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This think piece reflects on a major change of direction in a specific social policy related to the  funding of supported accommodation procured from the private rented sector. It does so from the perspective of an ongoing research and improvement project led by Thea Raisbeck in the Housing and Communities Research Group targeted on some of the least safe housing occupied by some of the most vulnerable households in Birmingham

In August 2018 plans to devolve funding and standard setting for this sector to local authorities were abandoned. In their place is a commitment by DWP and MHCLG to develop a robust oversight regime and to better understand how housing and support fit together in relation to short term non-commissioned supported housing.

This think piece argues that while the failure to devolve funding and standard setting could be regarded as a major opportunity missed; there is still scope within proposals for an oversight regime to develop new leverage for reform. What is most important is to keep the interests and experiences of the residents at the heart and to build on the widespread concerns about the status quo that have been identified in the research.

So, Thea’s research and improvement project aims to promote user voice and safety, make greater links between the cost and level of support; remove disincentives to enter employment; set expectations around quality standards, and aligns approval of providers and new units to strategic assessment of local need and demand. This month sees the publication and dissemination of a major report on the first stage of the research which has been supported by the Birmingham Adult Safeguarding Board. More reports will be published as the project develops.

David Mullins, Emeritus Professor of Housing Policy, November 2018

On August 9th, 2018 the Ministry of Housing, Communities and Local Government released a response to their latest consultation on the future funding of supported housing. At the start of the consultation had posited that, from 2020, funding for all accommodation currently qualifying as ‘exempt’ for Housing Benefit purposes and classed as ‘short term,’ or of two years’ maximum duration, would be removed from the welfare benefits system and devolved to local authorities to administer at their own discretion, based on a strategic consideration of need and supply.

In the seven years preceding this announcement, successive government reviews had acknowledged that the current system for funding the housing-related costs of supported housing, introduced into Regulations in 1996, is problematic; lacking transparency, performance, safety and outcome monitoring protocols, and providing no link between cost and quality. This had left local authorities with few tools beyond the qualifying threshold of an organisation providing ‘more than minimal’ care support or supervision to a claimant, and with no requirement for further monitoring or assessment beyond the initial point of claim. In the same period of time, Birmingham had seen the supported ‘exempt’ accommodation sub-sector grow exponentially. By 2018  an estimated 10,000 units of non-commissioned accommodation were utilising this funding mechanism and housing some of our most vulnerable and disadvantaged citizens.

The much-anticipated government response on August 9th was an effective abandonment of the ‘short term’ devolved funding policy, announcing as it did that the government would ‘maintain Housing Benefit for all supported housing, reflecting the needs of the vulnerable people who rely on it and the need for continued supply across the sector(MHCLG, 2018; 24).The statement went on to say that “we recognise the level of commitment and high standards demonstrated by most providers in this sector, but we need to ensure standards across the whole sector. We will continue to work with providers, local authorities, membership bodies and resident representatives over the coming months to put together a sound and robust oversight regime…we have also heard concerns from the sector about how support is funded, and the relationship between support and eligible service charges. We are keen to have a full and clear picture of the important role of housing related support and will therefore undertake a review of that element in order to better understand how housing and support currently fit together (ibid; 24).

It felt as if the wider sector simultaneously expelled the breath they had been holding for almost three years; palpably relieved that a policy seemingly universally derided as ‘disastrous’ and ‘short-sighted’, had been reversed. The proposals, of course, were far from perfect; with some of the implications deeply problematic, perhaps rendering the eventual outcome in some ways inevitable. Local control over funding for what is essentially a life-saving, national network of domestic abuse refuges and the resultant halting of an estimated 85% of new supported housing supply were perhaps the most salient, and ‘lobbyable’, issues in a seemingly growing list of unintended consequences.

Nonetheless, beyond the flurry of post-announcement comment pieces and the ‘return of common sense’ according to various national interest groups, there was a quiet disappointment emanating from a corner of Birmingham’s housing and homelessness sectors. Whilst almost unanimously unpopular with the majority of supported housing providers nationally, the proposals for ‘short term’ funding were, for those grappling with some of the very real consequences of ‘exempt’ Housing Benefit Regulations in Birmingham, viewed as a real opportunity to gain a much-required level of control, oversight and monitoring over a vast, growing and largely hidden sub-sector.

Phase One of the Exempt Accommodation Partnership Project, funded by Birmingham Safeguarding Adults Board, was designed to explore some of the problems resulting from the current benefits-led funding system. The research began – and was almost completed - under the assumption that all funding for ‘short term’ supported housing would be devolved to the local authority by 2020, and that our findings and learning would help to inform and support future devolved local authority commissioning plans and priorities. Devolution could have been the key driver for improvement. However, with the government’s announcement firmly re-establishing the centrality of the DWP funded benefits system within supported housing funding, our thinking and focus must now turn to three short paragraphs contained within the final page of the government’s consultation response which must now provide the key driver for reform.

These paragraphs include

  1. a  pledge to work with ‘providers, local authorities, membership bodies and resident representatives over the coming months to put together a sound and robust oversight regime’;
  2. a commitment to ‘getting it right’ and
  3. the keenness to undertake a review ‘to better understand how housing and support currently fit together’.

There will be, of course, much more work to come behind what is for now little more than an acknowledgement that the current, unregulated, system cannot remain as it is, and that the retrenchment of Supporting People funding has shifted much of those costs back into the benefits system as ‘intensive housing management’.

Whilst we wait to see what form the devil within these details will take, here in Birmingham we must view the consultation response not as an opportunity lost but as a new framework for promoting reform. We must ensure that the specific issues experienced within non-commissioned ‘exempt’ accommodation in Birmingham are highlighted to central government and that the human costs of a problematic funding regime with little recourse, oversight and redress are not able to escalate any further.

Through a process of policy analysis; stakeholder and user involvement; action and peer research, and through the development of best practice modelling of property based solutions, we hope to influence and shape the development of the government’s proposed ‘robust oversight regime’ by

  1.  promoting a system that enhances user voice and centralises resident safety;
  2. enables for greater links between the cost and level of support;
  3. removes disincentives to enter employment;
  4. sets expectations around quality standards, and
  5. ensures the approval of providers and new units is more tightly aligned with strategic considerations of local need and demand. 

Ultimately, this announcement increases the importance of key stakeholders within Birmingham working together to ensure individuals accessing, and living in, the ‘exempt’ sub-sector are as safe and well-supported as possible and do not have their lives or their progress stymied by inadequate or inappropriate support, or by inflated housing costs that often bear little relation to the service they receive.

A national oversight regime perhaps cannot avoid a tendency to focus on the most visible issues; or at least on those evidenced by the most visible organisations within the wider sector. Likewise, we cannot expect a nationally applicable oversight regime to focus too tightly on the particular challenges and risks evidenced within one City, albeit one as large and as subject to population influx as Birmingham. Nonetheless, the evidence we have already gathered for our Phase One report ‘Risk, Safety and Wellbeing in Shared ‘Exempt’ Accommodation’ will help to highlight some of what we have termed the ‘risk gaps’ and ‘accountability deficits’ within the current system, and ensure any oversight regimes prioritises resident safety, introduces choice and redress mechanisms for residents and returns some accountability and control to administering authorities.

At its best, non-commissioned supported accommodation is able to bring creativity, flexibility and innovation into the sector and provide services tailored to individual need. Indeed, this sub-sector currently plays a vital part in Birmingham’s housing and homelessness systems, but we desperately need it to do what it does in a way that no longer places the acquisition of the highest rents possible at the centre of provision. We must ensure, through the promotion of good practice, and by listening closely to what residents and providers need, that we are able to equip all stakeholders with the tools they need to develop a service that works best for those who need it most. 

Thea Raisbeck, Housing and Communities Research Group, November 2018