RESPONSE FROM THE HOUSING SUPPORT ENABLING UNIT
13th February 2017
- The Housing Support Enabling Unit (the Unit)
The Housing Support Enabling Unit assists providers of housing support and supported housing across Scotland in the voluntary and independent sectors. The Unit was set up in 2004 just 9 months after the Supporting People Programme was launched and the separation of housing support costs from housing costs had taken place. The Unit is jointly hosted by the Coalition of Care and Support Providers in Scotland and the Scottish Federation of Housing Associations.
The Unit has worked with organisations as service regulation came into force; workforce regulation was developed; policy on personalisation and self-directed supportwas developed and local authorities developed commissioning and procurement practices (eg the model SP contract). Since 2011 the Unit has contributed to various consultations that have been undertaken about the future shape of the benefits system with regard to supported housing.
The Unit has discussed the planned changes to the benefits system with providers across Scotland and various concerns have been expressed about the proposal to apply the Local Housing Allowance to supported housing. Whilst the commitment to maintain funding levels in 2019/20 through a new top up fund is to be welcomed, there are nevertheless risks involved in creating a new system which involves a move away from individual entitlement to benefit. This poses a risk for both services and for individual tenants as there is currently no guarantee about how the new top up funding will be developed or allocated. We do, however, welcome the opportunity to set out these concerns and address some of the issues set out in the consultation document.
- Summary of key points
- We question the merit of creating a new funding system when greater rigour could be introduced to the existing system. Whilst there is not always a dedicated support service associated with supported housing, in many cases there is and greater use could be made by the benefits system of available information about the quality and outcomes of supported housing.
- The timescale for designing a new benefits system to deal with supported housing should be extended beyond the current timescale.
- Extending the current timescale would allow a pilot to be carried out to ensure that any unintended consequences are ironed out before full roll out.
- Consideration could be given to maintaining the HB system beyond 2019/20 so that supported housing tenants of working age could continue to be dealt with outside of the Universal Credit system.
- Any new top up fund for Scotland should be based on actual benefit spend above the one bedroom rate plus anticipated costs associated with new supported housing in development as well as private sector supported housing.
- The creation of the new top up fund should be carried out in a transparent way so that providers can see a link between costs relating to their services and to the new fund – this would increase security for providers and for tenants and would promote a smooth transition to the new system
- Short term supported accommodation should be dealt with by the Universal Credit system on a daily rather than monthly basis.
- Short term supported accommodation should not be defined in terms of average length of stay because that average may change from time to time and the provider may have little control over that variation.
- Responses to questions
i)Fair access to funding
Whilst the arrangements for administering any new top up fund will be the Scottish Government’s responsibility, the size of the fund devolved to Scotland will be fundamental in terms of enabling fair access to it. We note the intention to extend the sort of supported housing which can be considered for assistance beyond the categories of supported housing currently falling within Specified Accommodation. This would create more of a level playing field between landlord sectors but could put additional pressure on the top up fund depending on how well the additional demand has been factored into the overall calculation used to establish the fund. The information presented in the Ipsos MORI report recently, though providing a useful overview of supported housing, does not go into the level of detail required for sizing the new top up fund; not least because the shortfall between the 1 bedroom LHA cap and actual rent/eligible service charge level was not an issue which Ipsos MORI was tasked with exploring.
A thorough examination of actual benefit spend above the one bedroom LHA rate for supported housing plus an examination of the additional costs associated with supported housing in development and private sector supported housing is required if the top up fund to be devolved to Scotland is to be adequate.
We note the intention to build capacity in supported housing and urge that the top up fund be reviewed at each Spending Review so as to be able to reflect growing need and demand for this sort of housing option.
ii)Local roles and responsibilities
In Scotland the Scottish Government will decide how to allocate the new top up fund and we will discuss this with them in the coming months. It is of interest that the consultation document refers to ‘new burdens funding’ for local authorities if they are to manage and allocate the funding in England. If such funding is to be made available across Great Britain consideration could be given to maintaining Housing Benefit teams at least up to 2022 in order to continue to deal with supported accommodation outside the Universal Credit system for those of working age.
iii)Value for money and quality outcomes focused services
Whilst we understand that Ministers have had concerns about the quality and outcomes of supported accommodation in the past we would like to highlight that support services are regulated in Scotland through the Care Inspectorate which providesaccessible information about the quality of support being provided. In addition, the Scottish Government has funded the Unit to develop an outcomes system specifically for housing support and supported housing services. This outcomes system, Better Futures, has now been in operation for 5 years and is growing in use. It provides an ideal means for local authorities and providers to share information about the way people plan and achieve personalised outcomes and move through services. We question the merit of creating a new funding system when greater rigour could be introduced to the existing system. Whilst there is not always a dedicated support service associated with supported housing, in many cases there is and greater use could be made of available information about quality and outcomes.
iv)Balancing local flexibility and provider certainty
The current benefits system already provides a good balance between local flexibility and provider certainty and, most importantly, the certainty that individual tenants have about their individual entitlement to assistance with housing costs when they are living in supported housing. Local commissioners can review services and decide to change or move funding for support. This in turn can change the nature of the housing provided and in this respect the system already accommodates flexibility. The introduction of the LHA cap could erode the current sense of security for individuals and for providers in many supported housing settings and we are seeing signs of this erosion already.
We have already referred to the way the top up funding for Scotland will be established. One furtherissue is the relationship between current services and the new top up fund. To maintain security of funding beyond 2019 providers of supported housing need to see a link between their service and an element of funding in the top up fund. A transparent exercise to calculate the overall funding pot to be devolved to the Scottish Government would assist individuals and providers of supported housing envisage a future for supported housing.
v)Short term supported housing
The reason why short term supported accommodation is particularly at risk is the roll out of the Universal Credit system rather than simply the introduction of the LHA cap. Under UC the cost of short stays in supported accommodation will be difficult to recover because of the lengthy assessment period and lack of entitlement to assistance with a few days / weeks rent.
One option would be for the UC system to be adapted to cover shorter rental periods for those services. The calculation of housing costs for short term supported housing needs to be based on a daily rather than monthly assessment. We concur with the Scottish Federation of Housing Associationsthat payment of personal allowances should also be calculated on a daily basis to avoid severe hardship.
Once set up with the necessary identifiers the UC system could deal with claims from short term supported housing addresses appropriately with no need to establish a new system for that type ofsupported accommodation.
If this approach were taken the LHA cap would still present challenges for short term supported accommodation as shortfalls would still arise but this could be dealt with through the overall ‘top up fund’ available to supported housing more generally rather than through a separate system. One way of making this approach more appealing to service providers would be to adopt a new higher supported housing LHA rate with the potential to cover the costs of some supported housing services through the benefits system without reliance on a ‘top up fund’. This approach would have the merits of maintaining individual entitlement to a greater extent.
Another option and one which is favoured by some short term supported housing providers who do not think that the UC system could be adapted sufficiently to offer them the security they need, is to take the housing related costs out of the benefits system and fund through a national programme. This option could provide a simpler funding solution for providers but does present a financial riskfor them as there would be no individual entitlement to any level of support with housing related costs. The Unit is contributing to the work of the Short Term Task and Finish Group as it explores this and other options in greater detail.
If short term supported accommodation is to be treated differently from other sorts of supported housing there needs to be a new definition to help identify it. There is a concern amongst providers that a new definition of short term supported accommodation will be based on average length of stay. This could create difficulties for services and their tenants when average stays vary from time to time. Such variation may be due to factors beyond the control of the supported housing provider such as availability of move on accommodation. Instead, we suggest that services are identified on the basis of their aimto provide short term supported housing with a focus on moving on and that a register of addresses is maintained by all local authorities to assist those making decisions about benefit claims.
We share a concern with other commentators that people living in short term supported accommodation currently face difficulties in maintaining or securing employment because of the cost of services and the current housing benefit taper. We suggest that the benefit taper be reviewed to help ensure that people living in short term supported accommodation can continue to receive assistance with their rent/eligible service charges through the benefits system and the top up fund.
Yvette Burgess
Unit Director, Housing Support Enabling Unit
Tel 0131 475 2676
1