Exempt Accommodation in Birmingham

Accommodation funded under the current ‘exempt’ provisions of Housing Benefit and Universal Credit regulations.

“Accommodation which is…provided by a nonmetropolitan country council, a housing association, a registered charity or a voluntary organisation where that body or a person acting on its behalf also provides the claimant with care, support or supervision”. 

It is non-commissioned and often operated, directly or by proxy, through Private Registered Providers of social housing. 

It is outside the purview of both local authority licensing controls and commissioning accountability and monitoring procedures.It is 'direct access',transitional in nature, and occupied by a wide cross-section of vulnerable citizens; many with multiple or complex care and support needs.

Birmingham is a ‘national hotspot’ for this type of accommodation. It is ‘home’ to an estimated 10,000 vulnerable people in the City who have few, if any, accommodation options. For residents living there it can be risky and provides little real choice. Single room accommodation in Birmingham that is ‘exempted’ can command rents of £250 a week compared to the LHA single room rate of  £57.34.

 

Action Research aims to understand and improve the exempt accommodation sector in Birmingham. We will:

• Build a network of referral agencies and other actors with an interest in the sector
• Investigate and understand policy and practice concerns and priorities
• Develop and implement recommendations to Reduce Risk and Enable Choice
• Give voice to residents to inform actions to improve the sector
• Enable peer improvement by landlords and Private Registered Providers

This research is highly policy focused and since work commenced the policy environment has moved rapidly with:

• Homelessness Reduction Act 2017
• Proposed Funding changes to supported housing from 2020 (Government decided not to proceed with these in August 2018)
• Proposed development of a robust oversight regime for supported housing (from August 2018)

Following a presentation of the Housing and Communities Research Group social lettings agency research findings at the Library of Birmingham in March 2017 a selection of statutory and voluntary agency professionals joined colleagues from the University of Birmingham to form a small working group. This group set about considering some of the challenges and opportunities presented by the prevalence of non-commissioned, supported, private sector accommodation in Birmingham (the so called ‘exempt accommodation sector’). As the presenting issues grew in complexity and scope, funding was sought to enable research and mapping work to be carried out. This ongoing collaborative research and best practice project is the result.  

Thea Raisbeck is an Honorary Research Associate in the Housing and Communities Research Group at the University of Birmingham and an Associate of Spring Housing, where she is based. Thea has worked in the housing and homeless sectors for over twelve years and combines academic and frontline practice with campaigning and advocacy work. She has a Masters Degree in Social Policy from the University of Birmingham. Thea is the Project Lead and a member of the Birmingham Homelessness Partnership Board.

David Mullins is Professor of Housing Policy and leads the Housing and Communities Research Group. In recent years he has researched the growing role played by the private rented sector in Birmingham, particularly in relation to low income households, homelessness prevention and community-led use of empty homes. He supervised Ben Pattison’s PhD on Understanding the Growth of the Private Rented Sector in England, and several student projects with the City Council’s Private Sector Housing Team. He led research for the West Midlands Housing Officers Group on social lettings agencies and is part of the research team led by Sheffield Hallam University working on Scaling up Social Lettings for the Joseph Rowntree Foundation and Nationwide Foundation. He has been working with Thea Raisbeck since Spring 2017 to develop a research agenda to understand and improve the exempt accommodation sector in Birmingham.

Dr Halima Sacranie is a Research and Teaching Fellow at the Housing and Communities Research Group at the University of Birmingham. Halima has worked on a range of research projects including the West Midlands Social Lettings Agency Project (2016-2107) and more recently a joint project with Sheffield Hallam on “Scaling- up social lettings – Scope, Impact and Barriers” (2018). Case studies conducted for both these projects revealed complex issues around the non-commissioned, supported or Exempt Accommodation sector niche in Birmingham. Halima will be working as part of the Thea’s research team for this project.

Jessica Duncan is a second year Political Science and Social Policy BA student at the University of Birmingham. Jessica will be providing support to the project during an internship in May-June 2018 and will go on to focus her third year dissertation on provider motivations and behaviour in the exempt accommodation sector in Birmingham. 

We have engaged with many agencies working with housing and homelessness issues in Birmingham and received wide-ranging support for the project. Two key partners have worked closely with us on the first stages of our journey: Birmingham Safeguarding Adults Board and Spring Housing. We are currently actively seeking further partners so that the work can continue. 

Birmingham Safeguarding Adults Board

Birmingham Safeguarding Adults Board have commissioned the first piece of work for this project. They have a particular interest in, and concern with, the placement of vulnerable adults with care and support needs into non-commissioned, private sector supported accommodation and the ongoing management and support provided to these individuals. 

Spring Housing Association

Spring Housing Association were one of the original project group members, and continue to support and contribute to the project, providing specialist knowledge and understanding of both supported and social housing provision and the homelessness sector in Birmingham. Spring Housing also host the Project Lead, Thea Raisbeck. 

There are now two important policy drivers for action research on exempt accommodation. These policy changes are stimulating interest from statutory authorities, referral agencies and landlords:

1. The Homelessness Reduction Act 2017

This Act was implemented on April 3rd 2018, three weeks before fieldwork for the Phase One project began. This Act is the biggest change to the rights of homeless people for over fifteen years and for the first time bolsters and enhances statutory duties towards those who would previously have been deemed ‘non priority’ or ‘single homeless’ and provided with minimal to no advice and support. The Act introduces a ‘duty to prevent’ homelessness and a ‘duty to relieve’ homelessness and places an emphasis on prevention, joint working and more person-centred or client-focussed casework.

From October 2018, the Act will introduce a ‘duty to refer’, placing a duty on a range of statutory agencies to refer, with consent, those identified as at risk of homelessness within 56 days to the local authority of that individual’s choice. This will significantly increase the already high demand from multiplicity of agencies to secure access to private rented sector accommodation in the city for their clients.

Carrying out the project at an early stage of implementation for such a significant piece of legislation has provided a fascinating and timely dimension to the fieldwork, allowing for the incorporation of a wide range of reactions, considerations and views towards emerging policy and practice change brought about by the Act.  Although it is too early during the Act’s implementation to establish an evidence base of impact, it is likely that reformed ways of working and engagement will impact upon referral processes, local authority engagement with the ‘exempt’ sub-sector, stakeholder responses to ‘single homeless’ client groups and the role of supported, exempt HMOs within an individual’s housing ‘plan’ or ‘pathway

Brill, C. (2017, April 27). Homelessness Reduction Act receives Royal Assent

https://www.gov.uk/government/publications/homelessness-duty-to-refer/a-guide-to-the-duty-to-refer

2.   Consultation Paper and Response on Funding Supported Housing

In August 2018 the Government announces the proposed development of a ‘robust oversight regime’ for supported housing together with a full review of how housing and support currently fit together. The latter is being led by the Ministry of Housing Communities and Local Government following a series of consultations between 2016 and 2018 on the future funding of supported housing.

2016 Consultation

Funding Supported Housing: Policy Statement and Consultation (PDF)

2018 Policy Response

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/732692/Supported_Housing_Funding_Consultation_Response.pdf

Proposed Funding changes to supported housing from 2020

NB: During the fieldwork for Phase One, the proposals outlined below were expected to be implemented by 2020. However, on August 9^th, 2018 the government announced a reversal of their proposals, stating that funding for all supported housing would remain within the existing benefits system.  

The original proposed changes would have had a significant impact on the ‘exempt’ sub-sector in Birmingham. Before August 2018 it had been expected that the funding for all accommodation providing a level of care, support and supervision, and classed as ‘short term’, would be removed from the Housing Benefit system, with the relevant budgets devolved by the Department of Work and Pensions to local authorities to administer based on a much more comprehensive needs assessment than has operated hitherto. This policy change would have had a wide-ranging impact on the ‘exempt’ accommodation sub-sector in Birmingham, bringing what is currently a largely disjointed, hidden and relatively unregulated sector under the purview of the local authority. Such a significant potential policy change meant that the current and proposed research and good practice work around this sub-sector would have direct relevance for the new funding regime expected by April 2020.

The policy reversal in August 2018 does not lessen any of the underlying concerns about the sector but does change the potential mechanisms for reform. Our work to date has allowed for the incorporation of the thoughts, considerations and hopes of a large range of stakeholders. Later stages of the project will build on the stakeholder perspectives currently being analysed (which include resident and landlord perspectives) and will aim to provide a direct voice for residents in monitoring and improvement of support and property management standards and a collaborative vehicle for peer improvement by landlords alongside the anticipated improved arrangements for commissioning and regulation of the sector.

Birmingham currently has one of the highest concentrations in the country of supported accommodation operating outside of local authority commissioning structures. This varied sector is predominantly made up of Houses in Multiple Occupation (HMOs); is 'direct access', transitional in nature, and occupied by a wide cross-section of vulnerable citizens; many with multiple or complex care and support needs. As this accommodation operates under the current ‘exempt’ provisions of Housing Benefit and Universal Credit regulations, is non-commissioned and often operated, directly or by proxy, through Private Registered Providers of social housing, it is taken out of the purview of both local authority licensing controls and commissioning accountability and monitoring procedures.

The resulting weak oversight of this sub-sector, the absence of a central, monitored referral point and the corresponding paucity of consistent, user-focused, safety-led and rights-based standards and practices has meant that a significant number of homeless and vulnerable citizens are placed in inadequate, inappropriate and sometimes risky living situations. Many are subsequently left without opportunity to access appropriate support or to exercise any choice or control over their situation.

Equally, although in many senses a ‘hidden’ sector without the cohesiveness and collaboration often witnessed in commissioned and more formalised sectors, there is still some evidence of good practice, professionalism and innovation within supported, ‘exempt’ HMO accommodation. By collating, building on and sharing this evidence the project seeks to build a collaborative platform for improvement.

The prevalence of supported ‘exempt’ accommodation in Birmingham, and the numerous challenges and considerations it presents, have ensured that this issue is high on the agenda for both statutory and voluntary agencies within the City of Birmingham. Similarly, numerous local and national policy drivers, such as the proposed funding changes for ‘short term’ supported housing from April 2020 (now replaced with the proposed development of a ‘robust oversight regime’ for supported housing, led by MHCLG), the implementation of the Homelessness Reduction Act, the West Midlands Mayor’s Homelessness Task Force and Birmingham’s new Homelessness Prevention Strategy have rendered this is an opportune time to investigate a largely hidden and vastly under-researched sub-sector. 

With Birmingham Adult Safeguarding Board (BASAB)

The large number of vulnerable adults living in supported HMOs, alongside the prevalence of inadequate, reactive accommodation placements and the ensuing likelihood of inappropriate or ‘risky’ mixes of residents has placed this issue high within Birmingham Safeguarding Adults Board’s strategic aims. A history of joint-working and a shared concern around supported HMOs led Birmingham Safeguarding Adults Board to commission the first project workstream Risk, Safety and Wellbeing in Shared ‘Exempt’ Accommodation in Birmingham, England.

This preliminary, exploratory project has provided a baseline for ongoing research, policy and practice work around supported, ‘exempt’, shared accommodation in Birmingham and the wider West Midlands. Taking the multiple, untracked and inconsistent referral ‘pathways’ as its point of departure, the project involved homelessness and welfare service practitioners, residents, expert stakeholders and landlords in a collaborative process of meaningful discussion and reflection.  

The main aims of Phase 1 were to:

• Map and analyse existing referral routes into ‘exempt’ HMOs in Birmingham
• Place non-commissioned exempt accommodation within wider homelessness systems and pathways
• Review, and invite practitioners and accommodation providers to reflect upon, current referral processes and procedures
• Review agency awareness and utilisation of safeguarding protocols
• Investigate and understand the policy and practice concerns and priorities of a wide range of sector stakeholders
• Investigate and understand the experiences of residents living in supported HMO accommodation
• Investigate and understand sector stakeholder responses to emerging policy change and reflect on how this may impact upon referral processes, future provision, and the housing and support needs of homeless and vulnerable citizens
• Invite stakeholders and residents to identify gaps in practice and provision and make suggestions for improvement
• Collate good practice examples of referrals into, and management of, exempt HMOs
• Identify areas for collaboration, partnership working and cross-sector engagement
• Make recommendations for both policy and practice change, and for further research and investigation into supported and HMO accommodation in Birmingham

The project commenced with a local and national literature and policy review of supported housing, HMOs and shared living contexts and ‘exempt’ accommodation. Fieldwork, completed between March 2018 and May 2018, involved semi-structured, qualitative interviews and group discussions with 94 individuals including:

• Referring practitioners and support agencies
• Current residents of exempt HMOs and shared housing, and those with recent lived experience
• Accommodation providers
• Expert stakeholders

Project Outputs

Presentation: The ‘Exempt Accommodation’ Sector in Birmingham - what is it, who lives there and how can they be engaged in its improvement? November 2017

Report: Reducing Risk and Enabling Choice in Supported Exempt Accommodation 

Report for Birmingham Adult Safeguarding Board (BSAB). November 2018 

Phase One Report:  Risk, Safety and Wellbeing in Shared ‘Exempt’ Accommodation in Birmingham, England

Phase One Report Summary: Risk, Safety and Wellbeing in Shared ‘Exempt’ Accommodation in Birmingham, England. External Research Report Summary 

An internal summary report  for BSAB (unpublished). 

The research findings were presented to Birmingham Safeguarding Adults Board on 25^th September 2018. This meeting was also attended by selected key stakeholders from Commissioning, Adult Social Care, Probation and Community Rehabilitation Companies, Private Rented Sector Enforcement, West Midlands Police, Housing Benefit and The Housing Birmingham Partnership.

Research findings were disseminated to Safeguarding professionals and selected local authority internal stakeholders at an event on September 25^th, 2018. The response was incredibly positive, reflecting a real appetite and commitment for action, collaboration and change.

Further dissemination events will be planned for Autumn 2018 and we will be updating the site with details of how the report recommendations are being taken up and on commitments to take action declared by key stakeholders. 

HCRG Seminar November 20^th 2018

Importing Need?: West Midlands agency referrals into the non-commissioned supported accommodation sub-sector in Birmingham

Commonwealth Housing

The Housing and Communities Research Group, in partnership with Spring Housing, have recently secured funding from Commonweal Housing, a national charity which promotes housing solution to social injustice, to carry out a Pre-pilot evaluation of Exempt Accommodation for vulnerable households in Birmingham. Using the Commonweal strategic approach to learning, this Pre-Pilot evaluation project will develop structured work to clarify the social injustices and contributory factors associated with the current use of exempt accommodation in Birmingham, develop hypotheses and principles to design and cost pilots. We will explore the feasibility and cost of these property-based pilots and propose system level solutions. Our project outputs will make evidence-based proposals for appropriate system and practice reforms based on a good understanding of practical constraints and opportunities. It I hoped that these working principles will provide long term solutions that can be replicated elsewhere. 

We are currently actively seeking further partners for future phases of work to build in the baseline mapping and recommendations within Risk, Safety and Wellbeing in Shared ‘Exempt’ Accommodation in Birmingham, England

Subject to interest and advice we hope to develop further workstreams to:

• Undertake a peer research training project to give voice to residents of exempt accommodation and feed their experience and knowledge into any reforms of the commissioning and the regulatory environment

• Develop a peer improvement project for landlords and Private Registered Providers involved in exempt accommodation provision to share learning on management and support services and enable compliance with reformed commissioning and regulation

• Undertake mapping of the structure of the exempt sector in Birmingham , the relationships between registered providers and landlords, location, services and costs 

Links with University Teaching Programmes

The Project’s location within the Housing and Communities Research Group has provided an excellent opportunity to connect with teaching and provide students with ‘live’ action research opportunities in the city.

In her role as an Honorary Research Associate, Thea Raisbeck delivered a lecture for Year 2 University of Birmingham undergraduates taking the Housing and Communities module in Spring 2018. This two-hour session covered issues around ‘exempt’ accommodation in Birmingham and the policy and practice background to the growth of shared housing in the private rented sector for low income, homeless and vulnerable groups. Thea will deliver this lecture again during the Autumn 2018 term, updated with findings from the completed research project, Risk, Safety and Wellbeing in Shared ‘Exempt’ Accommodation in Birmingham, England.

As the project develops there will be further scope to feed in research-based teaching into a wide range of Social Policy, Criminology and Sociology Programmes given the insight the project can provide on issues such as Social Harm, Resettlement of Offenders, transitions to adulthood, inter-organisational collaboration, evidence-based policy, migration and housing, peer research and action research methods.

In Autumn 2018 the first two Jane Slowey Memorial Bursaries for third year undergraduate dissertation projects, supported by Commonweal were awarded. One of these enables Political Science and Social Policy BA  Joint Honours student Jessica Duncan to undertake her dissertation on provider motivations and behaviour in the exempt accommodation sector in Birmingham.  This follows her internship with the research project in May-June 2018.