Written evidence submitted by Midland Heart Limited [DPH 024]

Top line

Affordable access to safe and suitable homes is a core function of the social housing sector.  We develop and manage homes for a wide range of needs, and frequently arrange for adaptations to be installed upon request.  Where such works offer a general benefit to current and future occupants, we arrange installation of adaptations in communal spaces without charging residents.  We also support customers to seek Disabled Facilities Grants for specialist equipment where needed.

Nevertheless, provision for households with disabilities can raise conflicting considerations and additional challenges when reletting homes.  We have introduced internal policies aimed at broadening choice for disabled tenants, but would welcome measures to further improve availability of accessible housing and the independence this can offer.

Key points

• There is a balance to be struck between the supply of new accessible homes, and adaptation to accommodate residents’ needs; both approaches can be helpful for existing and prospective residents.

• Development of specialist housing for the disabled residents would better meet people’s specific needs if local authorities and housing providers had detailed information regarding demand and projected needs in the local area.  These homes should be dispersed in order to offer a choice of locations and proximity to preferred amenities.  Provision could be expanded further via policies standardising features such as wetrooms in certain types of property.

• Adaptation via the Disabled Facilities Grant can be difficult to pursue and is often hindered by unexplained delays to the necessary works.  As heavily adapted properties may be harder to relet, we would welcome amendments to allocations policy enabling households to ‘queue jump’ when bidding for a home that already has adaptations suited to their needs.

About Midland Heart 

We are a leading housing organisation, delivering homes and services across the Midlands that enable people to live independently.  We own and manage 34,000 homes and are dedicated to providing decent, affordable homes combined with excellent services to over 70,000 customers. 

We are committed to spending £200m over five years to improve the condition and energy efficiency of our homes.  We also have an expanding development programme with an ambition to deliver over 600 new homes a year.  We build homes principally for low-cost rent, in line with our social purpose, and also offer affordable shared-ownership options for prospective homeowners. 

Alongside general needs, we offer a wide variety of supported living accommodation, from extra care retirement schemes to temporary accommodation for people with a history of homelessness.  We are an experienced provider of specialist and adapted accommodation for people with a range of needs, receiving over 700 adaptation requests in the three years to 31st August 2023 and agreeing these in 85% of cases. 

A significant proportion of our properties (46%) currently have adaptations to accommodate disability, most commonly requested for adult tenants and in particular for the over-60s.  Over three quarters of these homes are for general needs.  The works are most commonly initiated by an occupational therapist or by direct liaison between Midland Heart and the residents.  The most common additions are lever handle taps and grab rails, and in over half of cases we arrange to complete the works in-house. 

Over a third of our adapted homes, however, have major adaptations in place, such as ramps, accessible kitchens and bathrooms or lifts.  Whilst we encourage customers to choose and manage their homes independently, however, in some cases we may decline a request and instead propose a priority move to more accessible housing.  This would take place where the equipment would require ongoing servicing and maintenance that the customer could not realistically afford, or where its presence may carry a disproportionate impact on the property or other residents.

Detailed response

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

Better data collation nationwide would be enormously helpful in identifying and addressing specific housing needs.  Strategic Housing Market Assessments typically yield a number and/or percentage of new homes to be built for disabled residents within a local area, but not what type of needs are as-yet unmet or precisely what fixtures are necessary. 

New homes intended as accessible therefore often cater for ‘identikit’ wheelchair access rather than sensory/cognitive issues, or children’s specific needs.  Similarly, local authority nominations do not usually take into account which member of a household has disabilities.  A property with a wheelchair-accessible kitchen, for example, will not suit the needs of a household with able-bodied adults and a disabled child.

We would also welcome more specific guidance regarding the siting of accessible homes.  Where local authorities try to meet agreed targets by including higher numbers of accessible homes across a limited number of developments, or within a single new estate, this risks creating ‘ghettos’ for the disabled, who may find themselves with a limited choice of places to live and reduced access to the amenities they need.  It is unclear whether consideration is necessarily given to proximity to schools, hospitals, shops and so on when siting accessible homes.

Strengthened Building Regulations could expand upon the concept of lifetime homes.  For example, permissible room sizes do not always allow for the addition of larger adaptations such as through-floor lifts.  We feel that it would be helpful for updated Building Regulations to mandate that M4(2) should be the norm for new homes, to make future adaptation simpler; and to ensure M4(3) remains enforceable by local authorities, but only where they have evidence to demonstrate the need for accessible dwellings in that particular area.

However, it is perhaps unrealistic to discuss access to disability-friendly housing options without touching upon the subject of funding; accessible homes simply cost more to develop.  Housing providers currently carry an extra £30,000 per unit development cost for accessible homes, in addition to Section 106 contributions.  These homes also attract higher maintenance costs during their lifetime.  Ultimately, at a time when running costs and materials are increasingly expensive, our ability to supply and manage homes to meet demand would be enhanced by further financial support from Government.

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

In theory, we believe that it does.  Each local planning authority is subject to the Public Sector Equality Duty in carrying out its duties – such as identifying all types of housing needed in their areas as well as engaging with the local community/other interested parties to developing plan policies.

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?

We do not feel that there has been a significant shift over the last year.  There does not appear to have been an update to the relevant section of Building Regulation M that would require widespread change.

Certain issues remain commonplace.  Fire doors in our retirement schemes may be too heavy and stiff for frailer, less mobile residents.  Residents’ efforts to remedy this by wedging them open, or fitting additional handles, can compromise the doors effectiveness.  We are working to make the doors more user-friendly without affecting their fire safety function.

In our view, private developers have little incentive to deliver accessible homes.  These homes tend to have larger floorplates but are harder to sell, making them therefore less profitable.  Developers may favour limiting themselves to compliance with Local Development Plans, but such plans may themselves prove unviable for housing associations or the private sector.  In practice, this can lead to insufficient provision.

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

Government, local authorities, developers and social landlords should provide a range of dwellings to satisfy the needs of the local area, including accessible homes where there is evidence of existing demand. Where fully-accessible homes are provided in areas where there is little need for them, we have found that they are difficult to sell or let. An alternative, more effective way of ensuring we provide homes that are suitable for a wider range of needs, is our recently adopted policy of making sure all of our bungalows have wetrooms.

Housing provision for the disabled needs a more joined-up approach.  Strategic Housing Market Assessments do not adequately inform specific local needs, and local authorities struggling to meet policy quotas may resort to seeking clusters of accessible homes in limited locations unsuitable for some applicants.  For example, one council within our area of operation has sought 10% accessible units on a single affordable development.  Planners cited a waiting list for such properties, but were unable to confirm individual households’ needs or whether applicants had expressed an interest in the location. 

Given the lead time from planning a new housing development to its completion, we might reasonably expect many households waiting for accessible homes to have made alternative arrangements in the interim, or for their needs to have evolved.  Local planning policy and local housing registers are currently disconnected. Providers, and therefore prospective tenants, would benefit significantly from accurate, current information about local housing requirements. 

Another solution would be to include retirement properties on a higher proportion of developments; our offer for age 55+ is accessible as standard.  Retirement/sheltered schemes also feature care and support onsite.  Alternatively, we would favour a renewed focus on properties adaptable for later works as and when needed; these are £20-25,000 cheaper to build per unit than fully-accessible homes.  In many cases, tailored adaptation is preferable to a standard-spec accessible home, though this does of course need occupational therapists’ assessment and full details of needs. 

However, it remains very difficult to predict the ongoing level of demand in any local area, and where change to a home is needed this may mean removing expensive fittings already in situ.  Very specific adaptations can prolong void periods.  In other cases, people accept allocations with features that are not suitable for them, such as lowered worktops. 

There is therefore a persistent difficulty in striking a balance between hyperspecialised homes (sometimes constructed for a specific household) and a cookie-cutter approach to providing wheelchair-enabled properties.  The latter is more efficient in terms of supply, but overlooks a range of needs; and bespoke adaptations take time and funding.

Does the Disabled Facilities Grant fully support housing adaptations?

Bidding and applications processes typically require prospective tenants to use a computer, and this can present a barrier.  Unless they can call upon friends or family to help, some applicants may be digitally excluded; they may lack internet access, computer literacy, fluency in English, cognitive capacity or practical support.  This is further complicated for disabled applicants unable to use standard technology. 

Grant-funded works are also subject to delays.  A tenant or their general practitioner may contact Social Services, leading to a pre-application via the local authority before we are contacted about specialist major works to a property.  Nevertheless, after grant funding has been secured it may still take 6-12 months for the local authority to arrange for specialist works to be completed. 

During this time, communications from the agencies involved may also be unreliable after we have agreed to the works.  The most frequent issue raised by our tenants in relation to this process is unexplained delays, where the local authority and contractors do not provide updates.

Nevertheless, it is often more practical to adapt for an incoming household than to build/source specialist homes.  A full one-size-fits-all is not necessarily appropriate – for example, there is no need for an accessible oven if it is a young child who is disabled.  We are happy to install large equipment such as lifts or hoists and now operate a policy of wetrooms in all bungalows to improve accessibility. 

Adaptation carries its own peripheral considerations.  Where adaptations are removed ahead of reletting, vouchers to redecorate may be insufficient.  Supported schemes’ vulnerable residents have been known to exchange them to fund substance misuse.  Where residents are physically unable to redecorate for themselves, or are unlikely to use vouchers for their intended purpose, we act on requests to make good ahead of reletting.  In effect we are redefining ‘making good’ to include decorating, applying separate void standards for adapted properties.  Of course, some adaptations make reletting harder, such as through-floor lifts that take up living space.  In this regard, accessibility-ready homes limit cost and delays.

In cases where adaptations are particularly expensive or require major changes, we will suggest an alternative property – liaising with local authorities if we have no suitable properties vacant in the area.  Moves and adaptations may, however, mean longer wait times for a suitable home.  Going forward this could be exacerbated by the cost of the incoming new Decent Homes Standard, leading to reduced supply as landlords channel their limited incomes increasingly toward refurbishment and energy efficiency in their existing stock.

How can the Government ensure it provides sufficient provisions to support disabled residents who do not live in new build homes?

As discussed above, we believe that these household would benefit from measures improving the Disabled Facilities Grant process.  This assistance should be easier to apply for, with support if needed.  Specific guidance would be helpful regarding timeframes and communications between the agencies involved, to expedite works and to clarify what applicants should expect.

Emergency/temporary accommodation (TA) should be a focal area for improvement, as this is often scarce and very rarely disability-friendly.  Homeless applicants have little choice but to remain in unsuitable accommodation whilst waiting for occupational therapists’ assessment.  Such short-term housing is nevertheless often excluded from broader policymaking aimed at disability.  We would welcome opportunities to work with Government to source suitable TA and to expedite moves to homes that meet their needs.

It could be helpful for local and central Government to commission services to include a full Equality Impact Assessment in order to understand diverse needs, and to check that providers’ properties are suitable.  This would embed the practice of researching current needs.  Details could be passed to prospective providers and contracts drawn up tailored to local people’s requirements. 

Adjustments to allocations policy could also support households with disabilities.  We consider it reasonable for bidders with disabilities to be prioritised where a property is already adapted appropriately.  This could reduce wait times for disabled applicants, and curb void periods. 

September 2023

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