Introduction

It is heartening to know that, from time to time, the Government listens to the collective voice of those they seek to govern. Following a period of consultation, it seems the Government has done just that and agreed to reverse their earlier decisions regarding the way in which supported housing is funded. The following outlines what we can now expect to happen.

The Consultations

On 31st October 2017, the Ministry for Housing, Communities and Local Government (previously Department for Communities and Local Government) and the Department for Work and Pensions launched two consultations, which closed on 23 January 2018. One consultation related to sheltered and extra care housing and the other to short-term supported housing. The consultation related to England only.

Who responded to these consultations?

Sheltered and extra care housing

A total of 304 responses were received from local authorities, registered social landlords, other housing associations, professional bodies, voluntary organisations, representative groups and individuals.

Short-term supported housing

From those working in this type of supported housing, a total of 434 responses were received from local authorities, registered social landlords and others.

Other responses

In addition to the above, the Government received a total of 72 responses in the form of generalised statements which were not specific to the questions asked during the consultation process.

What questions were considered?

This article will deal solely with the specific questions raised relating to short-term supported housing as this is the type of supported housing that most of our clients provide. However, we are able to provide details of the questions raised for those working in the area of sheltered and extra care housing upon request.

The questions for those working in short-term supported housing

A total of 11 questions were asked for those working in this group of supported housing. Some of the key questions and an outline of the answers provided are set out below:

Question: For the purpose of the funding model we have defined short-term supported housing as: “Accommodation with support, accessed following a point of crisis or as part of a transition to living independently, and provided for a period of up to two years or until transition to suitable long-term stable accommodation is found, whichever occurs first.”

Answers:

158 (45%) agreed with the definition and 147 (42%) did not agree with the definition.

There were a total of 147 responses from Local Authorities (LAs), including Scotland and Wales, and of these 82 (56%) agreed with the definition and 38 (26%) did not.

80 (23%) of 350 respondents felt that the 2 year time period set out in the definition was too short and 48 (14%) felt it was too long.

69 (20%) of those in the overall total responses wanted the definition to include other groups and 31 (9%) wanted it to be separate for other groups.

Many respondents that accepted the definition expressed a preference for the timescale to be reduced to three months.

Respondents also asked that funding remain in the welfare system.

Question: What detailed design features would help to provide the necessary assurance that costs will be met?

Answers:

Of these, there were 178 (53%) requests for grants to respond to rent inflation and rising needs.

118 (35%) requested detailed guidance.

84 (25%) suggested that the grant should be supported by statutory duties and stronger protections.

75 (22%) suggested long-term commissioning contracts ranging from a minimum of 5 to 10 year contracts.

Question: Providers – could you provide local government with a detailed assessment of demand and provision if you were asked to do so?

Answers:

There were a total of 152 responses to this question.

99 (65 %) of respondents said they could provide both.

There were 23 (15%) demand only and 29 (19%) provisions only. Question: How can we help to ensure that local authorities are able to commission both accommodation and associated support costs in a more aligned and strategic way? Do you have further suggestions to ensure this is achieved?

Answers:

There were a total of 156 responses.

115 (74%) respondents said there should be commissioning arrangements.

76 (49%) respondents said that guidance should be in place.

43 (28%) of the respondents indicated that there should be new statutory duties.

45 (29%) thought that this could be achieved through strategic plans and a needs assessment.

Question: How will you prepare for implementation in 2020, and what can the Government do to facilitate this?

Answers:

There were 296 responses to this question. Of these:

125 (43%) respondents asked for clear guidance to be published.

95 (32%) respondents would require more time to prepare.

77 (26%) of these asked for additional funding to be made available.

53 (18%) respondents wanted the focus on getting needs assessments completed.

Question: What suggestions do you have for testing and/or piloting the funding model?

Answers:

There were a total of 206 responses to this question. Of these:

147 (71%) respondents said they wanted a range of LAs to pilot.

44 ( 21%) respondents wanted a phased implementation.

43 (21%) respondents wanted a limited time period within which this must be done.

37 (18%) respondents offered to pilot the funding model.

Question: If you have any comments on any aspects of our proposals for short-term supported housing, please could you state them here?

Answers:

There were 115 mixed responses to this question.

Some responses set out a preference for keeping funding within the welfare system.

Some asked for certainty around the future allocation of funding to short-term supported housing.

Some asked the Government to reconsider the definition of short-term supported housing.

What is the Government’s response to these consultations?

Sheltered and extra care housing

The Government recognises there are a considerable diversity of schemes under this type of housing and, as a consequence, the level of service charges will inevitably vary. Those who responded to this consultation expressed concern therefore that the previously proposed ‘Sheltered Rent’ would be difficult to set at a level that suits all. There was also concern expressed that it would be challenging and complex to regulate gross rent as setting a consistent cap would be almost impossible to achieve. Therefore, the Government has decided not to pursue the Sheltered Rent model for this type of housing.

Short-term supported accommodation

This type of supported housing is also diverse with a variety of services, supplier and business models. As a result of this, there was little consensus among those who responded on many areas affecting this sector of supported housing, including agreement regarding the correct definition of short-term supported housing or the right funding model. Concern was expressed at the practical difficulties of moving from a demand-led funding model to a commissioning model for housing costs, with many identifying the increased administrative burden that would fall on providers. Many providers were anxious to receive a guarantee from the Government that the grant fund would grow annually in line with social rents and increased demand. This would be complex to achieve within the confines of a fixed grant. There was also concern that the proposed future funding would have a negative impact on both current and future development. Having accepted the many issues raised by those who responded during the consultation period, the Government has concluded that continuing to provide funding via the welfare system, together with a ‘robust’ oversight regime, is the better option. This means that the grant model will not be brought into effect and Housing Benefit will be maintained for all supported housing, including short-term.

What are the next steps?

In summary, after taking account of the responses received, the Government has decided to maintain Housing Benefit for all supported housing. The Government remains determined to ensure that both quality and value for money remain at the heart of the supported housing sector providing much needed accommodation for the most vulnerable in society. To that end, they will continue to work with providers, local authorities, membership bodies and resident representatives in the coming months to create a sound and robust oversight regime. Finally, the Government has heard concerns expressed within the sector about how support is funded, and the relationship between support and eligible service charges and they are committed to reviewing this whole area.

Concluding remarks

It remains to be seen if these decisions will be lasting final decisions but, for now at least, many providers may feel a sense of relief at the Government’s u-turn regarding the future funding of supported housing.