Written evidence submitted by Hft [008]

1           About Hft

1.1         Hft is a learning disability charity working across England and North Wales. We provide support to more than 2,000 adults with a learning disability, and employ over 2,500 staff to deliver a range of services including residential care, supported living, day services and respite care.

1.2         Hft was founded 60 years ago by a group of families who believed that, with the right support, their relatives were capable of more than society expected of them. Today, we still share that same vision to support adults with a learning to live their best life possible, where they can thrive and not just survive.

1.3         We also support adults with a learning disability in several other ways, for example, to find friendship and connection through our Luv2MeetU project. Members are supported to get out, try new things, meet new people, make friends and develop relationships if they choose. Through Luv2MeetU we support people to achieve goals in life through becoming more involved in their local community, learning new skills, widening their circle of friends and signposting them to different opportunities and services.

1.4         Hft provides supported housing and residential care nationally. We currently have around 526 units of supported living properties and around 200 units of residential care properties. We operate a centralised Commercial Housing Team that has responsibility for managing the tenancies and properties such as rent collection, tenancy support, day to day and planned repairs, and property compliance works.

1.5         We are also undertaking a review of some of our properties to ensure they will meet the needs of the people we support and their future requirements, as well as the expectations of individuals, families, commissioners and funders.

1.6         Our work also extends to employment support, advice for family carers as well as the assessment and provision of assistive technology.

1.7         Through engagement with decision makers, the Public Affairs and Policy function at Hft seeks to affect positive change for adults who have a learning disability and the social care sector. We work closely with adults who have a learning disability to ensure their experiences and opinions inform our work. Our efforts focus on social care funding and reform, employment, housing and attitudes.

1.8         As a charity supporting adults with a learning disability, our written response reflects this perspective.

2           Context: Housing and learning-disabled adults

1.1                        At present, between 23% and 25% of the identified population of people with learning disabilities/autistic people live in supported housing. A further 23% of this population live in mainstream housing with a care/support package, 15% are living in residential/ nursing care settings and 37% live with family and friends.[1]

1.2                        While things have come a long way since people with a learning disability were locked away in large institutions, these numbers do not illustrate how a lack of appropriate housing means that far too many still cannot find homes which are accessible or which meet their wants and needs. This might include housing which is accessible for wheelchairs or has other adaptations, including assistive technology or robust features (such as durable fixtures, fittings, and furniture) but also, and perhaps most importantly, provides individuals with choice about where they live – city or country – and with who – alone, with housemates or a partner. 

1.3                        When considering physical accessibility, it is clear there is a chronic shortage. In England only 7% of homes offer minimal accessibility features.[2]  However, when looking specifically at the needs of adults with a learning disability, who may require physically accessible homes, but also other adaptations - such as assistive technology or specialist, robust fixtures and fittings - the picture is even more unclear.

1.4                        In 2012, 82% of local authorities reported that there was a shortage of suitable housing for adults with a learning disability in their area, and 67% said that it had become more difficult for adults with a learning disability to have their housing needs met.[3] Clearly this research is out-of-date, and while we know that anecdotally this is still the case, there is no recent data to confirm this.

1.5                        This lack of accessible housing has a profound impact for learning disabled adults. It can impact health and mobility, work opportunities, feelings of social isolation, and the ability to live independently.

1.6                        It is likely that the need for housing which meets the individual needs of learning-disabled adults will only grow in the future. The relevant population of adults with learning disabilities and/or autism is estimated to increase to c.169,500 by 2037, an increase of nearly 20,000 people over the next 15 years. Over this period it is likely that fewer people will be living:

-          in registered care settings due to commissioning trends

-          with family/informal carers (particularly older carers)

-          in a secure hospital setting, should the government meet it’s Transforming Care targets

1.7                        Given this context, the Learning Disability and Autism Housing Network has recently estimated that between 25,800 units and 32,800 units of additional supported housing will be required by 2037 (equivalent to between c.1,800 and c.2,300 units per annum over the period to 2037).[4]

1.8                        It is therefore clear that far more needs to be done to increase the availability of accessible housing and create a future where people with a learning disability can exercise their right to live independently, in a home they can access, and with choice about where and with who they live. Our response addresses the questions asked as part of the call for evidence, and what more can be done to make this a reality.

Our response

1.9                        It is clear that the systems used to identify disabled people’s requirements and deliver accessible houses are weak and contribute to the status quo. There are a number of actions the Government and Local authorities could take in order to ensure disabled residents across England have access to accessible and adaptable housing.

Improved understanding and needs-based planning

1.10                   Local authorities should have a better understanding of their population, in order to successfully identify the needs of adults with a learning disability and plan and build based upon this. Unfortunately, at present, local authorities are making decisions about current need and future demand for accessible houses based on very limited data.

1.11                   It is true that the National Planning Policy Framework reads that “…the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to… people with disabilities…’ However, Only 12 per cent of local authorities rated the data on the population of disabled adults available to them as ‘good’ or ‘very good’.[5]  This is a clear precursor to a lack of suitable housing.

1.12                   Recommendations

1.12.1             Individuals responsible for planning and commissioning care and housing should be required to work together to ensure there is an appropriate supply of housing which meets the needs of people with a learning disability. The aim to integrate housing into local health and care strategies was proposed as part of the Government’s Social Care White Paper, but was absent in their most recent update. We strongly recommend that the Government reinstate this objective and accompanying investment.  

Improved accessibility standards

1.13                   In August 2022, ministers pledged to introduce new rules that will force all new homes in England to be built to the M4(2) standard of accessibility, except for cases where this is “impractical and unachievable”.

1.14                   Part M4(2) has 16 accessible or adaptable features, and is broadly equivalent to the Lifetime Homes Standards, which are a series of 16 design criteria that are intended to make homes more easily adaptable for lifetime use at minimal cost. Although they do not make housing fully accessible, these features enable most adaptations to be retro-fitted quickly and cheaply.

1.15                   This is a welcome step, however, it is worth noting that few local authorities across Britain set targets for accessible housing, and many report that developers are reluctant to build accessible houses, as they see them as less profitable. Indeed 68% of local authorities report that developers do not always comply with accessibility requirements, with only 3% having taken legal action against developers on the grounds of accessibility.[6]

1.16                   Furthermore, while the M4(2) standard is a brilliant tool to support accessible housing, it largely focuses on the design features to improve accessibility for those with a physical disability. This means that this policy will not address the housing needs of adults with a learning disability who may require other design features – such as robust fittings and assistive technology. 

1.17                   While there are some existing resources which are useful overall there is insufficient guidance and an absence of standards relating to housing for adults with a learning disability for either Local Authorities or developers to refer to.

1.18                   Recommendation:

1.19                   Should the consultation result in the M4(2) standards becoming mandatory for all new homes, the Government should clarify where accountability for this will lie, how adherence will be monitored, and what the consequences will be for non-compliance. With little incentive for developers to currently comply with accessibility requirements, it is hard to see how this will change without setting out the above.

1.20                   The Government should work with adults with a learning disability and care providers to establish a new set of accessibility standards to meet the housing needs for learning disabled people.

Improved funding mechanisms

1.21                   The Disabled Facilities Grant is given to local authorities for individuals who require changes or adaptations to be made to their home, making it safe and accessible for them to continue living in. However, despite providing a vital service supporting people to live in an accessible home, the Grant has been referred to as one of the ‘best kept secrets’ of the UK welfare system due to barriers to access it and issues with the system:

1.21.1              Delays: Delays to the assessment and building process mean that individuals are spending years waiting for the accessible equipment they need to live comfortably and safely in their own home. The Government has mandated a timescale of 18 months for the application process. However, a Freedom of Information request highlighted that in nine council areas disabled people had to wait over a year on average just to see an occupational therapist for an assessment, let alone for the work to be completed.   

1.21.2              Restrictive upper limit: In England, the maximum amount councils can give each applicant is £30,000; in Wales, it’s £36,000.  Individuals have reported that this limitation means that on some occasions, the cost of adaptations fall outside of the cap and can’t be carried out, are ineffective, or are of poor quality. This cap has not changed since 2008, despite an independent review of the Grant, undertaken in 2018, recommending that the Grant increase with inflation.  Some councils offer grants for costs above £30,000, but these range dramatically, resulting in a postcode lottery. In some cases a loan is offered for costs above £30,000 instead, which has led to individuals dropping out of the scheme altogether. 

1.22                   Recommendations:

1.22.1             The Disabled Facilities Grant:

1.22.2             Should receive additional funding to enable the cap of £30,000 for each grant to be immediately lifted to reflect the current cost of living. This must also be reviewed and increased in line with inflation, with regional weighting awarded for variable building costs and professional fees

1.22.3             Should be streamlined and easier to access for both individuals and organisations providing housing. This will ensure it can be administered quickly to ensure people can live safely within their own home.

September 2023

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