Categories
Policy

The National Statement of Expectations for Supported Housing

Introduction

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, albeit that the 2018 decision to continue funding supported housing from the welfare system, rather than a local authority commissioned funding model to top up Local Housing Allowance rates of Housing Benefit, was a welcome hiatus.

We knew that MHCLG and DWP were going to focus on:

  • Controlling Housing Benefit costs
  • Exploring sector led accreditation and benchmarking for supported housing
  • Identifying local authorities’ strategic planning frameworks for supported housing, resulting initially in the draft National Statement of Expectations published in 2017 as part of the “Funding Supported Housing” consultation and policy statement.
  • Examining enhanced regulation for supported housing

Publication of the National Statement of Expectations for Supported Housing is well overdue after having been flagged up as a UK Government intention over two years ago as part of the “Funding Supported Housing” proposals of 2018 and the draft National Statement of Expectations of 2017.

Added to that is the increasingly urgent and understandably strident tone of various parties demanding that supported housing, or at least the “exempt accommodation sector” should be regulated. Thea Raisbeck’s important “Exempt From Responsibility?” report focusses on this and more.

I agree. I have said so often, for example, my blog post of June 2020. For me, any regulatory and oversight frameworks for supported housing have to be based on Value Generation principles:

  • Outcomes for people
  • Cost benefit
  • Wider social and community benefit

Regulation and Oversight

Regulation should apply to how an organisation is structured, managed and financed. Oversight, in contrast, should apply to what it does, in this case the delivery of supported housing.

There is already a multiplicity of regulators in the supported housing sector, none of which in my opinion has a complete grasp of the nature of supported housing. There are also many supported housing providers that are entirely unregulated. Add to that the vexed question of who oversees what supported housing does, regulated or not?

The National Statement of Expectations for Supported Housing is not about regulation, it’s about oversight. It’s not about many of the services provided to people in supported housing, it’s about the accommodation itself and tenancy related services, the latter being Intensive Housing Management funded by enhanced Housing Benefit.

It’s also “guidance”. It relies on the statutory sector for its implementation and without additional funding it will have very little meaningful impact on how supported housing is overseen. This is a missed opportunity.

Having made clear that this Statement of Expectations is about oversight not regulation, it then makes clear that it’s about the oversight of supported housing accommodation not supported housing services. To be frank, it’s not really about oversight at all. It should oversee what supported housing does and how, not just where it does it.

Jurisdictional Scope

The National Statement of Expectations for Supported Housing doesn’t make clear to whom it applies in UK jurisdictional terms. It’s a UK Government document but to the extent it mentions regulators it only mentions English regulators. The Housing Benefit about which it talks a lot is a non-devolved function. So, is this England only or is it, at least in part, UK wide? At least one of the examples of good practice used is from a Scottish housing provider.

Analysis

When a policy pronouncement of this potential significance is made, I would usually undertake a line by line analysis. I did begin to, but rapidly came to the conclusion that you’d lose the will to live after the nth vague exhortation by UK Government that local authorities should be “encouraged” to do stuff that was originally set out in the draft National Statement of Expectations of 2017.

I have therefore tried to summarise the UK Government’s “wish list” and to contextualise it by referring to what might have been.

The National statement of Expectations for Supported Housing is divided into two main sections:

  1. Assessing local need and planning effectively to meet demand
  2. Delivering accommodation which is safe, good quality and value for money

Assessing local need and planning effectively to meet demand

The National Statement of Expectations for Supported Housing says that there should be collaboration between statutory sector agencies, including revenues and benefits teams, which should enable us to see that this is partly about controlling Housing Benefit costs in the specified/exempt accommodation sector.

I entirely agree that providers should collaborate with local authorities in the development of new supported housing. There are too many entirely unregulated supported housing providers setting up independently of commissioners and then applying for enhanced Housing Benefit.

Local authorities are “encouraged” to

  • Implement oversight arrangements
  • Undertake accommodation needs assessments
  • Map supply against current and future demands (as per the 2017 draft National Statement of Expectations)
  • Identify additional funding requirements.

Local authorities are not being given new money to do this and it isn’t a statutory requirement it’s just guidance, so there are no prizes for guessing what the likely upshot of this will be.

Providers of supported housing are exhorted to ensure safe and good quality housing, including the use of “the most secure form of tenancy/licence compatible with the purpose of the supported housing”.

Local authorities should ensure “value for money” by sharing data and benchmarking within and across local authority boundaries. Maybe you’ll forgive me for hoping that this is more about generating value (see the definition of Value Generation in the Introduction) than just crudely controlling costs, which often achieves the opposite effect. Restricting investment in prevention simply causes more human suffering and the much higher costs of subsequent, and otherwise avoidable, statutory health, social care and criminal justice interventions.

The National Statement of Expectations for Supported Housing is right to say that enhanced Housing Benefit claims should be no higher than the cost of providing eligible services that people need, but the likely outcome of what may be chalk and cheese comparisons of different supported housing services to establish local benchmarks may simply be to restrict the amounts payable on the basis of false comparisons. In other words, it may well be more about controlling costs than meeting peoples’ needs or generating value.

The National Statement of Expectation for Supported Housing provides a comprehensive list of (English) statutory and other agencies which should be involved in assessing needs and planning supported housing. It refers to the National Planning Policy Framework (which applies to England only, by the way) and makes reference to the need for “cross authority arrangements”. The latter have been with us in spirit but alas, rarely in physical form since the days of Supporting People.

Delivering accommodation, which is safe, good quality and value for money

The National Standards of Expectations for Supported Housing document refers to a checklist of existing legal requirements and suggested standards for accommodation and “tenancy related housing services” (presumably a reference to Intensive Housing Management funded by enhanced Housing Benefit). These are in Annexes A and B of the document.

Rather predictably much of the focus on “oversight” is around controlling Housing Benefit costs. I’m very much in favour of ensuring that enhanced Housing Benefit is paid at a rate equivalent to the reasonable costs of providing Housing Benefit eligible services that supported housing residents need. To do so is a good investment in prevention and enablement. I am not in favour of reducing enhanced Housing Benefit payments down to artificial maxima established on the basis of false comparisons between different supported housing services as a means of cost control. I’m also bitterly opposed to paying any Housing Benefit whatsoever to contrived supported housing arrangements set up by ill-motivated people to milk the system at the expense of people with additional needs and of the public purse.

I return again to the notion of Value Generation. Sometimes the enhanced Housing Benefit costs of supported housing seem high, whether it’s paid to Specialised Supported Housing (see page 4 of the hyperlinked document for a definition) or other forms of supported and sheltered housing. However, other services for people with additional needs are often far more expensive, and if supported housing generates value:

  • Outcomes for people
  • Cost benefit (to the public purse)
  • Wider social and community benefit

then enhanced Housing Benefit, which equates to what it reasonably costs to provide eligible services, generates a lot of value as well. To use the National Statement of Expectations for Supported Housing to artificially suppress enhanced Housing Benefit entitlements would be a myopic mistake.

The exhortation within the National Statement of Expectations for Supported Housing for commissioners and revenues and benefits departments to work together is both welcome and overdue. I am familiar with too many examples where commissioners give strategic support to a supported housing service (even if they’re not funding it) but revenues and benefits departments refuse enhanced Housing Benefit payments. This is most frequently because they can’t fully recover the amount of the proposed charge from the DWP, which is jointly responsible for the National Statement of Expectations for Supported Housing by the way.

In addition, I’m familiar with so-called supported housing services that are awarded enhanced Housing Benefit by revenues and benefits departments, even though these services are set up without reference to commissioners. Mercifully, this situation is increasingly less common now.

As I said in my introduction to this briefing, the UK Government was thinking about sector led benchmarking and accreditation schemes. My own view is that oversight should be conducted by an externally developed framework for accreditation and quality, based on Value Generation principles. In my “Oversight of Supported Housing” blog post I set out the basis for such a system, to be developed by a University or think tank and implemented by the same agency independently of commissioners/funders and providers, although they would inform its shape and nature according to Value Generation principles. The measurement of the value of supported housing must be independent of the people who fund and provide it.

The National Statement of Expectations for Supported Housing proposes a Supported Housing Sector Scorecard, an initiative apparently being led by the National Housing Federation but about which there is little in the public domain. Its development has been delayed for understandable pandemic-related reasons. What is less understandable is the apparent lack of openness about its development, with organisations simply being asked to email the coordinating agency to participate.

It’s based on the more general Sector Scorecard for social housing, the vast bulk of the reports from which are quantitative not qualitative. For supported housing in particular, qualitative data really matters because how people feel about supported housing can often not be measured in quantitative terms, neither can much of its wider social and community benefit. Forgive me for reminding you again of the three Value Generation principles:

  • Outcomes for people
  • Cost benefit (to the public purse)
  • Wider social and community benefit

Of these three the first and the third principles need to be measured qualitatively lest we become preoccupied with the cost of everything and the value of nothing.

Conclusions

The National Statement of Expectations for Supported Housing has been a long time in the making. It hasn’t changed that much from the draft National Statement of Expectations of 2017 and is disappointing in its scope.

Its focus is on the oversight of the buildings in which supported housing is provided and on “tenancy-related services” only (presumably another term for Intensive Housing Management). It doesn’t concern itself with regulation.

Existing regulators in the sector have neither the scope not the expertise to regulate what supported housing does nor the mandate to oversee it. Given the extent of additional need that supported and sheltered housing is now expected to meet we’ve been let down here. Much of what the sector does will remain inadequately overseen and unregulated.

It seems to me that the primary thrust of the National Statement of Expectations for Supported Housing is the control of enhanced Housing Benefit expenditure. It is certainly true that we should be very careful about who is paid enhanced Housing Benefit. That is a very different thing from artificially restricting such payments to genuine, value generating supported housing providers. We have an opportunity and a necessity to separate the supported housing sheep from the goats and the National Statement of Expectations for Supported Housing manifestly fails to help us do this.

To the extent to which the National Statement of Expectations for Supported Housing identifies useful things, for example, coordination between revenues and benefits teams and commissioners, wider involvement of other statutory agencies, strategic planning and the mapping of supply and demand for supported housing, it does nothing to enable these things. It’s only guidance and provides no new funding for implementation and as such it’s a recipe for inaction save for the focus on restricting enhanced Housing Benefit.

The framework for the oversight of supported housing should be developed and implemented independently of commissioners and providers, albeit with the latter’s significant input. There has to be a separation between the measurement of quality on the one hand and the funding and delivery of supported housing on the other.

Moreover, the oversight of supported housing should be conducted according to Value Generation principles, which have their own internal cost/quality checks and balances.

Michael Patterson

October 2020

Categories
Policy Supported Housing Management

Using Commercial & Retail Space for Reconfigured Supported Housing in the “Post Covid” Era

This blog post looks at the post Covid 19 challenges facing organisations and people who are involved in Emergency Access Accommodation such as refuges, hostels and night shelters that are physically incompatible with the requirements of social distancing. It’s also relevant to people and organisations looking to fund, commission and develop supported and social housing irrespective of whether they have been involved in Emergency Access Accommodation.

If you’re a commissioner, social/institutional capital funder or supported housing provider please read on and get in touch with me if you want to be involved in the development of supported housing, especially but not essentially, in what was previously commercial property such as office or retail space.

One of the consequences of Covid 19 has been the fact that many of us have been required to work from home. Employers have historically been nervous about letting employees work from home perhaps because they fear the consequences of not being able to physically oversee what they’re doing.

However, one of the unanticipated consequences of Covid 19 has been that many employers have developed systems to manage homeworking situations so that employees are clear about what is expected of them, people can communicate well with each other and employers have discovered, in the main, that their fears were unfounded.

This has significant implications for the future of commercial property; primarily office and retail space. Having been required to bite the homeworking bullet many companies will have realised that they no longer need the office space they had, at least not all of it. Furthermore, the retail sector has retrenched and will retrench further in areas where office space falls vacant. As a consequence, it is likely that there will be a glut of unoccupied commercial buildings the owners of which will be desperate to lease it or sell it at a price which will be accordingly reduced.

Some of these premises will be reconfigurable as living space for social and supported housing, often based in central locations. Covid 19 has made us rethink the practicability of the traditional hostel, refuge and other supported housing provision (Emergency Access Accommodation) where people with additional needs are in close proximity to each other. One pandemic is one pandemic too many, but unfortunately, it’s unlikely to be the last. We have the opportunity, albeit an enforced opportunity, to rethink the configuration of supported housing and to move away from HMO style arrangements and to consider designs that give people more personal physical and communal space.

Appropriate surplus commercial space can be reconfigured to supported housing in such a way as to allow a hostel or refuge HMO to be relocated. Instead of single rooms with shared facilities, we can create more self-contained spaces and buildings that will also accommodate communal and management space. Combine this with the fact that there is a lot of institutional and other capital waiting to be deployed into supported housing, and an enhanced Housing Benefit revenue stream to support repayment of the capital and the operation of reconfigured housing. We might all have an unexpected opportunity for the development of new and better designed supported housing in central locations.

Covid 19 has forced the UK Government and national governments to fund programs to drastically reduce street homelessness at the same time as forcing us to rethink the configuration of HMO configured supported housing/Emergency Access Accommodation such as homelessness hostels night shelters and refuges. Housing First services need housing that can be managed with geographical ease and without sacrificing self-containment. Think of the other client groups you work with in supported housing and what the possible opportunities might be.

Think also about how you might approach the need for both capital and revenue and when you do, please get in touch with me because I can help you with these things.

Michael Patterson 18th August 2020 michael@michaelpatterson.co.uk 07376737675

Categories
Finance & Funding Policy

Working Together to Develop New Supported Housing

A Bit of Background

One of the issues that has preoccupied me lately is the way in which private and institutional capital has been and is being introduced to the sector to fund supported housing for people with often high levels of additional need.

Let me be clear; I’m very much in favour of this, but it’s important that it’s done properly by investors, commissioners, housing associations and care and support providers.

You’ll probably be familiar with my emphasis on Value Generation principles

  • Outcomes for people
  • Cost benefit to the public purse
  • Wider social and community benefit

It’s important that all parties have a common values base, such as Value Generation, if we are all involved with services for people with additional needs. If supported housing is developed without common values between the parties involved, the people who pay the price of failure are those who live in it and those who work directly with them to do so.

Private Capital for Supported Housing

Supported housing funded through private capital is a relatively immature “market” and the record so far is a patchy one.

Investors are being offered a good deal here if they’ve done their homework, they know they’ll get a safe long-term return on their investment. That return should be measured in single figure ROI percentages, yet commissioners tell me of investors seeking excessive double-digit percentages whilst some “aggregators” walk off with huge commissions.

If the bottom line is all that matters, then you’re dealing with the wrong sector. To the extent that supported housing is “market” it’s a social one, and your social purpose has to underpin your investment. There are some really good socially oriented investors out there and they’re looking for commissioners who need supported housing. There are housing associations that understand what their role should be and providers with the capacity and vision to take on a wider role, for example, direct responsibility for day-to-day and reactive maintenance as well as direct support to residents.

The Role of Housing Associations

Housing associations are a necessary part of the mix here and, in many cases, they don’t actually provide much or any intensive housing management and support to people who live in supported housing (who are their tenants). This is more often done by specialist providers, but not always: some housing associations are also providers in their own right.

There are different types of housing associations. The “REIT” (Real Estate Investment Trust) based housing associations are there to enable local authorities to fully recover from the DWP the enhanced Housing Benefit they claim for supported housing, and to be a regulated presence that should provide comfort to commissioners and others involved in the development of privately funded supported housing.

REIT-based housing associations need to be independent of capital finance providers, not just a vehicle for enhanced revenue. We should be entitled to expect them to manage their finances and conduct their governance in accordance with a social model of operation. They claim significant levels of public funding in the form of enhanced Housing Benefit, which is a personal benefit of their residents. They should make proper provision for the operation of the housing for which they are responsible, including the creation of maintenance sinking funds and other operational costs. They should remunerate their people on the basis of the value they generate within a social market.

The English Social Housing Regulator recently investigated a number of REIT-based housing associations that develop supported housing with the use of private capital and operate on the basis of public revenue (enhanced Housing Benefit). Regulatory judgements were issued on a number of these. Without commenting on specific cases, it seems to me that the Social Housing Regulator may have rightly censured some but did so without publicly identifying whether any individuals involved made significant personal financial gain. To some extent the Regulator may have also thrown the baby out with the bathwater by criticising other REIT-based housing associations that develop and operate very good supported housing and generate significant value.

Community-based or “traditional” housing associations are typically different from REIT-based associations as they’re not primarily vehicles for the introduction of private capital. What I would like to see is a model where these community-based housing associations act to facilitate the introduction of private capital for supported housing and matching enhanced Housing Benefit because they typically have good governance and operational/financial management.

Sometimes community-based housing associations directly manage supported housing, often they conclude Management Agreements with specialist provider agencies to do so. The agency management route is a well-worn path, but not without its own problems. One of the problems with many housing associations is a common failure to provide sufficiently responsive maintenance services. A broken window in a general needs property may not be deemed to be an “urgent” or “emergency” repair, but in supported housing it often exactly that because of the tenants’ additional needs. The provider agency is usually in a better position to deal with responsive maintenance and in my opinion the Management Agreement should allow for this and the maintenance revenue stream should go direct to the provider agency.

Socially oriented private and institutional investors, commissioners and providers in supported housing would very much value being involved with community-based housing associations, which would take a lease on the supported housing properties. Under such an arrangement, community-based housing associations would enable the claiming of enhanced Housing Benefit such that the local authorities that pay it can fully reclaim it from the DWP.

A Management Agreement would still need to be concluded with the provider agency within which the community-based housing association’s role would be minimal: ensuring that occupancy agreements with their tenants are properly administered by the provider agency and ensuring that the physical environment is of an excellent standard without actually doing the day-to-day maintenance, which would be one of the provider’s roles.

The housing association would receive a management and administration fee and possibly an equity share in the properties as well as plaudits from commissioners and others for acting according to a social purpose.

A Call To Action

I’m prompted to write about this having recently been in discussion with social investors and property developers who are looking for community housing associations and provider partners to work with in the development of new supported housing.

I’ve also been asked to help connect providers with people who fund and develop property for use of supported housing.

  • So if you’re a support provider looking for property for supported housing or the capital to develop it
  • A socially oriented property developer/investor looking for a supported housing provider or a community housing association to work with
  • A commissioner who wants to see the development of good quality supported housing in your area
  • Or a community housing association that’s interested in working with a socially oriented property developer/investor to develop supported housing, with or without an agency support provider

Then please get in touch directly with me and I can put you in touch with my wide network of contacts in the provider, housing association, commissioning and investor/developer sectors.

A Few Words of Caution

On a final, if slightly separate matter: if you’re someone who wants me to help you

  • Set up as a housing association/RP
  • Or a supported housing provider using private property in which you have a personal interest
  • Or you want enhanced Housing Benefit for supported housing that you set up without the active support of local commissioners

Then please DON’T contact me.

Please excuse the slightly tetchy tone but it sometimes gets a little tiresome. I publish blog posts and briefings promoting the need for an integrated and social approach to the development of supported housing, and I then get inundated with requests from private individuals whose intentions have much to do with private profit and little or nothing to do with social value.

I have values (see Value Generation above). They’re important to me and to supported housing in general. I work with people who share those values. I don’t work with people who don’t share those values.

Categories
Finance & Funding

Claiming Enhanced Housing Benefit for Intensive Housing Management

Context

I was recently rereading a Briefing on enhanced Housing Benefit and Intensive Housing Management (also known as enhanced housing management and/or additional housing management), that I wrote for Support Solutions in 2010. I was struck by how relevant and important the information in that Briefing remains today.

Enhanced Housing Benefit is payable to providers of most types of supported and sheltered housing, provided they comply with the Exempt Accommodation rules. If you’re not sure whether your organisation qualifies please ask.

Please be aware that we do not support unregulated private supported housing providers to claim Enhanced Housing Benefit for reasons set out in Thea Raisbeck’s “Exempt From Responsibility?” report.

The reason that Enhanced Housing Benefit is payable is because qualifying supported housing providers provide additional and more intensive housing management and maintenance services than would be the case in general needs rented housing. They do so because supported housing residents have additional housing needs and supported housing itself has additional maintenance and services costs.

What Are Enhanced Housing Benefit & Intensive Housing Management?

There is no definitive list of Intensive Housing Management tasks. We have developed one based on the notion that Housing Benefit will fund tasks which are part and parcel of adequate accommodation, bearing in mind the needs of the residents, and provided these tasks are not funded elsewhere.

Many of these tasks routinely constitute much of a Support Worker or a Scheme Manager’s job description. Housing management functions such as lettings, assistance with claiming Housing Benefit to ensure that rent and service charges are paid, controlling access and facilitating and monitoring site visits from contractors and other visitors/professionals, arranging aids and adaptations, health and safety and risk assessments of property, management, administration, delivery and facilitation of housing services provided, the additional maintenance and services costs……I could go on.

If you are a non-profit provider of accommodation and support and the Intensive Housing Management tasks you perform aren’t funded by another revenue stream, then it can be funded by Housing Benefit. Even better, if you’re a registered provider of social housing (RP) and you provide supported or sheltered accommodation, in which you charge Intensive Housing Management as an eligible service charge, the local authority receives full reimbursement from the DWP in subsidy recovery. This means you’re actually bringing in money to the local area.

This subsidy top-up doesn’t fully apply where non-RPs go down this route. 40% of the difference between what you claim and the Rent Officer determination, which will be similar to the relevant Local Housing Allowance, goes onto the Council Tax bill or is picked up within another local authority budget, such as Adult Social Care. But that’s still a cost-effective way of a community funding a preventative, enabling service.

Why You Should Consider Enhanced Housing Benefit & Intensive Housing Management

It’s a very attractive proposition for RPs and other non-profit accommodation-based support providers for a variety of reasons.

You get full cost recovery on your housing costs which have often been underfunded for years. OK, RPs have an issue with compliance with the Regulator’s Rent Standards (unless its “Specialised Supported Housing”). But that isn’t a problem: Intensive Housing Management costs can be treated as service charge items. You can re-allocate costs and budget headings from rent to housing services where feasible in supported and sheltered housing arrangements.

This enables you to invest in the properties in which people with additional needs live: the physical environment, services and staff. Your support costs can be cheaper because you’ve remodelled your service delivery structure and/or taken some costs out and allocated them (where eligible) to Intensive Housing Management, funded through Housing Benefit. This matters when you bid for support/care contracts because your unit cost for support will be lower without actually reducing your revenue – you’ve just spread the cost.

The Current & Future of Enhanced Housing Benefit & Intensive Housing Management

Having worked with Enhanced Housing Benefit since 2005 you get used to hearing people say, “but it has to end sometime”. Well it hasn’t yet and one of its distinguishing features is its longevity and the fact that case law precedent has established that Intensive Housing Management is eligible for Housing Benefit, having regard to the nature of the accommodation type and personal circumstances of the tenant group.

Over time the Enhanced Housing Benefit pot has grown. Initially, this was directly in response to the retrenchment of “Supporting People”. We advised providers (and not a few local authorities) on reallocating the eligible proportion of their Supporting People revenue loss into Enhanced Housing Benefit. Over time this has become a well-worn path, supported as it is by regulation and case law.

Commissioners/funders will routinely ask supported housing providers looking for funding “have you reallocated your eligible costs into Enhanced Housing Benefit?” because it makes absolutely no sense not to do so.

Providers might want to consider revising service delivery models if this adds value to the lives of people with additional needs. For example, we are often told “well we would provide more services because people need them, but we don’t have the funding”. One of the things we do is to review service models and staff job descriptions in order to introduce Housing Benefit-eligible services such as concierge, access control or night security, for example.

If you’re a qualifying supported or sheltered housing provider (i.e. most social/non-profit providers of supported housing) and you haven’t gone down this route, or you haven’t done so for a while, you really should think about it and get in touch.

Even with the introduction of Universal Credit Enhanced Housing Benefit remains payable in respect of supported housing tenants. This is despite the fact that Housing Benefit was one of the benefits absorbed by Universal Credit and would not otherwise exist. When someone claims Universal Credit, the online application asks the claimant whether they live in supported housing. If they answer “yes” to that question the housing component of their Universal Credit is administered by the LA on an uncapped basis under the Exempt Accommodation rules. This also gives supported housing residents protection from the Benefit Cap, and in some cases from the Spare Room Subsidy/Bedroom Tax.

The “but it has to end sometime” mantra is true of course; it’s just been overly pessimistic for years. It’s likely that the time for change will come when the UK Government finally decides on the funding model for supported housing (in England). Specifically, whether a  transitional arrangement of paying Enhanced Housing Benefit for supported housing via Universal Credit be formalised as a permanent arrangement (which is what we believe will happen). The UK Government did eventually commit to keeping the funding of supported housing within the welfare system after all.

Health and social care are devolved functions within the UK, and supported housing would be were it not for the fact that a proportion of its funding, in the form of (Enhanced) Housing Benefit, remains non-devolved. If the UK Government takes a sensible view of supported housing, and not just its funding, it’ll see it as an integrated part of the health and social care system in England going forward. At the point of change, whatever and whenever that is, it may be that Enhanced Housing Benefit will become a component of Universal Credit.

What happens in NI, Scotland and Wales depends on whether those nations have a fully devolved welfare system (easy to see in Scotland) and whether they choose to (part) fund supported housing from within it or choose to put the funding within health and social care commissioning structures.

Why You Should Think About It

Our message is that you should consider now whether you’re properly recovering the costs of providing the supported housing services that your residents need, or whether you should consider reviewing your service delivery model to enhance revenue recovery. Not just the costs of human (staff) services, but the additional costs you incur in maintaining and servicing your supported and sheltered housing.

Supported housing providers are rightly asked to demonstrate the value that they deliver. They should be equally concerned to identify the costs they incur in delivering that value.

The best way to do so is to ask us to audit what you do and to calculate what it that translates into as a full-cost recovery rent structure. If the amounts are more than you currently charge, then please let us negotiate with Housing Benefit colleagues on your behalf to redress the imbalance.

The good news is that it won’t cost you anything if we find that you can’t claim Enhanced Housing Benefit. If we find that you can, and we successfully negotiate an increase, then you pay a percentage of the increase we achieve for 1 year only. You only pay this percentage when you’re in receipt of the increased revenue and you can pay it over a 12-month period to aid cash flow. If we don’t get you an increase, you don’t pay us anything at all. Contact us.

There is an evident danger in not demonstrating your true costs, or revisiting your service delivery model, whether to appear “reasonable/competitive” to funders or for some other reason.

That danger may manifest itself if we have a funding system change at the point of which supported housing providers’ costs are frozen. If you haven’t optimised your rent and services charges income, the new system may assume you can make do with what you have.

Michael Patterson and Danny Key have worked together on Enhanced Housing Benefit, Intensive Housing Management and other things since 2005. Michael writes, publishes and speaks on supported housing and related matters and provides strategic advice a range of supported housing providers and revenue and capital funders.

Danny’s expertise lies in the technical side of Enhanced Housing Benefit and its relationship to capital. He is an expert on Housing Benefit regulations, the Exempt Accommodation rules and negotiation of claims.

If you’re interested in Enhanced Housing Benefit please get in touch. If Michael thinks your organisation properly qualifies for Enhanced Housing Benefit he’ll involve Danny and if you decide to ask us to help you claim it, you’ll also get half a day of Michael’s supported housing consultancy service (usually via Zoom) for no charge at all.

Categories
Policy

The Oversight of Supported Housing

Context

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.

Oversight

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
  • Values

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.

Summary

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.

Categories
Finance & Funding

Funding Supported Housing

Context

This blog post is the third in the “What is Supported Housing?” Series. To summarise so far I have suggested that supported housing:

  • Be defined other than by timescale
  • Is where someone with an additional needs lives, for the duration of that need, irrespective of who the landlord is
  • Should be regulated (see my next blog post)
  • Should be commissioned, funded and “measured” according to Value Generation principles

The UK Government is working on draft social care legislation for England and devolved governments have yet to integrate supported housing into the health and social care mainstream. Supported housing, not least its funding, should be part of the health and social care mainstream.

Revenue

Supported housing revenue includes local authority and NHS administered funding for social and health care needs, and people’s own personal budgets.

Supporting People funding is now the exception not the rule. A significant amount of the value of the Supporting People budget (originally £1.8 billion) has been reallocated into (enhanced) Housing Benefit as Intensive Housing Management funding. It’s moved from the instability of local authority finances to the relative stability of the welfare benefits system.

The key question when it comes to recurring revenue for supported housing, however is “where will it sit in relation to the welfare benefits system?”. The UK Government gave a “Future of Supported Housing” policy commitment in 2018 to keep the funding of supported housing within the welfare system.

Lord Freud acknowledged in 2012 that people in exempt or specified accommodation would have the housing component of their Universal Credit administered by the local Housing Benefit team under the Exempt Accommodation rules. So effectively, enhanced Housing Benefit for Intensive Housing Management is paid as the housing component of Universal Credit on an uncapped basis.

I believe that this supported housing component of Universal Credit should be redesignated “Supported Housing Rent”, which should be payable to all supported housing providers regardless of legal identity, provided they are properly regulated (see my next blog post “The Regulation of Supported Housing”).

Whoever the landlord is, be it social, private, statutory, voluntary charitable; would it not be better for there to be a simple system whereby the costs of the building are met through a banded system to take account of different cost variables? In England these bandings would probably be regionally based. (See the “Lord Best letter” of 2017). The additional (non bricks and mortar) housing needs components can also be banded according to level of assessed need (low, medium or high).

This system has the advantages of reflecting variable levels of additional need and building/property costs whilst at the same time applying sufficient maxima to each band. It dispenses with the need for basing rent levels on wildly inconsistent Local Housing Allowance levels.

Within a Universal Credit claim Supported Housing Rent components would be therefore be awarded based on a banded regional basis to reflect the variable costs of the development and management of property in every and any given region of England, and whilst Universal Credit remains a non-devolved issue this model may also be of interest to NI, Scotland & Wales.

The housing based additional needs component of Supported Housing Rent could be paid at three levels: low medium and high. These are simple principles that allow for variable costs in both buildings and the needs of the people who live in them.

Recipients of Supported Housing Rent (landlords) will have to generate value:

  • outcomes for people
  • cost benefit to the public purse
  • wider community benefit.

They will have to comply with regulatory standards (see my next blog post). We really should dispense with the absurd and discriminatory notion that peoples’ entitlements to enhanced revenue (in this case Supported Housing Rent) as a consequence of their additional needs should be dependent on the legal identity of their landlord, which is the case now.

Capital

The capital funding of supported housing is a blog post in its own right. However, having given a view on supported housing revenue it seems sensible to make some summary comments on the capital position.

We are moving increasingly in the direction of private capital funded supported housing. This has been especially so in the case of Specialised Supported Housing (what I would refer to as “Intensive Supported Housing”).

There is a need to get the balance right between social motivation and profit. Put a different way, there is a need to be realistic about what percentage return on capital public revenue should be expected to return. Investors should generate value in what they do just as much as providers of supported housing are expected to do.

REITs (Real Estate Investment Trusts), which facilitate much of the investment in supported housing, need to evolve their structures in the light of the English social housing regulator’s judgements against some REIT-based housing associations and the associated trade press reporting.

Conversely, we should consider how well-placed social housing regulators across the UK are to oversee supported housing, a significant amount of which sits outside their sectors. I think there are strong arguments to make for the independent regulation of supported housing, arguments I shall attempt to make in my next blog.

Investment in supported housing is based on a viable revenue stream. This viable revenue stream, with its consequent impetus to investors, should be built into universal credit on a Supported Housing Rent basis.

The UK Government will also continue to deploy public capital (and revenue) in the form of targeted funding for specific outcomes. For example, it has recently announced that it is bringing forward £160m of its Rough Sleeping Services budget to provide 6000 homes with support for street homeless people in England. This is ambitious enough to be a game changer for street homelessness, provided the revenue for support is sufficient and stays in place.

Conclusion

We need to think about the funding of supported housing in the context of its outcomes (see my blog post on defining supported housing) and its regulation (watch this space!).

Supported housing needs revenue funding certainty for its day to day operation and in order to give investors confidence to invest and providers confidence to provide.

Supported Housing Rent builds revenue and confidence into the system and makes the relationship between needs and resources. It retains revenue for supported housing within the welfare benefits system.

Supported housing providers, “social” or not, should generate value and comply with a regulatory framework in order to qualify for Supported Housing Rent.

Categories
Policy

What is “Supported Housing” ? (Part 2): Defining it

In my 1st blog post of the “What is Supported Housing?” series I said that supported housing is a victim of its own limiting misdescriptions. I also argued that this isn’t helped by the definitions of supported housing in the UK Government’s (now stalled) “Funding Supported Housing” policy agenda of 2018, which I’ll look at below.

Here is an opportunity then, to offer some definitions for supported housing based on peoples’ needs. Definitions that will support the integration of supported housing into the social care mainstream.

This blog post may be of interest to UK-wide readers, despite the policy focus being on England. Social care is a devolved matter but supported housing still isn’t, to the extent that it’s funded through enhanced Housing Benefit/Universal Credit. In addition, the revised definitions of supported housing I propose have universal applicability.

Formal Definitions

The Social Housing Rents (Exceptions and Miscellaneous Provisions) Regulations 2016 give definitions of supported housing in its widest sense (for England) as follows:

specialised supported housing” means supported housing—
(a) which is designed, structurally altered, refurbished or designated for occupation by, and made available to, residents who require specialised services or support in order to enable them to live, or to adjust to living, independently within the community,
(b) which offers a high level of support, which approximates to the services or support which would be provided in a care home, for residents for whom the only acceptable alternative would be a care home,
(c) which is provided by a private registered provider under an agreement or arrangement with—
(i) a local authority, or
(ii) the health service within the meaning of the National Health Service Act 2006(d),
(d) in respect of which the rent charged or to be charged complies with the agreement or arrangement mentioned in paragraph (c), and
(e) in respect of which either—
(i) there was no public assistance, or
(ii) if there was public assistance, it was by means of a loan secured by means of a charge or a mortgage against a property;

supported housing” means low cost rental accommodation provided by a registered provider which—
(a) is made available only in conjunction with the supply of support,
(b) is made available exclusively to residents who have been identified as needing support, and
(c) falls into one or both of the following categories—
(i) accommodation that has been designed, structurally altered or refurbished in order to enable residents to live independently,
(ii) accommodation that has been designated as being available only to individuals within an identified group with specific support needs;
“support” includes—
(a) sheltered accommodation,
(b) extra care housing,
(c) domestic violence refuges,
(d) hostels for the homeless,
(e) support for people with drug or alcohol problems,
(f) support for people with mental health problems,
(g) support for people with learning disabilities,
(h) support for people with disabilities,
(i) support for offenders and people at risk of offending,
(j) support for young people leaving care,
(k) support for teenage parents
(l) support for refugees;

So Specialised Supported Housing is for people who might otherwise be in a registered care home and is funded through the use of private capital. It’s also exempt from the Rent Standard.

Other “Conventional” Supported Housing defined above is subject to the Rent Standard and reflects a “typical” definition of mainstream supported housing.

Both definitions in the Social Housing Rents (Exceptions and Miscellaneous Provisions) Regulations 2016 specify the landlord as a Registered Provider. However, there are many supported housing services run by nonprofit agencies that have no registered provider involvement, and still other supported housing services provided by the private sector. Are these not supported housing?

The legal identity of a tenant’s landlord does make a difference to that tenant’s entitlement to enhanced Housing Benefit where additional needs are an issue (only social/nonprofit housing tenants/licensees are eligible). This is perverse in circumstances where additional need isn’t restricted to social housing. The regulation of all supported housing is more important than the legal status of a supported housing landlord.

Definitions Proposed in “Funding Supported Housing”

In addition to these two broad definitions above, the UK Government’s “Funding Supported Housing” policy consultation originally had the following definitions of supported housing:

  • Short-term supported housing: The UK Government has defined “Short-Term Supported Housing” as being supported housing that is accessed by people in crisis and with a maximum duration of two years or until a transition to “long term stable accommodation” is possible, whichever occurs first.
  • Long-term supported housing: Long-Term Supported Housing includes people with learning disabilities mental health needs and other groups whose additional needs are permanent.
  • Sheltered & Extracare Housing: the UK Government hasn’t defined this type of supported housing in its “Future Funding” policy agenda, apart from identifying its existence. It did accept the need not to be too prescriptive in how sheltered and extracare are defined.

I don’t believe that timescale or client group should define Supported Housing; it should be defined by the nature of the needs it meets. As I mention in previous blog posts, definitions of supported housing based on a timeframe are about the restrictive management of a pot of public money, not about meeting peoples’ needs.

The proposed definitions of Short-Term, Long-Term and Sheltered & Extra Care Housing do not reflect the diversity of supported housing services. For example, where do Shared Lives/Adult Placements, Respite Care, Housing First and Intermediate Housing fit in? No consideration is given to the sometimes high degree of overlap between Sheltered & Extra Care, Long-Term Supported Housing and Specialised Supported Housing.

Proper consideration will be given to funding supported housing in my next blog post, but for the sake of clarity all forms of supported housing should be funded, in part at least, through the welfare system as the UK Government has accepted.

Revised Definitions

So-called “short-term supported housing” should be redesignated as “Immediate Access Accommodation“. Within that definition refuges and other forms of emergency accommodation for which Universal Credit is not immediately appropriate should be funded by a ringfenced local authority fund for up to 6 weeks, after which Universal Credit including an enhanced housing component should fund it.

Intermediate Supported Housing“: which, by definition, applies to people who don’t need Immediate Access Accommodation, although they may have come from it, and don’t need Intensive Supported Housing, although they may have come from it. The duration of someone’s stay in Intermediate Supported Housing would depend on the duration and extent of their need within a system geared towards the maximisation of managed interdependence. If appropriate, Intermediate Supported Housing may be provided in the same building as Immediate Access Accommodation, for example a refuge. Funded through Universal Credit.

In the same way I challenged the appropriateness of the term “Short-Term Supported Housing” I believe the term “Long-Term Supported Housing” is inappropriate and should be replaced with the term “Intensive Supported Housing“. Within “Intensive Supported Housing” peoples’ needs can be of any duration but the point is that they’re intensive. This might be as a consequence of an addiction or as a consequence of a severe learning disability to give just two very different examples of many.

Specialised Supported Housing and Intensive Supported Housing are not dissimilar. If the requirement for Specialised Supported Housing to be privately funded by definition were removed, they would be practically identical.

Sheltered and Extra Care Housing is defined by the UK Government’s 2nd set of “Funding Supported Housing” consultation proposals. I agree that definitions of the people who live in sheltered/extracare shouldn’t be too prescriptive.

Wherever we are in the UK it is important that supported housing is an integrated part of the network of social and healthcare services that people need. Social care reform is on the agenda universally and it’s important that we inform the nature of change by putting supported housing front and centre.

Providing revised definitions of supported housing that focus on peoples’ needs is important in a context where such definitions are habitually geared to the management of a budget (“long-term”, “short-term” etc). I understand that money is important but it’s much better looked at as part of a Value Generation approach:

  • Outcomes for people
  • Cost benefit to the public purse
  • Wider social/community benefit

Cost alone is a very crude measure of the value that supported housing generates. Value Generation contextualises it better within a wider framework of measurement.

My next blog post in this “What is Supported Housing?” series will focus on funding supported housing.

Michael Patterson 18th May 2020

Categories
Policy

What is “Supported Housing”? (Part 1)

Supported Housing: A Victim of its Own Misdescription

As an advocate for supported housing I think it is important to think about what we actually mean when we think of “supported housing”.

In my experience it is certainly the case that supported housing has been and remains a victim of its own misdescription. We have allowed people and institutions, some of whom see themselves as advocates for supported housing, to impose their own limiting beliefs and definitions. We have allowed our vision of supported housing (and other preventative, enabling services) to be blurred by other agendas such as “cost control” in the commissioning of supported housing and the administration of public money. The preoccupation with the cost of everything and the value of nothing has led us to limit our own beliefs about what’s possible with supported housing and has helped to restrict its significance as an essential part of our social response to additional need.

Supported Housing, Health & Social Care

Supported housing is routinely seen as a disconnected, less important component of the social network of services people need. It’s not seen as an integral part of the wider social care agenda, which is its rightful place. Social care services throughout the UK are under immense pressure; there is both an opportunity and a necessity to talk about supported housing in a way that gives it the status it deserves but seldom gets as part of the solution to the UK-wide crisis in social care. 

The Scottish Government has taken steps to integrate health and social care in both structural and funding terms, but supported housing seems to be a separate matter. The Welsh Government is also focusing on health and social care integration and makes the link with housing and education without being very specific. Northern Ireland has integrated Health & Social Care Trusts, which cover residential care but not supported housing. The UK Government, on behalf of the otherwise ungoverned English, has said it wants to solve the social care crisis, but we have yet to hear any specific proposals. In all 4 constituent nations of the UK it is important to identify supported housing as fundamental to any vision of the structure of health and social care.

The next few posts to the Supported Housing Blog will focus on how we should define, fund, review, “measure” and regulate supported housing. The intention is to offer a view of the nature, scope and purpose of supported housing and its place within the wider agenda of social care.

What is Supported Housing?

The most obvious, and least helpful, way to see supported housing is as buildings in multiple occupation, owned or managed by a social organisation that were designed and developed to temporarily accommodate people with additional housing and other needs. It’s certainly true that such supported housing does exist, and so it should, but not at the price of limiting our thinking and peoples’ choices.

I’ve always considered that it is less about the building and the landlord and more about the people and their needs. For me supported housing is somewhere that someone with an additional need lives. It is supported housing for the duration of that additional need (and the length of time that someone is supporting the person to live there). Sometimes it’s permanent supported housing, sometimes it’s temporary supported housing: it all depends on what its occupants’ needs are

It shouldn’t matter whether it’s “social” housing, rented, owned, multiply occupied or solely occupied; whether it was developed and built as “supported housing” or just an ordinary house or flat

Furthermore, we shouldn’t make the damaging mistake of limiting how people see the scope of supported housing through careless definitions of its purpose and of the people who live in it, for example, as describing it as for “…people who need a bit of support”. Supported housing is for such people, but it’s also for people who would otherwise be in hospital, registered residential care or prison.

Neither should we allow the tail to wag the dog by giving different “types” of supported housing definitions based on timescales (“long-term”, “short-term”). Such definitions are based on a discredited “cost control” approach to managing the administration of the funding upon which supported housing depends. When looking to commission or fund supported housing “lowest unit cost” should not be a reason to fund it, it should be a reason to scrutinise more closely its outcomes in the context of Value Generation, which is defined as follows:

  • Outcomes (for people)
  • Cost benefit (to the public purse)
  • Wider social benefit (community sustainment)

Then we can have a much more nuanced idea of whether it should be funded. A crude dependency on cost control and the preference for lowest unit cost over all else prioritises the management of a budget over the needs of people. And it’s an expensive way of doing things too: when we fail to invest in preventative services such as supported housing, we pay a much higher financial price to fund otherwise avoidable healthcare, criminal justice, homelessness and other interventions as a consequence. And that doesn’t include the calamitous human cost of a failure to invest in prevention.

The funding bias in favour of “social” providers is a reflection of the lack of any proper regulatory framework for supported housing. The lack of dedicated regulation forces us to take false comfort from the fact that “social” organisations are often regulated by some agency or other (although not as supported housing providers per se). To assume that supported housing run by a social landlord will necessarily be cheaper or better than any other form of supported housing is an assumption borne of a failure to imagine how supported housing regulation and funding should work.

To Summarise

So, the story so far is that we are having to work and live with a system the fundamentals of which are in error.

We haven’t thought deeply enough about supported housing to conceptualise what it is in order to describe it properly. In order to describe supported housing properly I’m going to devote my next few blog posts on how we should 

  • define it
  • fund it
  • regulate it 
  • measure the quality of what it does.

It is important to take the opportunity to think in depth beyond the restraints of the system that currently defines and funds supported housing from a cost control perspective, which fails to regulate and measure quality in any meaningful sense.

Watch this space for weekly Supported Housing Blog posts that develop a definition of supported housing as part of the wider health and social care agenda. Please do comment on this blog post and share it widely.

Michael Patterson

May 2020

Categories
Supported Housing Management

Managing the Covid 19 Pandemic for Landlords & Providers of Social & Supported Housing

Summary

This Briefing seeks to provide information about Covid 19 to landlords and providers of social and supported housing.

It identifies “at risk” groups, explains why people are at risk and sets out (and adds to) the recently published “Social Distancing” guidance.

You can get the most recent daily updates on Covid 19 within the UK, EU & EEA here.[1]

It identifies the specific responsibilities that landlords and providers need to be thinking about and the actions you need to be taking.

It identifies Housing Proactive and Housing Proactive Plus as value generating interventions that are usually provided, installed and maintained, at nil cost (subject to welfare benefits eligibility) and that enable landlords and providers to increase human contact with tenants with additional needs whilst minimising infection risk and optimising staff deployment.

Introduction

I’m writing this Briefing whilst in self-isolation as a consequence of Covid 19 infection. Covid 19 impacts different people in different ways. For me my head throbs like a bell tower, my limbs ache, my voice strains through a throat that feels like I’ve swallowed a cheese grater, my chest is tight, and I am tired, really tired. But I’m writing this Briefing so I’m one of the more fortunate Covid 19 victims, and to be honest what bothers me more is the thought that my 96-year-old mother, or my son with learning disabilities might fall victim to it.

Being involved in supported housing, it is natural that the impact of Covid 19 on people with additional needs occupies my thoughts. People with a variety of additional needs are vulnerable to the physical effects of the virus, and also to the societal effects. Providers are struggling with the sheer enormity of what we are facing.

Part of the purpose of this Briefing is to suggest a solution that will genuinely help people. I’m a believer in things that generate value. Value Generation has 3 components:

  • Positive outcomes for people (with additional needs)
  • Cost-benefit
  • Wider social/community benefit

But before we look at a solution, let’s take the measure of the problem.

Who is Most at Risk?

Emerging data show clearly that the people at most risk from Covid 19 infection are older people, and people with lung, heart and immunological problems of any age. The UK Government/Public Health England guidance on social distancing (see below) lists a much wider community of “at risk” groups.

The primary cause of Covid 19 mortality is lung infection, and this isn’t limited to older people although they are more susceptible to such infection and also to general immunological weakness.

The second most common cause is cytokine storm, which is the technical term for an overreaction of the body to infection and is most common in people over 75. At that age peoples’ immune systems are less effective and can overreact to infection potentially resulting in fever and organ failure.

Older people generally suffer more than their younger peers from one or more chronic illnesses. Findings from China, Italy and the USA show that it is a combination of age and pre-existing chronic illness that makes people especially vulnerable to the worst consequences of Covid 19 infection.

Public Health England on behalf of the UK Government has produced a Guidance Document: “Guidance on social distancing for everyone in the UK and protecting older people and vulnerable adults[2] within which the following advice is given:

We are advising those who are at increased risk of severe illness from coronavirus (COVID-19) to be particularly stringent in following social distancing measures.
This group includes those who are:

How do we Respond?

Social landlords, their agents and provider organisations that operate accommodation-based (and other) services to people with additional needs should be mindful of the social distancing guidance document. Judging by our engagement with them they are very mindful of their obligations to people they house and support, but in common with society in its entirety they’re struggling with the enormity of the situation.

People are being told to self-isolate. People over 70, and those under 70 with a “chronic condition” (see the social distancing guidance) are being asked to do so for a period of 12 weeks.

Social isolation is harmful, especially for older people. It can result in high blood pressureheart diseaseobesity, a weakened immune system, anxiety, depressioncognitive declineAlzheimer’s disease……..”.[3] None of these conditions are good at any time, but with Covid 19 risk many of them become cast into sharper, more urgent focus. Social isolation exists, and is dangerous, without Covid 19 so any solution to help with it should be present after the Covid 19 threat has gone.

According to Age UK “…..more than 2 million people in England over the age of 75 live alone, and more than a million older people say they go for over a month without speaking to a friend, neighbour or family member.”[4] Many of these people will be social housing tenants in general needs and sheltered accommodation, much of the latter is now physically unstaffed.

It isn’t just supported housing that contains a multiplicity of vulnerabilities to Covid 19 infection. The population of so-called “general needs” social housing exhibits very significant levels of additional need. According to the ONS: “One-quarter (24.7%) of disabled people in 2019 rented social housing, compared with just 8.2% of non-disabled people.”[5]

We should be mindful of the “at risk” groups identified in the social distancing guidance, for example, age, respiratory disease, heart and kidney disease, “neurological” issues such as Parkinson’s Disease, Motor Neurone Disease, Multiple Sclerosis, learning disability, cerebral palsy, diabetes. Also sickle cell and spleen-related conditions, HIV/AIDS and other immunological deficiencies and obesity.

In addition, people with mental health needs, substance misuse needs and other conditions where self-care may be compromised may be susceptible to Covid 19. Homeless people, people at risk of domestic violence & abuse, asylum seekers and refugees and other needs groups are also more likely to slip through the medical/social net as well.

Housing Proactive/Proactive Plus

Housing Proactive is a telephone/tablet-based system that, at its most basic level requires users to press a button on their ‘phone or device that says, “OK Each Day” (supplied free) by a specified time of day, assuming everything is OK with regard to their property and tenancy in general. If a tenant doesn’t press that button by the agreed time, they get a ‘phone call from a real person asking them if everything’s OK at home. If they don’t pick up the call then a call is immediately made to the landlord, provider, family member or whomsoever has been agreed as the point of contact in such circumstances.

With Covid 19 the challenge for landlords and providers is to increase two-way social contact without infection risk. Housing Proactive does this by providing a telephone and/or tablet-based communication service that enables social landlords to communicate directly to individuals and groups of tenants verbally or by message. Similarly, tenants can contact you. In addition to letting you know they’re OK by pressing their “OK Each Day” button by an agreed time/times, they can also let you know they’re not OK.

Housing Proactive Tablet

Given the many changes in procedures required and challenges with staffing, the need to communicate quickly and effectively with people is critical, especially for higher needs and more at-risk groups.

Housing Proactive has an add-on capacity (known as Housing Proactive Plus) in the form of what’s called “Envosense”, which is a sensor that detects changes in temperature and humidity and alerts you when either or both are not what they should be.

Envosense Temperature & Humidity Sensor

As temperature falls in a home, blood pressure goes up – putting people at greater risk of stroke, heart attack or other cardiovascular problems. Furthermore, as temperature falls susceptibility to influenza, colds and other viral infections such as Covid 19 increases.

Housing providers may have a duty of care, particular in sheltered and supported housing where it is understood that tenants have higher needs and greater health challenges to ensure temperature ranges are in appropriate ranges.

Furthermore, excessively high temperatures in a property can be an indicator that someone is unwell (as they have turned their heating up in response), or might be an indicator that the tenant is at higher risk of energy related arrears.

Public Health England reviewed the literature on the impacts of temperature and humidity on people, older people in particular, and their findings are given sharper focus given the risk factors associated with Covid 19 infection discussed above:

“The evidence from the small number of epidemiological studies identified suggests an association between raised blood pressure with exposure to indoor temperatures of around 18°C or colder in the general adult population.

When the effects of cold in older people were compared with those in younger people, the studies showed in general that the changes in outcomes such as blood pressure, clotting factors, cholesterol and in core and skin temperature were more profound, with slower recovery, in older people. Several studies also demonstrated reduced thermoregulatory control and thermal perception/discrimination with ageing.

There are a number of quite serious health issues related to living to excess moisture. A relative humidity of 60 per cent or above provides optimum conditions for microorganisms and airborne allergens, such as dust mites or mould spores to thrive. Black mould in particular is highly toxic and can cause respiratory infections.

Our homes also suffer if humidity is too high. Excess moisture will rot wood, corrode electronics and appliances, spoil instruments or books, cause food to go stale, and trigger the proliferation of mould and mildew, which can damage wallpaper and soft furnishings, and even compromise the structural integrity of a building.

Maintaining a relatively constant humidity level indoors, between 40 per cent and 50 per cent, can bring great benefits. 

Below this, and influenza and other air-borne viruses can thrive – and are more easily transmissible, above this – mould, and other bacteria begin to thrive which can cause significant respiratory and allergic issues, impair the immune system, increase illness and begin to physically damage properties. Wood also rots faster at these higher humidity levels.”[6]

Landlords will know that the management of temperature and humidity in their properties is one of the obligations of the The Homes (Fitness for Human Habitation) Act 2018 and Schedule 1 of the Housing Health and Safety (England) Regulations 2005. Envosense as part of Housing Proactive Plus is an aid to compliance.

Staff Deployment

More efficient staff deployment is a necessity at times like this. Social housing and provider organisation staff are stretched at the best of times. Covid 19 adds the additional challenge of a social distancing requirement to reduce infection risk and higher staff demand. Using Housing Proactive enables social landlords and providers to deploy staff in a different way. They can focus on those people who they know are in difficulty for whatever reason because they didn’t press their “OKEachDay” button and they didn’t respond to the call from Housing Proactive’s call centre that would result from a failure to press their button. Similarly, tenants have the ability to call you if all isn’t well with their property or tenancy in general. Being part of an integrated system drastically reduces the necessity for face-to-face contact whilst actually increasing the level of other human contact and the mutual reassurance that goes with it.

That mutual reassurance is in place 24 hours every day, every week all year round.

Cost

The fundamental principle of Housing Proactive and Envosense is to enable the housing provider to manage their properties, tenancies and facilities more effectively and efficiently. As such it is Housing Benefit/Universal Credit/Pension Credit eligible, so people entitled to those benefits don’t pay for it and neither does the landlord/provider. The equipment is free; the installation is free (above a certain number of units) and there are no servicing or other costs. This is a Value Generation proposition that has a great deal of value to offer in a time of significant challenge. In addition to the direct benefits it brings in this time of unprecedented challenge it also provides important byproducts: a reduction in social isolation, more efficient staff deployment and the detection of changing needs. These factors will remain after Covid 19 has gone.

Please Get in Touch

Housing Proactive has an established track record and is deployed by 40+ housing providers across the UK for a variety of needs groups. We didn’t anticipate the Covid 19 emergency, but the fact is that Housing Proactive is in the right place at the right time to be part of your integrated approach to managing this unprecedented situation.

Remember that, subject to welfare benefits, eligibility it’s effectively free of charge. Even where people aren’t eligible for Housing Benefit/Universal Credit/Pension Credit it generates huge value for a minimal weekly cost.

Please click here to email us an inquiry or call Alertacall on 0808 208 1234 and mention this Briefing.

Michael Patterson 24th March 2020


[1] European Centre for Disease Prevention and Control Situation update for the EU/EEA and the UK https://www.ecdc.europa.eu/en/cases-2019-ncov-eueea

[2] Public Health England (March 2020):https://www.gov.uk/government/publications/covid-19-guidance-on-social-distancing-and-for-vulnerable-people/guidance-on-social-distancing-for-everyone-in-the-uk-and-protecting-older-people-and-vulnerable-adults

[3] US National Institute on Ageing, April 2019 https://www.nia.nih.gov/news/social-isolation-loneliness-older-people-pose-health-risks

[4] Age UK quoted in https://www.nhs.uk/conditions/stress-anxiety-depression/loneliness-in-older-people/

[5] Office for National Statistics: “Disability & Housing, UK: 2019” Housing outcomes for disabled adults, with analysis by age, sex, impairment type and country using Annual Population Survey (APS) data. https://www.ons.gov.uk/peoplepopulationandcommunity/healthandsocialcare/disability/bulletins/disabilityandhousinguk/2019

[6] Public Health England, 2014: “Minimum home temperature thresholds for health in winter – A systematic literature review” https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/776497/Min_temp_threshold_for_homes_in_winter.pdf

(Added to site Tuesday, March 24th, 2020)

Categories
Finance & Funding

Funding Intensive Housing Management

Many of you will know what “Intensive Housing Management” is. It’s a term that the old Housing Corporation in England used to describe the additional housing management services that people in supported housing often need. Intensive Housing Management services were funded by the Housing Corporation through a revenue grant known (latterly) as SHMG (Supported Housing Management Grant) some of which was often paid on by RSLs to their specialist agency partners that typically manage the RSL’s supported housing.

The set of prescribed intensive housing management services was defined in hardcopy in the Housing Corporation’s “Guide to Supported Housing”, before the age of the Internet. There is a similar list you can gain access to online here: in Scottish statutory instruments 2002 number 444 with its list of “Prescribed Housing Support Services” in Regulation 3.

The revenue funding streams for intensive housing management were put into the Supporting People pot in 2003, to help fund what became known as “Housing Related Support”. And that, you might think, was the end of that.

Except that it wasn’t. Supporting People begin to retrench very quickly. In 2005 Michael Patterson and Danny Key teamed up to identify and promote a regulatory means of mitigating providers’ losses of Supporting People revenue, by claiming the cost of eligible Intensive Housing Management tasks from Housing Benefit. This involves the use of the Exempt Accommodation route to enhanced levels of Housing Benefit. 

Over time this led to a substantial number of eligible providers (housing associations and voluntary agencies namely) being able to claim enhanced levels of Housing Benefit for the costs of the eligible housing management tasks Supporting People no longer funded.

Michael Patterson renamed these eligible housing management tasks as “Intensive Housing Management”, a term which has returned to the language of supported housing, bringing with it a substantial pot of revenue known as enhanced Housing Benefit, which continues to exist to this day.

As someone with a values base I commend the “Exempt From Responsibility?” report written by Thea Raisbeck in November 2019 for Spring/Commonweal Housing, which identifies problems over the lack of regulation of supported housing, and the oversight of the system through which some landlords claimed enhanced Housing Benefit. To put it more bluntly: some unregulated supported housing providers are claiming Housing Benefit but apparently not providing adequate housing or intensive housing management services.

Not all supported housing providers are eligible for intensive housing management funding, but most social supported housing providers are. Rather than go through the criteria for Exempt Accommodation compliance here (but watch this space) just ask yourself these questions:

  • Are you a genuinely social organisation? (For the purposes of enhanced Housing Benefit this means nonprofit)
  • Do you generate value?
    • Outcomes for people
    • Cost-benefit
    • Wider social benefit (Community Sustainment)
  • Do you own or manage supported housing?.

If you can say yes to the above questions you’re likely to be eligible to claim Intensive Housing Management and Maintenance funding. It’s a complex process that requires you (or me on your behalf) to audit your supported housing and provide a properly optimised rent structure that you can use to support an enhanced Housing Benefit claim. I have a useful spreadsheet for your revised rent structure that you can continue to use into the future.

If, on the basis of my rent structure, you decide you want to claim Intensive Housing Management and Maintenance funding you can negotiate with the local authorities you work with, on your own. Or you can ask me to refer you to Support Solutions, the leading experts in enhanced Housing Benefit negotiation.

If you decide to work with Support Solutions you won’t have to pay my fee for devising the rent structure. Support Solutions will work for you on a “no increase, no fee” basis, taking only a percentage of the increase they achieve, for one year only.

It’s also important to consider the likely future funding of Intensive Housing Management and Maintenance, and supported housing in general for that matter. I’ll keep the wider context for a future blog post/briefing but what about the Intensive Housing Management components of supported housing revenue, currently paid as enhanced Housing Benefit?

We should bear in mind both the implementation of Universal Credit and the UK Government’s (stalled) “future funding of supported housing” policy agenda.

Universal Credit allows supported housing claimants to have the housing component of their Universal Credit paid by local Housing Benefit teams as enhanced Housing Benefit. The future funding of supported housing policy agenda originally intended to pass supported housing revenue, of which Intensive Housing Management funding is a substantial part, to local authorities but that idea was parked.

Nothing much has happened on the supported housing policy agenda due to the UK Government’s preoccupation with Brexit and the current Covid 19 pandemic. But the UK Government is working on a Social Care Bill, and they would be remiss to omit supported housing from it.

It seems opportune therefore to remind the UK Government and the wider sector that Intensive Housing Management funding needs to stay exactly where it is now – as a flexible component of Universal Credit.

Going back to the “Exempt From Responsibility?” report, and my own briefings for Support Solutions going back some years, it’s not just about the future funding of supported housing, important though that is. It’s also about supported housing regulation, it’s about how we define supported housing and it’s about what values base we apply to supported housing.

I’ll be publishing more blog posts and briefings in future you can see and follow my blog site (supportedhousing.blog) Please also follow me on Twitter at @MPattersonLtd

I’ll be following up this blog post with a briefing on Intensive Housing Management and Maintenance, co-authored with Danny Key of Support Solutions. Watch this space!