I am writing to you to thank you for inviting me as CEO of Women’s Aid to give oral evidence to the Select Committee for its inquiry into exempt accommodation.
On behalf of Women’s Aid, I welcome your commitment to ensuring that the impact of women and children fleeing abuse, who constitute a large proportion of residents in exempt accommodation, are considered for your review into viable reforms of supported housing arrangements. Thank you for the opportunity to provide further detail to the Committee on the severe risk presented by the weak definitions and regulatory chasms underpinning the existing model for exempt accommodation to survivors of domestic abuse.
Women’s Aid, along with other experts from the housing and domestic abuse sector, have witnessed a rapid increase in the emergence of new exempt accommodation providers in the last two years. As has been made apparent through your Committee’s oral evidence sessions, exempt accommodation has long been identified as a complex and difficult to administer area of Housing Benefit. Exempt accommodation is open to administrative error and variable interpretation, and hampered by loose criteria which is interpreted in wide-ranging ways, with a high risk of landlords or providers claiming excessive rents whilst providing inadequate accommodation and support.
As noted in the oral evidence session, it is clear that problems with supported housing derive both from under-regulation and incorrect or confusing regulation. This must be addressed through stronger and clearer guidance. We recommend that the Department for Levelling Up, Housing and Communities (DLUHC) issues a specific directive to local authorities to withhold enhanced housing benefit from providers of specified or exempt accommodation targeting women experiencing domestic abuse where:
I. They are making profit, or there is evidence of a connection with profit-making organisations;
II. Survivors or local specialist services providers raise safety concerns;
III. They have no experience of, or are unable to evidence, safeguarding or risk assessment in cases of domestic abuse.
We have also called for the National Statement of Expectations for Supported Housing and National Statement of Expectations for VAWG to be strengthened to enable local authorities to address unsafe and dangerous housing provision, utilising findings from the exempt accommodation pilots, and in consultation with specialist domestic abuse organisations.
To address the lack of regulatory oversight, the Housing Benefit and Universal Credit (Supported Housing) (Amendment) Regulations 2014 should specifically exclude providers that do not meet recognised quality standards; do not provide single sex, secure spaces; and do not deliver dedicated support to survivors of domestic abuse, from the definition ‘other forms of emergency accommodation’.
Crucially, as I shared with the Committee, whereas refuge services’ core business is to support women and children impacted by domestic abuse, the majority of unregulated providers employ a ‘business model’ that relies on claiming higher levels of Housing Benefit, and therefore have no incentive to move women on to affordable housing. DLUHC should therefore guarantee that no further funding is delivered to those without recognised expertise or the ability to provide quality, wrap-around holistic support, in the sectors in which they serve. In the case of domestic abuse survivors, this means that providers housing women and children fleeing domestic abuse, regardless of whether they claim to be a refuge or not, should not be allowed to do so without clear safeguarding and recognised quality standards.
Whilst commissioned providers often have comparably higher standards of support, the binary between commissioned and non-commissioned in determining quality should not be overemphasised. There are many specialist domestic abuse services which are not commissioned by their local authority but which provide excellent care and support. Women’s Aid’s Annual Audit 2022 highlights that just under one in five (18%) were not commissioned on May 2021 by the local authority and were surviving on emergency government funding pots, charitable grants, trusts and other fundraising activities. A disproportionate number of these spaces are run by specialist ‘by and for’ services for Black and minoritised women.
The ‘hidden heroines’ across our national network of refuges worked tirelessly throughout the pandemic to ensure that women and children were free from abuse, a significant amount of which were not commissioned by their local authority. Any remedy for poor quality provision should therefore ensure that specialist non-commissioned providers, who are disproportionately specialist ‘by and for’ services, are able to continue providing safe and supportive care to the communities they serve.
I hope to continue working with your Committee to ensure that the regulatory oversight of exempt accommodation fosters a safe and stable environment for the most vulnerable members of society, including survivors of domestic abuse.
May 2022