HB on two units in shared specified accommodation and TA!

I have a case where we have a vulnerable singe parent and baby who has been placed in specified managed accommodation as an “emergency” case and they have given her two separate units - one for her and one for her newborn baby. Her license agreement shows the charge broken down as “room 1” and “room 2” so essentially she is being charged double.
The property is ususally rented out per room so has communal charges however, in this situation as she has exclusive use of the property the communal charges would be ineligible as there are no shared areas.
There are also Intensive Housing Management charges on one of the rooms which would be occupied by her baby, plus night security etc etc.
We are dealing with the case under specified accommodation regs as it was another LA that would have referred her (she is u25 so would have gone through their P2i scheme - patherways to independence).
As she is essentially being charged double we have no option but to refer the rent to the RO as excessive. As a LA we do have units suitable for familes in our area that offer CSS that are charging half the price. It’s also arguable that from a housing point of view, with a baby of that young age she would have been placed in one room accommodation.
I am thinking we would be better off paying for HB on two homes “room1” and “room 2” Reg 7(6)(c) if we can demonstrate she has been placed there by a LA - if they referred her through their pathways scheme I am wondering if this would count?

Is the landlord a registered social housing provider?

Yes so spare room subsidy applies she is not over accommodated for HB purposes but the rent is really excessive and I am not sure we could justify paying it without a RoR even if we strip out communal services (no communal areas) and housing management services which would not be provided for the baby, just for her.

It seems like an academic distinction to me: either you take the view that the two rooms are being occupied as a single dwelling and award HB on the aggregate; or you say they are two dwellings and treat the claimant as occupying both ... and still award HB on the aggregate.

I’m struggling to see why you would regard the rent as unreasonable one way but not the other.  The threshold for referring to the RO is that you consider the rent payable *for the dwelling* to be unreasonably high.  I don’t think this requires a comparison with suitable alternative accommodation elsewhere - this is about whether this dwelling is unreasonably priced in itself.  It seems to me that the answer ought to be the same whether it’s 2 x 1 rent or 1 x 2 rents.  If you would have been perfectly happy with the aggregate under Reg 7(6)(c), I would have thought you’d be happy with the aggregate treating them as one dwelling. 

Does that convince you?

Yeah I think we will need to just strip out the charges for things like housing support for the newborn and pay on the rest of i.