Advance claims for PIP

Hi,
I’m posting to check if I’m on the right track with interpreting the rules for making advanced payments of PIP.

The rules for making advanced payments of DLA seem straightforward – provided you claim no more than three months before you would qualify for DLA a decision can be made in advance of your date of entitlement –

“Where, although a person does not satisfy the requirements for entitlement to disability living allowance on the date on which the claim is made, the Secretary of State is of the opinion that unless there is a change of circumstances he will satisfy those requirements for a period beginning on a day (“the relevant day”) not more than 3 months after the date on which the claim is made, then Secretary of State may award disability living allowance from the relevant day subject to the condition that the person satisfies the requirements for entitlement on the relevant day.”
(Reg 13A Claims and Payment Regs 1987).

The rules for advance awards of PIP are different –

“Where, although a person does not satisfy the requirements for entitlement to personal independence payment on the date on which the claim is made, the Secretary of State is of the opinion that unless there is a change of circumstances the person will satisfy those requirements for a period beginning on a day (“the relevant day”) not more than 3 months after the date on which the decision on the claim is made, the Secretary of State may award personal independence payment from the relevant day subject to the condition that the person satisfies the requirements for entitlement on the relevant day.”
(Reg 33(1) The UC, PIP, JSA and ESA (Claims and Payments) Regulations 2013)

My take on this is that it’s possible for an advanced PIP award to be made at the latest three months after a decision maker makes a decision on the claim.

But does Reg 33(1) not also mean that an advanced award after the actual date of claim can be made also at any time before the date of decision on the cliaim?

For example, someone’s condition clearly deteriorates 4 months after their date of claim.
Can a decision maker under Reg 33(1) make an award of PIP starting 7 months after the date of claim?

Given that PIP decisions are taking up to 12 months at present, would Reg 33(1) form the basis of an ‘in the alternative’ submission at mandatory reconsideration/appeal i.e. that if a client does not meet the qualifying criteria at the date of their claim that they did so at some point up to and including the date of decision on their claim.

What do other people think?