The purpose of this blog post is to identify the high-level principles for the regulation of supported housing and for the assessment of the value generated by supported housing. Collectively we might call this “oversight”. The details of both systems are content for a future, longer published briefing (watch this space).
Supported housing accommodates between 600-700,000 people in the UK, some of whom have high levels of additional need. Supported housing providers receive over £4 billion annually in Housing Benefit/Universal Credit revenue together with contributions from the people they accommodate and, in some cases, statutory sector top-up funding as well.
No one is responsible for the oversight of supported housing. Some might argue that there are plenty of regulators in the supported housing sector: the various national social housing regulators, the Charity Commission in England and Wales, the OSCR in Scotland. To a greater or lesser extent these agencies might regulate supported housing providers, but they don’t oversee supported housing or what it does, and they probably shouldn’t try.
Supported housing accommodates a wide range of additional need and there is a need for oversight. I’ve made reference a number of times recently to Thea Raisbeck’s “Exempt From Responsibility?” Paper, part of which looks with concern the unregulated Exempt Accommodation sector.
There is a distinction between regulation on the one hand and the measurement of quality/assessment of value on the other, although there is a relationship between them as “oversight” functions.
Regulation & the Assessment of Value
Regulation might include the ongoing assessment of:
- Governance/organisational competence
- Financial security and stability (calibrated to accommodate a diversity of specialist supported housing providers)
- Service delivery competence
Any system for “measuring” (assessing) the value of what supported housing does, separately from regulating the organisations that provide it, should be based on Value Generation principles:
- Outcomes for people
- Cost benefit
- Wider social/community benefit
We have the opportunity here to put something in place that works. Whilst the UK has increasingly divergent health and social care systems, the regulatory and value assessment approaches I’m setting out have potential applicability across the 4 nations.
Some of you may recall the QAF (Quality Assessment Framework), compliance with which was required for Supporting People funding, although not all supported housing providers had Supporting People funding. In addition to QAF compliance, supported housing providers had to submit performance returns (SPPIs). Over time, these returns became increasingly compromised by the “cost control” bias applied to them by local authorities seeking cost savings. This in turn encouraged some providers to describe the service delivery outcomes in unjustifiably positive terms in order to maintain their less than adequate funding.
Consider this example, which is true. Someone with a high level of additional need who lives in supported housing runs up high arrears, threatens other people and causes significant property damage. That person is then moved by the (regulated) supported housing provider into private sector accommodation without recourse to eviction (this was pre-Covid 19), and this is described as “planned move on”. The planned move on enables the supported housing provider to tick the “successful outcome” box in contractual compliance terms when what they actually did was to pass unresolved need to another part of the system.
Neither the system for assessing value (Value Generation) or the regulatory framework it sits next to should be operationally onerous for providers of supported housing. The oversight tail shouldn’t wag the operational dog on a day-to-day basis.
Smaller and specialist providers often struggle to comply with finance and governance regulation requirements. Regulation systems should adjust themselves to the safe operating parameters of all supported housing providers, not vice versa.
Systems for regulating supported housing providers and for assessing the value they generate should be developed independently by universities or other social policy research bodies as national frameworks (by which I mean separate frameworks to suit the particular characteristics of the health and social care system in each nation).
It would be appropriate for the body that develops the regulatory and value assessment frameworks to then operate them independently from but in conjunction with the agencies that commission and fund the supported housing. This would break the link between funding and the assessment of value, which needs to happen lest we focus on the cost of everything and the value of nothing.
Supported housing oversight is essential. It accommodates high levels of additional need and receives significant public and other revenue.
An oversight system comprised of regulatory and value assessment components should be independently developed and then implemented/managed by a university or social policy agency.
Regulation should accommodate diversity and specialism: it should not discriminate in favour of scale.
Oversight as a whole should maximise security and quality of outcome for people without impinging on supported housing providers’ service delivery resources.
There is change to the social and healthcare landscapes throughout the UK. The evolution of health and social care should include seeing supported housing as an integrated part of the different systems within the 4 nations. For this to occur it is important for supported housing to have the type of oversight I have described.