Housing Benefit and Supported Housing: Consultation 19 th August 2011

1. Housing Benefit and Supported Housing: Consultation 19th August 2011 Yvette Burgess Unit Director

2. Introduction • Acknowledgements • Purpose & objectives of today • Introductions

3. Housing Benefit Reform-Supported HousingPublic Consultation July 2011 Peter Meehan LA Benefits Adviser

4. Why change? • ‘As we move towards the Universal Credit in 2013 we need to consider how supported housing costs can be met and whether they should be based on Local Housing Allowance principles’ Summary, bullet point 4, page 6

5. Current HB provisions • For council sector tenants; full HB normally paid covering contractual rent including and management overheads ( but less ineligible services) • For HA, registered charity or voluntary organisation where personal care, support or supervision is provided (exempt accommodation) ; generally higher levels of HB are payable under exempt accommodation provisions.

6. Exempt Accommodation? • The claimant must be elderly( ie aged 60 or over), unable to work or have dependant children. • Landlord must be registered HA, charity or voluntary organisation • Some personal care, support or supervision must be being provided • There is no cheaper suitable alternative accommodation available. • Distinct HB Subsidy rules and rates • Can be referred to the Rent Officer

7. Additional costs of supported accommodation? • Purpose built or specially acquired to meet needs of residents • Adaptations for disabled • Adaptations to provide suitable facilities for communal living and support ( eg security etc ) • More expensive communal quality fixtures and fittings coupled with greater wear and tear and higher maintenance costs • Staffing overheads involved in provision of intensive housing management

8. Reform Objectives? • Control levels of rent for HB/UC payments • Target those in need • Transparent and simpler to understand and administer • More certainty and consistency regarding levels of benefit entitlement • Flexible • Compatible with Universal Credit so that it can be delivered centrally

9. Two groups • Those who commonly need lower levels of personal care and support…such as hostels, refuges, foyers and purpose built sheltered housing • Those who often need more intensive levels of personal care and support to help them live in the community…which is often provided in housing specifically built, acquired and/or adapted for the individual tenant(s)

10. Group 1Conventional Supported Housing • A payment based on Local Housing Allowance with an addition that recognises the higher housing costs ( e.g. by allowing an extra room, by increasing the LHA by a percentage or by basing it on a broad average of actual costs provided by the Rent Officer). • Included in the Universal Credit and paid to the claimant 4 weeks in arrears.

11. Group 2Specific Supported Housing • An accommodation element, based on Local Housing Allowance rates, included in the claimants Universal Credit and paid to the individual • A separate application for a payment from a new Supported Housing Fund, provided to and administered by the local authority, to meet the additional housing costs.

12. Group 2Specific Supported Housing Fund • Expenditure ‘constraints’ • Overall policy responsibility remains with DWP • ‘Fixed’ funding controlled by limits on individual payment levels or by rent officer assessment • Initial ‘estimate’ based allocation with year end adjustment for actual expenditure • Paid direct to the landlord

13. Group 2An Alternative (Wider) Approach • An accommodation element, based on Local Housing Allowance, included in the Universal Credit • An additional allocation determined as part of a more holistic approach to the needs of the claimant, administered in the same way as Personal Budgets ( ie paid to the claimant along with other special need payments so that they can decide where and how it should be spent)

14. Other proposals • Registered providers treated in the same way as registered social landlords ( ie HB based on contractual rent less ineligible service charges) with option to refer to the Rent Officer • Review of service charges for HB with a more specific approach focussing on what is eligible as opposed to what is ineligible.

15. Issues/Risks • Direct payment of UC to claimants=rent arrears and increased collection overheads • Council Tax liability in HMOs? • Cash limited budget vs demand led expenditure? • Ring fenced or not and comparisons with Supporting People experience • Shared Accommodation restrictions and under-occupation reductions • Role of the Rent Officer • Migration timetable for new and existing claims • etc,etc,etc,etc,etc,etc,etc

16. Development Bottleneck in 2013/14 • New local Council Tax Support scheme • Introduction of Single Fraud Investigation Service • Introduction of under-occupation reduction in social rented sector • Introduction of new subsidy arrangements for Temporary Accommodation • Introduction of new Supported Accommodation funding arrangements • Localisation of Social Fund and Community Care Grants • Replacement of DLA • October 2013-introduction of Universal Credit

17. Responding to the DWP & questions posed in proposal

18. ‘Conventional supported housing’ • Types of supported housing – identifying types and grouping together • Different rates for each type in different areas? • Additional activities typical in supported housing? Weekly amount per unit? Flat rate or another way of working out?

19. ‘People with more specific housing needs’ • What type of supported housing would fall into this category? • What are the types of higher housing costs • Should ‘additional help’ be met by separate fund within council’s commissioning team? Who should administer?

20. Personalised budgets • Would it be a ‘step too far’ to separate out costs of ‘extra help’ associated with supported housing and take out of HB altogether? • Would this work only for people living in ‘specialised or adapted properties’?

21. RSLs and supported housing • Should supported housing be referred to Rent Officers? • Should the 3 types of supported housing be treated differently? • Is the referral process for mainstream rents suitable for supported housing? • Service charge review (this sector only) – not covered by regulation – would list of eligible services be helpful?

22. Impact assessment: use of local reference rents An example from one HA: Shared flat : 80% shortfall 1 bed flat: 71% shortfall 2 bed flat: 114% shortfall

23. Impact assessment: possible use of LHA A sheltered housing example looking ahead to possibility of future use of LHA: • Where HB covers rent only, 88% of flats would face monthly shortfall between £143 (33% of total cost) - £203 (47% of total cost) • Where HB covers rent and service charge in line with LHA, 68% of flats would face monthly shortfall between £36 (8% of total cost) - £166 (39% of total cost)

24. Transitional arrangements • How should the changes be introduced? • Should LAs maintain a role in signing off rent + service charge levels before passing across to the DWP (suggested by Cymorth Cymru)

25. UK wide response to the proposals • Concern about defining supported housing in the way laid out by the DWP • Concern about housing costs being included in Universal Credit: • DWP to administer instead of local authority • Risk that system would not recognise supported housing

26. Do we want to put other suggestions forward? • Defining supported housing • How to promote reasonableness in rent and service charge levels without leaving people with support needs with a shortfall to cover

27. Consultation • DWP Consultation document at: http://www.dwp.gov.uk/consultations/2011/supported-housing.shtml • Deadline 9th Oct • To have an input into SFHA / HSEU submissions please contact either by 30th September.

28. Keep in touch! HSEU: www.ccpscotland/hseu/org yvette.burgess@ccpscotland.org Tel 0131 229 9468 SFHA: http://www.sfha.co.uk/ dogilvie@sfha.co.uk Tel 0141 332 8113