Supported Housing Consultation

Response from Stratford-on-Avon District Council

Agreed by the Leader of the Council – Councillor Chris Saint, 10 February 2017

Contact Renata Mosz

District Housing Enabler

Stratford-on-Avon District Council

Elizabeth House

Church Street

Stratford-upon-Avon

Warwickshire

CV37 6HX

Tel 01789 260842

I confirm that the references to short-term accommodation relate to England.

Q1. The local top-up will be devolved to local authorities. Who should hold the funding; and, in two tier areas, should the upper tier authority hold the funding?

District/borough councils should hold the funding in all two tier areas.

It is essential that the funding and, consequently, the decision making as to how the funding is used, is devolved to district councils. It is likely that district councils will choose to pool funding across local authority boundaries but it is important that district councils have the ability to determine how any funding is spent for the reasons outlined below.

  • County councils have a number of statutory responsibilities to people with high level support and care needs. The removal of the former Supporting People ring fence has demonstrated that county councils inevitably (and understandably) prioritise these people for any available funding.
  • Cuts to other county council services have compounded the problems and made it difficult if not impossible for anyone to access services unless they are assessed as eligible for county services under the “Fair Access to Care” criteria and are classed as having at least “substantial” if not “critical” needs.
  • There is some overlap between the duties of county councils and district councils towards some people. However, district councils are not interested solely in people with high level needs but must also meettheir own statutory duties to prevent and deal with homelessness. The majority of people with housing and support issues approaching district councils require far lower levels of support than the people county councils routinely assist.As county councils hold the purse strings, it is the lower level support services and more housing focused services that are being disproportionately cutin comparison to county council statutory services.
  • Preventing people from becoming homelessand dealing effectively with people that are homeless and have support needs at first point of contact is far more cost effective to the public purse than waiting for problems to escalate to crisis point.
  • Joint working across housing, health and social care is vital. However, the reality is that housing is often perceived as a junior partner in any joint arrangements. For example,of the 154 Health and Well Being boards only 9% include housing. (Inside Housing 16 October 2016).
  • District Councils are responsible for housing benefit payments – at least for older people.

Q2.How should the funding model be designed to maximise the opportunities for local agencies to collaborate , encourage planning and commissioning across service boundaries, and ensure that different local commissioning bodies can have fair access to funding?

Notwithstanding the comments above(see Q1), Better Care Boards may be an effective mechanism for determining how funding should be distributed. However, housing must have seats on the main board.

Following on from this point it would be helpful to separate funding streams (and commissioning arrangements) for people with long term (lifetime) support needs e.g. older people in sheltered or extra careaccommodation, people with severe learning disabilities or mental health issues and people for whom support could be time limited.

It is worth emphasising that no one is going to build e.g. an extra care scheme if there is a risk that support or revenue funding may disappear after three years. Addressing long term needs requires some guarantee of long term support/revenue funding. The alternative is that schemes will close and no new supported schemes will be built – schemes are already on hold.

Short term needs could be addressed via three or five year contracts.

Obviously, the model is not needs led but determined by the housing benefit budget. It would be useful to move funding for long-termschemes out of the housing benefit budget entirely. See also the response to question 8.

Q3. How can we ensure that local allocation of funding by local authorities matches local need for supported housing across all client groups?

The fairest way is to look at demographics (including projections and age) and possibly at deprivation levels as well.

However, the major issue is the postcode lottery that the use of different Local Housing Allowance (LHA) rates plus limited top-up funding will create.

  • Stratford–on-Avon District Council area itself has seven different LHA rates which already makes affordable housing development more viable in some parts of the District than in others.
  • It is unlikely that the top-up funding will be sufficient to iron out thedifferences in LHA rates across England. Most supported housing has fixed costs – build costs (apart from land) management and maintenance costs including staff etc.
  • For example, typical charges for rented affordable extra care outside London vary from £180 to £220 per week. In Sunderland the LHA rate is approximately £70 per week and the question is whether sufficient top-up funding will be made available in the north or will there be no extra care schemes in the north? Will all extra care and high level needs schemes result in people with acute support needs having to move south to where there are higher LHA rates?

Q4. Do you think other funding protections for vulnerable groups, beyond the ring-fence, are needed to provide fair access to funding for all client groups, including those without existing statutory duties (including for example the case for any new statutory duties or any other sort of statutory provision)?

Yes. See response to Q3 above– particularly separate funding streams as regards long term and short term accommodation. Funding should be available for all the client groups listed in the Consultation document (paragraph 14, page 9) and for any other groups deemed to require support locally.

Q5. What expectations should there be for local roles and responsibilities? What planning, commissioning and partnership and monitoring arrangements might be necessary, both nationally and locally?

See responses to questions 2 and 6.

Q6. For local authority respondents, what administrative impact and specific tasks might this new role involve for your local authority?

There should be a designated amount within each top-up grant for administration funding. The proposed model will generate considerable bureaucracy not least because the funding methodology is so complicated and LHA rates differ considerably. There will be a necessity for ongoing dialogue not only to identify local needs properly but also with commissioners and procurement teams, monitoring of outcomes but also with housing benefit teams / DWP Universal Credit teams.

Q7. We welcome your views on what features the new model should include to provide greater oversight and assurance to tax payers that supported housing services are providing value for money, are of good quality and are delivering outcomes for individual tenants?

The new model must publish a framework (probably for England) that defines supported housing and which includes basic standards and conditions. This is essential – not least for housing benefit teams / Universal Credit teams that have little detailed knowledge of supported housing. Such an approach willalso help avoid a post-code lottery.

Publishing acceptable rents and support costs for particular schemes may also be helpful.

Q8. We are interested in your views on how to strike a balance between local flexibility and provider/developer certainty and simplicity. What features should the funding model have to provide greater certainty to providers and in particular, developers of new supply?

See response to questions 2 and 3. Providers need long-term certainty about capital and revenue/support funding. The Government can choose to guarantee long term funding for supported accommodation which saves money in the long term or whether it prefers to fund vastly more expensive crisis care – whether it is housing, health, social care or police etc. This is a political decision at national level.

The inclusion of rent and support in housing benefit /top up funding for supported accommodation is muddying the waters; it would be preferable to introduce a separate supporting housing allowance instead of relying on LHA rates and top up funding. Funding for supported housing must be ring fenced solely for that purpose.

Q9. Should there be a national statement of expectations or national commissioning framework within which local areas tailor their funding? How should this work with existing commissioning arrangements, for example across health and social care, and how would we ensure it was followed?

See responses to questions 1,2 and 7.

Q10.The Government wants a smooth transition to the new funding arrangement on 1 April 2019. What transitional arrangement might be helpful in supporting the transition to the new regime?

The timetable for the Green Paper and subsequent actions is very tight. As existing and new schemes are already being lost, it may make sense to allow time to get the model right. Clarity is required as soon as possible as to the parameters of the scheme and how it will operate. An English Framework with “definitions” must be published by April 2018 at the latest.Certainty is required about how much funding will be available at District level early in 2018 but also in the years that follow. Any funding must be index linked.

Q11. Do you have any other views about how the local top-up model can be designed to ensure it works for tenants, commissioners, providers and developers?

See responses to questions 1,2,3 and 8.

Q12. We welcome your views on how emergency and short term accommodation should be defined and how funding should be provided outside Universal Credit. How should funding be provided to tenants in these situations?

See response to question 8 and the concept of a “supported housing allowance”.

Short-term accommodation should be provided for up to three years. This will allow support to be provided to peoplewho require support for longer than the customary two years e.g. some people who formerly slept rough. Anyone requiring support for more than three years should be classed as in need of long term support – and guaranteed funding.

Emergency accommodation must include temporary accommodation provided in respect of local authority homelessness duties. Experience has shown that Universal Credit cannot adequately cover actual homelessness temporary accommodation rent costs that accrue to local authorities and that it is difficult to recoup any costs. In practice, Universal Credit means that the cost of temporary accommodation is being borne by local authorities. This needs to change.

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