The benefits system and Supported Housing
Supported Housing: National Statement of Expectations
Published in October 2020 by the DWP and MHCLG for England
The Department for Work and Pensions and the Ministry of Housing, Communities and Local Government have been working with supported housing stakeholders to produce this National Statement of Expectations. This signals a significant and increased role for supported housing in England. The purpose of this document is to set out principles underpinning good supported housing and to examine what good supported housing looks like.
The National Statement of Expectations is concerned with housing and housing related services rather than the support associated with supported housing although when considering what constitutes good quality supported housing then, of course, the support provided must be looked at too. It has been developed for England in recognition of the fact that supported housing is not subject to regulation there as it is in other parts of the UK such as in Scotland; also there has been a growing amount of non-commissioned supported housing developed in England (ie developed without being commissioned or planned for by the local authority or another public body) and the guidance considers ways to incorporate that sort of provision into local planning and scrutiny arrangements to improve provision.
Planning new supported housing services
Much of the document is concerned with the planning of services and the collaboration required between statutory partners (health services, LA commissioners and HB teams), landlords and support providers. This collaboration is crucial if all parties are to share an understanding about local need for supported housing; how best to provide for it and at what cost.
Local Authority record keeping
Local authorities in England are urged to keep a database of supported housing in their areas – both commissioned and non-commissioned – which they should share with agencies that may wish to make referrals. These lists should include information about supported housing that meets the criteria for specified accommodation under housing benefit regulations. Housing Benefits teams are also urged to keep a record of rent and service charges levels along with details about the sort of service provided and to use this information to benchmark with similar services in other areas. This would assist to determine the reasonableness of rent and service charge levels for HB purposes.
Supported housing providers are urged to take part in benchmarking exercises
The guidance encourages providers of supported housing to take part in sector led accreditation schemes and benchmarking exercises to help drive improvement and value for money. In particular, the Statement of Expectations highlights the Supported Housing Scorecard which has been developed by the sector to assist landlords to undertake benchmarking. The SHS is an extension of the Sector Scorecard used by housing associations in England and involves a series of indicators that enable the benchmarking of costs, quality and performance. Use of the SHS will be piloted from September 2020. Details can be found here.
Revenue and Benefit Teams scrutiny of supported housing
The Guidance sets out the sorts of methods that HB Teams should use to determine the reasonableness and eligibility of rent and service charges associated with supported housing. In a detailed case study about Sunderland Council’s approach to assessing HB claims, a series of ‘tools’ or methods for scrutinising rents and service charges in supported housing are highlighted. These include visiting services; asking for evidence of costs and calculations of charges; information about build costs; sharing information about costs with other local authorities, especially for housing management and staffing costs; check if rent standard has been used; examine intensive housing management costs; speak to service users to discuss the support they use and whether it is appropriate for their needs; ask for proof of funding for the support element of the service and examine staff structures and staff roles.
The UK Government has announced £3M funding for 5 pilot projects in England which will set out to improve quality, oversight, enforcement and value for money of supported housing with a particular focus on non-commissioned supported housing and short term supported housing. These projects are due to conclude by March 2021.
How the guidance might impact on Scotland
Whilst the guidance is aimed at England the fact that it considers the way Revenue and Benefits Teams deal with supported housing HB claims and new supported housing services could impact on Scotland because HB is not a devolved function. The guidance encourages a variety of methods for scrutinising rent and service charges by Revenue and Benefits Teams with a particular focus on benchmarking quality and costs across areas. This could result in landlords being required to provide additional information about cost calculations and the quality of the accommodation. Any re-setting of what are considered to be reasonable costs for supported housing could result in reduced financial support for those living in supported housing; increased pressure on Discretionary Housing Payments and ultimately less funding for the housing element of supported housing in Scotland.
The benefits system and supported housing – September 2018
The UK Government has announced that it will not be taking ‘short term’ support housing out of the benefits system and funding it through a devolved grant based system. Neither will it go ahead with the introduction of a regulated rent for sheltered housing and extra care housing in England.
This change of heart is very much testament to the sustained pressure that the housing and support sector have put on Westminster to re-think its plans and ends years of uncertainty for supported housing.
In their report Funding for Supported Housing – Government Response to Two Consultations, the Department for Work and Pensions (DWP) and the Ministry for Housing, Communities and Local Government (MHCLG) acknowledged the complexity of what they were planning and the concerns expressed by respondents to the two consultations they carried out earlier this year.
This change of heart appears to means that housing benefits will remain in place for those living in supported accommodation (ie specified accommodation) although we do not know how long for. The definition of specified accommodation looks set to remain unchanged eg homeless hostels run by local authorities that do not entail shared living space; purpose built supported or sheltered housing with little or no support. The DWP and MHCLG indicate that they are looking to make some changes in England: the report states that they will further scrutinise the relationship between support and eligible housing costs as well as the role of housing related support. The stated aim of this is to create a system in England that provides a ‘sound and robust oversight regime’ in England – something which the DWP and MHCLG is aware is in place in Scotland.
Whilst the announcement goes a long way to meeting the wish list that the Scottish Government presented to the DWP in July (to which the Unit and various other organisations signed up to) there are some areas that remain a concern:
- Refuge accommodation – women with no recourse to public funds will not be assisted by this change of heart and will continue to be unable to gain financial assistance with refuge costs.
- No requirement for LAs to create and maintain local registers of Specified Accommodation which would have provided transparency and assistance in identifying Universal Credit claims from this sort of accommodation.
- No guarantee about how long the HB system will remain in place – although it seems reasonable to infer that HB is set to stay beyond UC roll out.
- Specified Accommodation criteria is problematic for sheltered housing and for retirement housing even though these services may entail higher housing costs
- Working people in hostels and /or homeless supported housing face difficulties in affording the rent & service charge
If you would like to discuss the implications for your organisation or share your views on this area of policy, please contact Yvette Burgess at firstname.lastname@example.org