There is a saying that “hard cases make bad law” and I believe, unfortunately, that this is what we’re seeing here. With some exceptions, notably on domestic violence and abuse services, this Report is a missed opportunity based on an inadequate grasp of the supported housing ecosystem that it wishes to reform.
The Consultation on Rent Capping & Enhanced Housing Benefit
As you’re doubtless aware the Regulator for Social Housing is currently consulting on the introduction of a core rent increase of 3%, 5% or 7% for social housing. The consultation is here. The reason for the consultation is the significant increase in the rate of inflation in circumstances where social housing core rents can currently be… Continue reading The Consultation on Rent Capping & Enhanced Housing Benefit
The Problems with Exempt Accommodation
This influx of the uninvited has led to significant pressure on local authorities and enhanced Housing Benefit. Alleged supported housing providers, whether connected to dubiously motivated private capital or not, have popped up all over the place, usually in the form of a CIC, and demanded enhanced Housing Benefit for alleged supported housing services that no one asked them to provide.
Problems Claiming Enhanced Housing Benefit?
Charities, voluntary organisations and registered providers (housing associations) that provide supported housing and/or tenancy sustainment services are entitled to Enhanced Housing Benefit to provide Intensive Housing Management. However, all things are not equal and some organisations are, in practice, more entitled than others.
Enhanced Housing Benefit, the Exempt Accommodation Project and the Oversight of Supported Housing
We have seen additional restrictions on, and greater scrutiny of enhanced Housing Benefit claims made by supported housing providers under the Exempt Accommodation rules.
Back in October 2020 I wrote a briefing on the National Statement of Expectations for Supported Housing in which I expressed concern that it would be used as an exercise in cost control. Unfortunately, those fears seem to be justified in many instances. Some local authorities are trying to insist on supported housing providers becoming registered providers to qualify for framework agreements and tenders in circumstances where, in England at least, this is a very difficult thing to do.
The Exempt Accommodation Project
It simply wrong and discriminatory that tenants’ entitlements to Enhanced Housing Benefit, which is a personal benefit, are dependent on the legal identity of their landlord.
Why are some local authorities restricting enhanced Housing Benefit payments to charities & voluntary agency supported housing providers and/or forcing them to apply to become registered providers?
We are beginning to see disappointing examples of some local authorities imposing blanket restricted Enhanced Housing Benefit levels on non-registered provider supported housing (i.e., voluntary organisations and charities). This has nothing to do with matching resources to needs. It’s just crude cost control being exercised at the expense of supported housing and the people it houses and supports.
Intensive Housing Management & Enhanced Housing Benefit
A List of Routinely Eligible Intensive Housing Management Tasks & Functions
The Supported Housing (Regulation) Bill
In devising a system of regulation and oversight, we have the opportunity to either create a system that enables supported housing to generate value in a big way or one that is an albatross that starves supported housing of revenue and serves only to support the discredited system of public sector cost control within which the balance between cost and quality has become compromised.
The National Statement of Expectations for Supported Housing
It has been five years since the 2015 Comprehensive Spending Review suggested changes to the regulation and oversight of supported housing. The National Statement of Expectations for Supported Housing published on 20th October 2020 is an underwhelming development after this five year wait.