offer better value for money should be prioritised. The specific circumstances in which travel by taxi is an allowable expense are outlined below.

• in cases of poor mobility or disability or if required as a reasonable adjustment
• in emergencies
• when carrying heavy luggage, such as suitcases (this does not include laptops or documents)
• if no other public transport is reasonably available due to location / unsociable time of travel
• when travelling early in the morning / late at night where personal safety is perceived to be an issue

Any claims for travel by taxi should include a receipt and should show the reason for using a taxi from the allowable list, as well as the start and end postcode of the journey.

If any of the above conditions are not met, claims will be reduced to the equivalent public transport fare. In this case the HRA staff member processing the claim will replace the sum claimed with the cost of public transport that could have been used.

Claims for taxis to and from the HRA’s offices will not normally be met because public transport is readily available, unless essential due to any of the above reasons.

5.5 Car and bicycle travel

Using an electric car can offer a sustainable and efficient form of travel and is encouraged by the HRA. On occasions where you need to travel by petrol / diesel cars or motorcycle for your journey, for example as a reasonable adjustment due to a disability, please confirm this with your HRA contact prior to making your journey.

You can also claim a mileage rate for use of your own transport where this can be justified instead of using public transport.

In order to claim a mileage allowance, you must confirm (by completing the HRA Payment form for Public Involvement in HRA Activities) that the vehicle is in good working order, fully insured, taxed and has a current valid MOT certificate.

Where this confirmation is provided the HMRC car mileage rate of 59p per mile will be paid or 30p per mile for motorcycle travel. Claims may be audited from time to time in which case you may be asked to provide the registration number of your vehicle in order to confirm insurance and MOT requirements have been met.

Parking fines, clamping charges and penalty fees for non-payment of congestion charges will not be reimbursed.

For travel by bicycle the HMRC cycle milage of 20p per mile will be paid.

5.6 Accommodation

In general, HRA meetings and involvement activities are held at accessible locations and times during the day where accommodation costs are not normally necessary.

Where accommodation might be required, you should speak to your HRA contact who will normally arrange this for you up to a maximum overnight cost (inclusive of breakfast and VAT) of:

• London / Bristol / major European city maximum of £130 per night
• Outside London maximum of £85 per night

If booking full board accommodation £25 a night can be added to the limits above.

Incidental expenses such as mini-bars, private telephones and newspapers will not be paid by the HRA and must be settled by the individual directly with the hotel.

If you choose to stay with friends or family you can claim a flat 24 hours subsistence rate of £25. This includes an allowance for meals. No receipts are required and the payment will be subject to income tax.

5.7 Subsistence (meals / refreshments)

If the involvement work you do for the HRA requires you to travel away from home for more than five hours, including the lunch time period 12pm to 2pm, and where appropriate refreshments have not been provided, including as part of an all inclusive package with accommodation, you can claim reimbursement for the cost of a meal up to the maximum allowances shown below, provided that you attach receipts to your payment form.

Limits for the amount that can be claimed for meals / refreshments:

The cost of any alcoholic beverages will not be reimbursed.

5.8 Carer’s allowance

You are able to claim for costs incurred for the care of children, a dependent relative or their own carer requirements when necessarily incurred as a result of your involvement activity with the HRA. You will need to discuss any arrangement in advance.

The allowance should cover costs incurred up to the following hourly limits:

5.9 Carer’s costs

If it is necessary for an informal (unpaid) carer (such as a relative or friend) to accompany you for your work with the HRA, their expenses (travel, accommodation and meals / refreshments) can also be covered.

We can pay directly for these expenses or reimburse them after the event. You will need to discuss this arrangement in advance with your HRA contact. All claims require relevant receipts.

5.10 Personal assistants and support workers

If you use a personal assistant (PA) or support worker to accompany you, their expenses and costs can also be covered. You will need to discuss any such arrangement in advance with your HRA contact. The HRA can pay the personal assistant or support worker directly. For the HRA to reimburse these costs you will need to provide evidence of the expenditure, such as receipts, tickets, or an invoice.

Remember if you are in any doubt about whether you are entitled to have your expenses reimbursed by the HRA, please check with your HRA contact before spending any money. The HRA has the right to refuse to reimburse you for any unreasonable expense claims

Fees are ‘honorarium’ payments. They are a form of reward and recognition offered for the contribution that you make to the work of the HRA. This does not mean that you have a contract of employment with the HRA.

The HRA will always make clear what fees, if any, will be offered when an opportunity to be involved in our work is made available. It is then your choice as to whether or not you take part, and whether or not you accept any payment that is offered. We use the word fees to describe the money you may be offered for the contribution of time, expertise and skills.

As defined in our strategy for public involvement, when we involve patients and the public the work we do is undertaken with and by them working as advisers with our staff. It is in recognition of this that we offer you a fee for your involvement.

The HRA involves the public in a number of ways, which include asking people to:

• contribute to the development and drafting of policies and procedures, reports, website content and other documentation, which may be done in person or by email, phone or online meeting
• attend workshops or meetings with staff and other contributors to work with them to provide comments or contribute their views
• work alongside staff members of project teams developing new areas of work
• be a member of an interview panel for recruitment of staff or to appoint an organisation to do some work for the HRA
• contribute to the development and delivery of training sessions for staff

The payment scale adopted by the HRA and a number of other organisations is based on INVOLVE’s guidance agreed with the Department of Health in 2009 and is based on the duration of the task required. Each of the rates of payment below may cover one-off activities or those that take place over a longer period of time, for example being the member of a steering or advisory group for a piece of work. The relevant fee may be paid for each task of that particular length of time or for the whole piece of work depending on the length of time elapsed between separate tasks.

The different levels of fees paid by the HRA for involvement:

You may need to pay tax and national insurance (NI) on any payment you receive for your involvement. This depends on your level of income, whether you are retired, self-employed and / or receiving state benefits. It is your responsibility to find out whether you do need to pay tax and / or NI and to pay what you owe as a result.

The general rule is that you are required to inform HM Revenue and Customs (HMRC) if your total income (including the fees paid by HRA) is greater than your personal income tax allowance at the end of the financial year. Personal tax income allowances are set each year and depend on individual circumstances. Further information can be found on the HMRC website. If payment for your involvement takes you over your personal allowance, you will be required to declare it.

If you have any questions about tax or NI, it is best to contact your local HMRC office. You can find this on the HMRC website or call the HMRC helpline on 0300 200 3311. We are sorry but HRA staff cannot help you with this.

Tax and National Insurance Contributions will not be deducted by the HRA. Remember, you may be liable to pay Tax and National Insurance on the fees you have received and therefore you will need to check your total annual taxable income at the end of the financial year (5 April).

If you are receiving welfare benefits, it is vital that you seek independent advice before you accept any opportunity to get involved in the work of the HRA and any related offer of payment including reimbursement of expenses. Different benefits have different rules and set limits on what you can be paid before your benefits are affected. It is your responsibility to check whether you can receive any additional

payments without this affecting your benefits. It is important to do this ahead of time - otherwise your benefits could be withdrawn.

We are sorry but HRA staff cannot provide you with advice on how payments may affect your benefits or how to deal with Jobcentre Plus. If you have any questions it is best to contact your local JobCentre Plus (National Jobcentre Enquiry Line: 0345 604 3719 or www.gov.uk/contact-jobcentre-plus) or Citizens Advice (Consumer helpline 03454 040506).

However, the HRA can currently provide you with direct access to the Benefits Advice Service for Involvement which is a confidential specialist service delivered by Bedford and District Citizens Advice Bureau.

The service can support you:

• to make an informed decision on whether and how to get involved in the work of the HRA, based on current, reliable information on your benefits and the activity that you are involved in or being offered by the HRA
• in corresponding with the Department for Work and Pensions about your involvement work

For direct access to the service, please contact the public involvement team on public.involvement@hra.nhs.uk or 0207 104 8161.

To claim for reimbursement of expenses and payment of fees, if they are offered, we will send you a form to complete. If you have any difficulties completing the form please ask your HRA contact for help.

Claims should be submitted to your HRA contact for their approval. They will check that claims are in line with the policy, agreements and authorise them for payment provided that all payment forms have been digitally ‘signed’ and include relevant receipts and documents.

In particular your HRA contact will check that:

• claims are for reasonable, validated expenses and are in accordance with the policy
• evidence of receipts, attendance records or reasonable documented explanations where exceptional circumstances have been applied or agreed are attached to the payment form

9.1 How will fees and expenses be paid?

If you are involved in an HRA work activity or attend an event as a one off or regularly, we make payment to you via BACS (which is a system in the UK for making payments directly from one bank account to another and stands for Bankers’ Automated Clearing Services). To be set up on BACS, please complete a BACS form available from your HRA contact.

If you receive payment for fees and expenses by BACS, you will receive a remittance advice by email or post from NHS Shared Business Services (SBS).

Payment is made by BACS on behalf of the HRA by our outsourced payment provider, NHS SBS. The HRA processes a weekly BACS payment three times a week. Correctly completed forms can be expected to be paid within 30 days. On the rare occasion that things go wrong with the payment, please contact your HRA contact who will be able to follow this up for you.

9.2 Changing your bank or address

If you have changed banks, moved address since the last time you received a BACS payment for involvement undertaken with the HRA, or haven’t received a payment for over 12 months, then you will need to complete a new BACS form, so that the finance system can be updated. This will prevent any delays in making payment to you.

If you are unsure, then it is recommended that you complete a BACS form, which can be checked against the details on the finance system. All forms are destroyed after the information has been set up in the finance system.

9.3 Payments to an organisation

Arrangements cannot be made for fees to be paid to an organisation, rather than to you directly, for involvement work you do for the HRA.

Any event or circumstances not covered within the policy should be discussed first with your HRA contact, prior to you committing / agreeing any arrangements.

The HRA cannot guarantee that any expenses outside of this policy will be paid without prior approval. Any request under exceptional circumstances will need to be agreed with the Director of Finance.

Enquires associated with reimbursements or fees should be addressed in the first instance to your HRA contact.

This policy should be reviewed every three years or when a change in policy or legislation requires it (whichever is earlier).

12.1 Screening Questions - HRA Equality Analysis and Data Protection Impact Assessment

An Equality Impact Assessment is an examination of a proposed function, strategy, procedure, practice, project, or decision to see if it could adversely affect those with protected characteristics.

Policy aims and outcomes

Give a brief summary of the aims, purpose and outcomes of the policy / procedure. Please include:

· What is this policy intending to achieve?

· How does it intend to achieve this?

· Who is it intended to benefit, and how?

· Are there any disbenefits for staff, volunteers, stakeholders, the public?

The policy covers how we will pay fees and expenses to the people we involve in our work (sometimes known as public contributors). It is based on guidance from the Department of Health and Social Care and a review of good practice amongst other national research organisations. It is for use by HRA staff who involve the public in their work and the people we involve.

The policy intends to ensure the efficient and proportionate payment of payment fees for involvement (‘honorarium’ payments), which are a form of reward and recognition offered of the contribution public contributors make to the work of the HRA. The policy also intends to ensure the efficient reimbursement of involvement expenses and to ensure that these are incurred economically and sustainability in support of the HRA’s strategic and operational objectives.

The policy offers specific advice for people receiving welfare benefits, which could be impacted by payment fees for involvement. The policy supports fair and accessible treatment including the provision of reasonable adjustments where appropriate. It intends to achieve this by making provisions for public contributors to claim reimbursement of their reasonable travel, subsistence and other costs associated with their role. It also makes provisions for the costs of carers, personal assistants or support workers to accompany public contributors, if needed, and provisions of a carer’s allowance.

The policy intends to benefit all public members who get involved in our work.

There is potential for disbenefits for people receiving welfare benefits, who receive payment fees for involvement. Different benefits have different rules and set limits on what can be paid before benefits are affected. Given this we signpost to relevant organisations that can give advice to individuals that would potentially be impacted.

If you have answered YES to any of the questions in 1. above, please explain the impact you have identified.

By offering fees in recognition of people's time, the policy aims to make it possible for anyone to get involved, not only people who can afford to work for free. This reduces disadvantage for people on a low income, or contractors working in the gig economy.

The policy aims to eliminate disproportionate disadvantage for public contributors with protected characteristic who may need to occur additional expenses in relation to their role. For example an individual with a disability who requires a taxi to attend a training event or whether overnight accommodation is required. Throughout the policy reference is made to reasonable adjustments to help promote equality of opportunity for public contributors.

Public involvement brings diverse insights to our work. Making this affordable for everyone means we are more likely to create opportunities to learn from and about each other (fostering good relations).

If you have answered YES to any of the questions in 2. above, please explain the impact you have identified.

If you have answered yes to any of the protected characteristics above in question 3. please give further information about the potential positive impact:

Offering fees is a step towards making it easier for anyone to get involved and shape the HRA’s work. In time, this can contribute to the HRA’s ambition that health and social care research should be done with and for everyone.

If you have answered yes to any of the protected characteristics above in question 4. please give further information about the potential adverse impact:

Public contributors are asked to fill out an excel spreadsheet in order to claim fees and expenses.

This could have an adverse impact on certain individuals who have one or more of the protected equality characteristics (ie a visually-impaired individual).

There is potential that the policy may have an adverse impact on people receiving welfare benefits.

Different benefits have different rules and set limits on what can be paid before benefits are affected, and involvement payments can impact this.

Payment terms for fees and expenses are 30 days. This timeframe could have an impact on people on low incomes, people from groups less likely to trust public sector organisations.

To claim childcare costs, people need to provide invoice or other evidence of spend which impacts on people likely to use informal childcare - friends and family.

Young people may be less likely to have their own bank account and so it may be more difficult to receive payment or expenses.

5. Based on the responses above, please describe any actions that will be or have been taken to mitigate or minimise any negative impact for our workforce (including volunteers), stakeholders or the public, and to consolidate, communicate or build on any positive impact?

To help mitigate the potential impact of involvement fees on welfare benefits, we signpost within the policy to relevant organisations that can give independent advice to individuals that would potentially be impacted.

6. Where appropriate give details of any consultation carried out related to the policy or procedure

Consultation with Finance department, to align to staff/members expense policy where relevant.

Follows the 'Payment for public in involvement in health and care research: a guide for organisations on employment status and tax' which was co-authored by staff here at the HRA alongside, the National Institute for Health and Care Research, Health and Care Research Wales and a public contributor from Wales.

Some changes to wording and examples given, to make the process and provisions (such as reasonable adjustments) as clear as possible.

If you have answered YES to any of the questions in 2 and 4 above and the answers to question 5, 6 and 7 do not mitigate and adequately address the adverse impact, you may need to complete a full Equality Impact Assessment. Please consult the HRA Equality, Diversity and Inclusion Manager for further advice. If further analysis is required, the Document Owner must be informed.