Official

Written evidence submitted by Royal College of Occupational Therapists Specialist Section in Housing [DPH 007]

The Specialist Section in Housing are submitting this evidence due to our specific role in working with disabled people in their own homes and communities, seeing the daily barriers created by unsuitable and inaccessible housing. Housing Occupational Therapist roles vary but usually involve working with a range of housing providers and departments to ensure disabled peoples’ voices are heard and accessible housing stock used effectively, often liaising with colleagues in Health and Social Care. We also work with strategy, planning, building control, developers, designers, surveyors, contractors etc to oversee the design of new build housing from pre-planning to completion and undertaking post occupancy evaluation (POE). POE of housing is rarely undertaken by Built Environment professionals, so we provide valuable, evidence-based insight to influence lessons learnt and improve designs going forward. Our role provides significant resource savings in a variety of ways, as detailed below.

 

  1. What can the Government do to ensure disabled residents across England have access to accessible and adaptable housing?

 

Many of the recommendations below for disabled people echo those for older people, such as the 2019 Parliamentary Inquiry into Housing for Older People and the 2021 Centre for Ageing Better’s Good Home Inquiry, most of which have not been acted upon but which are wholly relevant to this inquiry.

1.1 Set up a Cross Party Housing Task Force to agree a Housing Strategy for Disabled People

It is imperative to adopt a genuinely holistic, inclusive approach to ensure all voices are heard, particularly disabled people. All stakeholders involved in the procurement and design of housing should come together gain an understanding and agree a way forward.

1.2 Mandate for M4(2) and M4(3) (see below)

Government to implement the mandating of M4(2)’ Accessible and Adaptable for all new housing, 10% to M4(3) Wheelchair user, and Nationally Described Space Standards. This has been policy in London since 2004., having undergone independent viability testing, so placing disabled people across much of England at a disadvantage.

1.3 Set up an Information, Advice and Advocacy Service

There is currently a complete lack of accessible information, or dedicated organisations to provide assistance and advocacy on housing options (across tenure). In desperation disabled people are often pushed towards their local authority (LA) when they may not otherwise choose or need to, may not meet qualifying criteria and not be appropriately signposted - partly as LA’s do not have information either.

There should therefore be a national, independent, housing information, advice and advocacy service led by disabled people with the support of professionals including Occupational Therapists. This could assist in addressing the points highlighted below.

1.4 Review Housing application and assessment processes

Currently most accessible housing is provided via social housing providers and disabled people are much more likely to live in rented social housing.  Historic policies requiring grant funded housing met access standards ceased with the introduction of 2105 Part M Volume 1, unless an LPA requires the optional categories M4(2) and M4(3).

Research from Habinteg shows that there are approximately 20,000 waiting for a new build M4(3) home (47yr wait) and an estimated 104,000 for M4(2) and only half the LA’s could supply data. The EHRC 2018 report ‘ Housing and Disabled People: Britain’s hidden crisis’ found that disabled people are demoralised and frustrated by the housing system.

It is therefore critical that accessible and adaptable housing is available to the people that need it . Despite this there are significant barriers such as a lack of information, trained/dedicated staff, online application and bidding system and medicalised assessment processes which do not understand how a person’s impairments impact daily living so fail to acknowledge impact of poorly designed housing and neighbourhoods. ‘Medical’ assessments may also tend towards refusing priority to go on waiting lists due to limited availability of accessible/adaptable housing which worryingly leads to LPA’s not correctly evidencing need when determining local planning policies for accessible housing.  This in turn puts unnecessary pressure on DFG budgets where people try to adapt homes which are unable to provide the same levels of access as new build M4(3).

Some LAs recognise the benefits of employing experienced professionals such as Housing O.T’s. Their person-centred, realistic, solutions-focussed approach and understanding of the daily barriers disabled people face due to inaccessible housing assist in providing advice/advocacy, realistic input into decision, provide evidenced based recommendations on the type of property a person needs, so assists with appropriate allocations. Their role helps streamline processes, provides disabled people with the appropriate help so can reduce unnecessary frustrations, appeals and reviews. Having an overview of people waiting for accessible housing and liaising with social care/health/housing colleagues also enables OT’s to provide the LPA with genuine data to evidence need for accessible housing. This is particularly useful where the Housing OT is involved in the design/provision of new build housing from pre-planning and liaises with planning, strategy and development colleagues, so can ensure what is built meets evidenced need.

1.5 Improve methods of identifying and letting accessible housing

It is imperative to ensure that accessible properties are let to those who need them, particularly when housing providers say they cannot find anyone, despite research showing an evidenced need. Landlords generally have limited information on the accessibility of their housing stock, including those which have had adaptation/DFG monies spent to meet the needs of disabled people. (To note - an ‘adapted’ home is not necessarily ‘accessible’ and will rarely meet the needs of wheelchair users due to limited circulation etc) so it is critical properties are appropriately identified.

A solution is to set up an Accessible Housing Register (AHR), as explained in the EHRC Housing for Disabled People ‘Allocations’ toolkit, referencing the London Accessible Housing Register (a project with specific input from Housing OTs) which provides a framework for collecting information on the accessibility of properties, categorising them to enable easy identification and help match individual with properties, and ensure property attributes are appropriately advertised. Whilst the categories are dated, the principles are the same.  Developing an AHR does not require a full stock survey (and helpful to know that properties above ground floor without a lift will be discounted) and properties can be categorised when they become ‘void’/ready to let instead.  There is a general lack of understanding as to their significant value, with landlords citing concerns about lack of expertise and limited resources. It is recommended that Government mandate for AHRs with updated guidance and training. An example of a project set up to assist social housing providers let wheelchair housing is the Habinteg and Homefinder UK Accessible Now project with input from wheelchair users and a housing OT. 

Employing a Housing OT can ensure quick, appropriate assessment and allocation of accessible properties (avoiding non-disabled people being allocated accessible properties), reduce void turnaround times and ensure best use of public monies including avoiding adaptations being ripped out unnecessarily. This includes liaison with property services/surveyor teams, assessing properties using checklists to ensure accurate categorisation and advertising or matching people from the waiting list. A Housing OT may visit when a person views a property to ensure it meets their requirements and some provide monies to adapt the property up-front, avoiding referrals to Social Care OT and associated delays. This saves significant resources as highlighted in the EHRC toolkit where a wheelchair user had to be placed in a nursing home at a cost of £56,000 due to a lack of availability of accessible housing. The Housing OT identified a ‘void’ property which was adapted at a cost of £23,000 meaning the family could all live together, he could live independently and return to work, saving not only the LA a significant outlay but much broader resource savings – as identified in Habinteg’s 2023 LSE research. This is a common part of a Housing OT role including matching disabled people with empty properties that have already been adapted A recent example was a LA moving 3 families to adapted properties, avoiding DFG funding for 3 ground floor extensions (at least £90K due to upper limit).

1.6 Improve and update information relating to other Affordable tenures

The Government’s shared ownership HOLD initiative offers applicants with a long- term disability the opportunity to buy shared ownership (SO) homes. It is extremely valuable and recognises that not all disabled people want, or need to, go on waiting lists for social housing. However aspects such as the deposit, and amounts of earnings need to be clarified to avoid discriminating against disabled people who want to live and work in certain locations.

Advertising of new build ‘affordable’ M4(2) and M4(3) such as HomesforLondoners provides a ‘wheelchair accessible’ search but due to a lack of critical information, properties are not sold to the people who need them. This type of platform for Affordable housing therefore needs to be improved and provided across England (see below)

1.7 Improve information and identification of accessible/adaptable housing for rent

Disabled people may have to rent privately and/or be able to purchase their own property, yet it is very difficult to obtain accurate information on a property’s accessibility. Relevant information is critical so as a result disabled people are indirectly discriminated against under the Equality Act. There are an increasing number of websites/organisations available, with some training national estate agents/landlords to improve this situation but there is still a general lack of information despite the recognised spending power of the Purple Pound, and disabled tenants in the private sector being more likely to remain in a tenancy etc.

Initiatives described above relating to AHR’s in the social rented sector could equally apply in the private sector if directed to do so and provide significant savings to DFG budgets. RCOTSS-Housing also worked with stakeholders and the National Residents Landlords Association to produce good practice guidance on adaptations,  explaining that landlords do not have to fund them, nor should they appear clinical, so improving overall marketability.

1.8 Positive Marketing of M4(2) and M4(3) new build homes

When M4(2( and M4(3) homes are built for rent or sale, people are often unaware of their beneficial design features including step free access, more circulation space, ground floor WC/cloakroom, adaptable bathrooms, even more so for M4(3). These significantly reduce health and care costs by enabling a person to remain in their home longer due to reduced reliance on care/assistance, being able to be discharged from hospital more quickly, reduced disruption and cost of adaptations. They also improve a person’s dignity, health and wellbeing, reduce loneliness and isolation through being able to get out, having visitors and 4 times more likely to be in  work.

It therefore makes good marketing sense to notify occupants of the property attributes in mainstream advertising material (not only specialist disability advertising where disabled people may never look). It is imperative, particularly for M4(3) properties, that disabled people can make an informed choice, so require details on accessible transport/amenities/parking, lift access, floorplans, photos, video tours.

Some L.A. Housing OTs oversee the design and build of private M4(3) homes and work with LPA’s to place planning conditions on developments to market M4(3) homes appropriately. This avoids Developers saying they cannot sell/let homes where on further scrutiny they have not marketed them as wheelchair adaptable, provided no/insufficient detail, or not designed them appropriately so that a wheelchair user cannot occupy them, as explained in this blog.

1.9 Employment of Housing Occupational Therapists

As explained throughout this response, the role of a Housing OT can add significant value, partly due to working with a variety of departments and stakeholder organisations but also their unique person-centred approach and insight from working with disabled people in their own homes/neighbourhoods to gain an understanding of the daily barriers they face due to unsuitable, inaccessible housing.

 

2.Does the National Planning Policy Framework ensure the Equality Act 2010 is complied with when building housing?

 

Only 9% of English homes offer basic ‘visitable’ standards yet the NPPF currently has no national planning policies requiring M4(2) and M4(3).

The 2018 EHRC inquiry ‘Housing and disabled people’ findings indicate that not much has changed and disabled people still face the same discrimination, also highlighting that the  principles to independent living enshrined in the UNCRPD were being undermined. This lack of progress by Government was highlighted in a recent EHRC report on the Progress on disability rights in the UK submitted to the United Nations.

Other relevant aspects in the report were for Government to assess how the Public Sector Equality Duty is complied with, and that the Planning Inspectorate should place more emphasis on meeting its obligations under the Public Sector Equality Duty when dealing with the examination of Local Plans

 

  1. Since the Government consultation ‘Raising accessibility standards for new homes’ (July 2022), what has been done to improve housing provisions for disabled residents in England? And has it been sufficient

 

 

  1. What role should the Government, Local Authorities and developers have for ensuring the delivery of suitable housing for disabled people?

 

Government

 

Local Authorities

The points above also relate to LA’s, so are not repeated below.

How do we make our housing stock ‘friendly’ to older and disabled people? (foundations.uk.com)

EXCLUSIVE: A day in the life of a specialist housing OT - AT Today - Assistive Technology

 

Developers

 

  1. Does the DFG fully support housing adaptations?

The Disabled facilities grant is a rare example of mandatory grant that plays a hugely important role in the removal of barriers in people’s homes, supporting personal independence, reducing falls and improve their health and wellbeing, there is strong evidence that installation of timely adaptations provides system wide benefits to the Health and Social care services.

 The increase in the capital DFG grant is welcome and has doubled since 2015.  However, the grant process is multiagency and bureaucratic and there has not been a commensurate increase in staff across agencies (Occupational therapists, trusted assessors, grant officers, case workers, technical officers) to be able to increase the throughput of cases. 

Waiting lists for adaptations in England are deeply troubling and there are often long delays waiting for each agency in the same case.  Difficulty remains recruiting and retaining Occupational Therapists and other technical staff involved in the DFG process and disparity in pay can be unattractive between the private and public sector. 

The audit commission historically had responsibility for regulating adaptations services but this is no longer the case and there would appear to be very little or no central monitoring of the delays and difficulties people with disabilities face accessing the grant.  This is evidenced by the increased number of referral to the Local Government & Social Care Ombudsman.

The rights of disabled people to access the grant is set out in the Housing, Grants Construction and Regeneration Act (1996) but this legislation is 27 years old and the whole system needs urgent review.  The administration of the grant places duties on both social care and the housing authorities and they have a duty to consult each which can cause delays.

The importance of accessing adaptations swiftly is set out in the Governments white paper where access to services is acknowledged as critical to provide choice and control.  Despite this, long delays for adaptations remain.  The Royal College of Occupational Therapists and partners published the report Adaptations without delay to find solution focussed ways to reduce the delays waiting for OT assessments.  Trusted assessors for simpler cases are encouraged but the uptake of these recommendations across the country has been patchy.

Foundations is doing important work in this area to promote the use of trusted assessors more widely across the country.

The DFG legislation only extends to meeting the needs of those with physical disability (as defined in the 1948 National Assistance Act) as set out in the purposes that govern the uses of the grant.  Urgent review is overdue to consider the needs of those with disabilities arising from sensory needs, learning disabilities, emotions expressed through behaviour, neuro divergence and mental health problems who also require changes to their environment to reduce the barriers to engage them in meaningful activity.

The mandatory limit of £30,000.00 has not changed since 2008 and has failed to keep pace with rising building costs.  It can easily cost three times this amount to build a ground floor extension. Different Local authorities have different approaches to this issue creating a postcode.

September 2023

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