Public Accounts Committee Supported Housing Inquiry evidence
Coventry City Council welcomes the Committee’s Inquiry into Supported Housing. Coventry, like many other metropolitan areas, has seen a growth in the number of exempt supported accommodation units. In Coventry there has been a rise of 900 units between 2018/19 and August 2022 (2018/19 2828 units/August 2022 3705 units) in the city with the majority operating outside of a commissioning framework. The provision is mainly targeted at those experiencing multiple disadvantages. Although there has been a small growth in reputable organisations operating in the city there are a number who are new to the sector with limited or no track record of providing a similar type of accommodation.
The evidence provided by Coventry will aim to showcase some of the collaboration between statutory partners that has led to improved outcomes. The evidence will also highlight several ongoing issues where Government intervention and influence is required to improve opportunities. The Supported Housing Bill, that lays out changes to exempt housing is also discussed as part of the evidence and Coventry pose points for the Committees consideration.
Outlined below are examples of the issues the current Supported Housing legislation and practices present for Coventry and similar local authorities.
Concentration of complex individuals
A current issue in Coventry is the number of former student HMOs on the market as investment opportunities and many of these being utilised for supported accommodation. The majority of HMO’s, and therefore exempt supported accommodation units are situated in pockets within the city alongside existing commissioned and temporary accommodation provision. With Serco and the probation Service (CASS 3) also procuring properties in similar areas of the city, this results in high numbers of complex individuals in small geographical areas thus placing pressure on local police and community safety resources.
During a recent example the council had significant issues with 2 providers that resulted in a multi-agency response that included:
As a consequence, the demand on public sector resources is significant and given current funding pressures, is unsustainable.
Referral pathways
Where there are known issues with a provider the local authority does cease referrals. However, the local authority has little control over who other services refer to and a limited understanding of referral routes, assessment processes and risk. Additionally, if voids are not filled locally then providers will widen their referral pathways to organisations and individuals from outside of Coventry. This can result in groups of incompatible, complex people being housed in a single location. Coventry recently experienced a challenge with a new provider in the city who acquired 40 units in close proximity to a number of existing HMO/ exempt dwellings. This led to the need for a multi-agency response to deal with the levels of ASB (Anti-Social Behaviour), criminality and safeguarding concerns in the area. There are significant impacts on residents in the area as a result of this clustering of provision resulting in community cohesion issues. Where tenancies are ended or fail additional pressure is also added to local authority commissioned services, front line homelessness service as well as the rough sleeping outreach provision.
HMO licensing
Local authorities are facing significant HMO licencing pressures. Many providers have not or do not believe they need an HMO license to operate thus are operating without one meaning that enforcing licence conditions is more difficult. Consequently, the growth in HMO style accommodation puts additional pressures on the Council's housing enforcement team.
Housing Benefit implications
The burden of non-registered providers continues to be a strain on local government finances. The costs associated with Housing Benefit subsidy are significant for Coventry. The subsidy loss because of non-registered providers establishing Supported Housing accommodation in the city is in the region of £2.5m per year. The table below outlines the headlines.
Year | Number of providers | Number of units | Registered Providers | Non-Registered providers | HB expenditure | Subsidy loss |
2022-23 (August) | 51 | 3705 | 311 | 158 (34%) | £8,904,392 (26.08.22) | £2,504,196 (Est) |
2021-22 | 49 | 3601 | 306 | 150 (33%) | £19,919,708 | £2,219,571 |
2020-21 | 46 | 3201 | 286 | 97 (25%) | £16,175,198 | £1,579,058 |
2019-20 | 41 | 2939 | 263 | 78 (23%) | £15,207,464 | £1,354,019 |
2018-19 | 38 | 2828 | 248 | 76 (23%) | £14,093,020 | £1,087,557 |
Data sharing and departmental collaboration
It is Coventry’s experience that data sharing across government departments is poor. This results in local authorities not having a clear picture of providers and those residents using Supported Housing. Improvements should be considered in relation to inter agency data sharing to better enable a holistic view of service users and providers across localities.
As different public bodies refer individuals to supported accommodation it is vital to share data about service users. For example it is Coventry’s experience that the Probation Service will look to source accommodation for prison leavers with complex needs. There is no systematic collaboration with other public bodies – such as the Police or Local Authority – to assess the wider implications of housing individuals with a particular provider or in a particular locality. The availability of shared data records would make the transition much better for both the service user and the statutory partners.
Outlined below are some examples of Coventry’s experience of good practice in relation to Supported Housing provision, which the Committee may find helpful during their Inquiry.
Effective multi agency working
Improving provision and outcomes for those accommodated in exempt supported accommodation is reliant on effective multiagency working for both on-going operational delivery of provision, and responsiveness to resolving issues and concerns. It is Coventry’s experience that when providers are part of the wider partnership in areas where they operate, the outcomes for individuals improve and, in many situations, successfully move on to independent tenancies that are sustainable.
When responding to issues and concerns in relation to provision, a multi-agency response that includes both internal and external partners allows for coordinated actions to be taken simultaneously in relation to the property and the quality of support. This is achieved whilst also ensuring value for money for the public purse.
In Coventry it was recently necessary to mobilise a multi-agency response in respect of concerns raised by partners and individuals regarding a particular provider. By working collaboratively, it was possible to not only ensure the wellbeing and safety of the individuals accommodated but also take quick, appropriate action regarding the property. This response also resulted in partners being able to clarify inaccuracy in charges that were being claimed by the provider for their services. By sharing information and collaborating with external agencies, including the police and fire service, the council were able to withdraw the providers exempt provider status. This was because there was clear evidence the provider was not meeting the basic requirements to be classified as an exempt support provider. As a consequence, this fraudulent activity was stopped and public finances benefitted, with limited impact on service users.
Though we welcome the introduction of the proposed exempt accommodation powers that have been laid out in the Supported Housing Bill the unintended consequences that may be realised with its implementation should be better considered by the Government. The risks the changes pose in terms of the potential increase in homelessness and rough sleeping for complex individuals needs to be mitigated before the bill is progressed.
The introduction of the recommendations and tighter controls will clearly improve standards; however, it is also likely to mean that several providers leave the market. This is due to increased administrative burdens and the costs associated, whilst others will no longer be able to operate as they no longer meet the required standards. We know from our own experiences that exempt providers often accommodate people whose housing options are extremely limited. It is Coventry’s experience that our exempt provision does not carry voids, thus illustrating a need for the bed spaces it provides.
If the number of providers operating decreases, there will be a reduction in available bed spaces that are currently operating at capacity. At a time when there is a cost-of-living crisis as well as a national housing crisis a reduction in accessible accommodation for those who have been traditionally housed within this sector will have a huge knock-on effect to both the statutory housing service and increases the risk of street homeless. Safeguards will need to be considered in terms of reduction of provision and alternative options explored and provided to mitigate this risk.
As part of the Inquiry the Public Accounts Committee will want to consider:
Coventry would like to thank the Committee for inviting representations from local authorities in relation to this key policy agenda. Should the Committee have any questions in relation to the experiences of Coventry we would welcome further correspondence.